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1 David E Czelusniak, Esq. (SBN: 118483)

SKEBBA, BUECHLER & ORLOV

2 777 South Figueroa Street, Suite 1507 Los Angeles, CA 90017 3 Telephone: (714) 824-0359 4 Facsimile: (213) 689-3523 Authorized E-Service Address: David.Czelusniak@aig.com 5 6 Attorneys for Defendant, Vornado Air, LLC 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 UNITED STATES DISTRICT COURT 10 CENTRAL DISTRICT OF CALIFORNIA 11 12 ALLIANCE OF SCHOOL CASE NO. 2:21-cv-09356-JAK-MAA

COOPERATIVE INSURANCE

13 PROGRAMS, STIPULATED PROTECTIVE ORDER 14 Plaintiff,

AS REVISED BY COURT

15 vs. 16 (Assigned to U.S. District John A. Kronstadt) 17 VORNADO AIR LLC, A KANSAS Complaint Filed: 12/02/2021

CORPORATION; VORNADO AIR

18 CIRCULATION SYSTEMS, INC., A Trial Date: 02/26/2022

DISSOLVED KANSAS

19 CORPORATION; and Does 1 to 30 20 inclusive, 21 Defendants. 22 23 I.PURPOSES AND LIMITATIONS 24 A.Discovery in this action is likely to involve production of confidential, proprietary, or 25 private information for which special protection from public disclosure and from use for any 26 purpose other than prosecuting this litigation may be warranted. Accordingly, the parties hereby 27 stipulate to and petition the Court to enter the following Stipulated Protective Order. The parties 28 acknowledge that this Order does not confer blanket protections on all disclosures or responses 1

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1 to discovery and that the protection it affords from public disclosure and use extends only to the 2 limited information or items that are entitled to confidential treatment under the applicable legal 3 principles. The parties further acknowledge, as set forth in Section XIII(C), below, that this 4 Stipulated Protective Order does not entitle them to file confidential information under seal; 5 Civil Local Rule 79-5 sets forth the procedures that must be followed and the standards that will 6 be applied when a party seeks permission from the Court to file material under seal. 7 II.GOOD CAUSE STATEMENT 8 A.This action is likely to involve trade secrets, customer and pricing lists and other 9 valuable research, development, commercial, financial, technical and/or proprietary information, 10 accounts receivable, customer credit balances, retail sales, expenses, inventory, raw materials for 11 which special protection from public disclosure and from use for any purpose other than 12 prosecution of this action is warranted. Such confidential and proprietary materials and 13 information consist of, among other things, confidential business or financial information, 14 information regarding confidential business practices, or other confidential research, 15 development, or commercial information (including information implicating privacy rights of 16 third parties), information otherwise generally unavailable to the public, or which may be 17 privileged or otherwise protected from disclosure under state or federal statutes, court rules, case 18 decisions, or common law. Accordingly, to expedite the flow of information, to facilitate the 19 prompt resolution of disputes over confidentiality of discovery materials, to adequately protect 20 information the parties are entitled to keep confidential, to ensure that the parties are permitted 21 reasonable necessary uses of such material in preparation for and in the conduct of trial, to 22 address their handling at the end of the litigation, and serve the ends of justice, a protective order 23 for such information is justified in this matter. It is the intent of the parties that information will 24 not be designated as confidential for tactical reasons and that nothing be so designated without a 25 good faith belief that it has been maintained in a confidential, non-public manner, and there is 26 good cause why it should not be part of the public record of this case. 27 /// 28 /// 2

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1 III.DEFINITIONS 2 A.Action: Alliance of School Cooperative Insurance Programs vs. Vornado Air, LLC. 3 Case Number 2:21-cv-09356-JAK-MAA. 4 B.Challenging Party: A Party or Non-Party that challenges the designation of 5 information or items under this Order. 6 C.“CONFIDENTIAL” Information or Items: Information (regardless of how it is 7 generated, stored or maintained) or tangible things that qualify for protection under 8 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 9 Statement. 10 D.Counsel: Outside Counsel of Record and House Counsel (as well as their support 11 staff). 12 E.Designating Party: A Party or Non-Party that designates information or items that it 13 produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 14 F.Disclosure or Discovery Material: All items or information, regardless of the medium 15 or manner in which it is generated, stored, or maintained (including, among other things, 16 testimony, transcripts, and tangible things), that are produced or generated in disclosures 17 or responses to discovery in this matter. 18 G.Expert: A person with specialized knowledge or experience in a matter pertinent to 19 the litigation who has been retained by a Party or its counsel to serve as an expert witness 20 or as a consultant in this Action. 21 H.House Counsel: Attorneys who are employees of a party to this Action. House 22 Counsel does not include Outside Counsel of Record or any other outside counsel. 23 I. Non-Party: Any natural person, partnership, corporation, association, or other legal 24 entity not named as a Party to this action. 25 J.Outside Counsel of Record: Attorneys who are not employees of a party to this Action 26 but are retained to represent or advise a party to this Action and have appeared in this 27 Action on behalf of that party or are affiliated with a law firm which has appeared on 28 behalf of that party, and includes support staff. 3

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1 K.Party: Any party to this Action, including all of its officers, directors, employees, 2 consultants, retained experts, and Outside Counsel of Record (and their support staffs). 3 L.Producing Party: A Party or Non-Party that produces Disclosure or Discovery Material 4 in this Action. 5 M.Professional Vendors: Persons or entities that provide litigation support services (e.g., 6 photocopying, videotaping, translating, preparing exhibits or demonstrations, and 7 organizing, storing, or retrieving data in any form or medium) and their employees and 8 subcontractors. 9 N.Protected Material: Any Disclosure or Discovery Material that is designated as 10 “CONFIDENTIAL.” 11 O.Receiving Party: A Party that receives Disclosure or Discovery Material from a 12 Producing Party. 13 IV.SCOPE 14 A.The protections conferred by this Stipulation and Order cover not only Protected 15 Material (as defined above), but also (1) any information copied or extracted from 16 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 17 Material; and (3) any testimony, conversations, or presentations by Parties or their 18 Counsel that might reveal Protected Material. 19 B.Any use of Protected Material at trial shall be governed by the orders of the trial judge. 20 This Order does not govern the use of Protected Material at trial. 21 V.DURATION 22 A. Once a case proceeds to trial, all of the information that was designated as 23 confidential or maintained pursuant to this Protective Order becomes public and will be 24 presumptively available to all members of the public, including the press, unless 25 compelling reasons supported by specific factual findings to proceed otherwise are made 26 to the trial judge in advance of the trial. See Kamakana v. City and County of Honolulu, 27 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing “good cause” showing for sealing 28 documents produced in discovery from “compelling reasons” standard when merits- 4

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1 related documents are part of court record). Accordingly, the terms of this Protective 2 Order do not extend beyond the commencement of the trial. 3 B. Even after final disposition of this litigation, the confidentiality obligations 4 imposed by this Order shall remain in effect until a Designating Party agrees otherwise in 5 writing or a court order otherwise directs. Final disposition shall be deemed to be the 6 later of (1) dismissal of all claims and defenses in this Action, with or without prejudice; 7 and (2) final judgment herein after the completion and exhaustion of all appeals, 8 rehearings, remands, trials, or reviews of this Action, including the time limits for filing 9 any motions or applications for extension of time pursuant to applicable law. 10 VI.DESIGNATING PROTECTED MATERIAL 11 A.Exercise of Restraint and Care in Designating Material for Protection 12 1.Each Party or Non-Party that designates information or items for protection 13 under this Order must take care to limit any such designation to specific material that 14 qualifies under the appropriate standards. The Designating Party must designate for 15 protection only those parts of material, documents, items, or oral or written 16 communications that qualify so that other portions of the material, documents, items, or 17 communications for which protection is not warranted are not swept unjustifiably within 18 the ambit of this Order. 19 2.Mass, indiscriminate, or routinized designations are prohibited. Designations 20 that are shown to be clearly unjustified or that have been made for an improper 21 purpose (e.g., to unnecessarily encumber the case development process or to 22 impose unnecessary expenses and burdens on other parties) may expose the 23 Designating Party to sanctions. 24 3.If it comes to a Designating Party’s attention that information or items that it 25 designated for protection do not qualify for protection, that Designating Party 26 must promptly notify all other Parties that it is withdrawing the inapplicable 27 designation. 28 /// 5

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1 B.Manner and Timing of Designations 2 1.Except as otherwise provided in this Order (see, e.g., Section B(2)(b) below), 3 or as otherwise stipulated or ordered, Disclosure or Discovery Material that 4 qualifies for protection under this Order must be clearly so designated before the 5 material is disclosed or produced. 6 2.Designation in conformity with this Order requires the following: 7 a.For information in documentary form (e.g., paper or electronic 8 documents, but excluding transcripts of depositions or other pretrial or 9 trial proceedings), that the Producing Party affix at a minimum, the legend 10 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each 11 page that contains protected material. If only a portion or portions of the 12 material on a page qualifies for protection, the Producing Party also must 13 clearly identify the protected portion(s) (e.g., by making appropriate 14 markings in the margins). 15 b.A Party or Non-Party that makes original documents available for 16 inspection need not designate them for protection until after the inspecting 17 Party has indicated which documents it would like copied and produced. 18 During the inspection and before the designation, all of the material made 19 available for inspection shall be deemed “CONFIDENTIAL.” After the 20 inspecting Party has identified the documents it wants copied and 21 produced, the Producing Party must determine which documents, or 22 portions thereof, qualify for protection under this Order. Then, before 23 producing the specified documents, the Producing Party must affix the 24 “CONFIDENTIAL legend” to each page that contains Protected Material. 25 If only a portion or portions of the material on a page qualifies for 26 protection, the Producing Party also must clearly identify the protected 27 portion(s) (e.g., by making appropriate markings in the margins). 28 /// 6

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1 c.For testimony given in depositions, that the Designating Party identify 2 the Disclosure or Discovery Material on the record, before the close of the 3 deposition all protected testimony. 4 d.For information produced in form other than document and for any 5 other tangible items, that the Producing Party affix in a prominent place on 6 the exterior of the container or containers in which the information is 7 stored the legend “CONFIDENTIAL.” If only a portion or portions of the 8 information warrants protection, the Producing Party, to the extent 9 practicable, shall identify the protected portion(s). 10 C.Inadvertent Failure to Designate 11 1.If timely corrected, an inadvertent failure to designate qualified information or 12 items does not, standing alone, waive the Designating Party’s right to secure 13 protection under this Order for such material. Upon timely correction of a 14 designation, the Receiving Party must make reasonable efforts to assure that the 15 material is treated in accordance with the provisions of this Order. 16 VII. CHALLENGING CONFIDENTIALITY DESIGNATIONS 17 A.Timing of Challenges 18 1.Any party or Non-Party may challenge a designation of confidentiality at any 19 time that is consistent with the Court’s Scheduling Order. 20 B.Meet and Confer 21 1.The Challenging Party shall initiate the dispute resolution process under Local 22 Rule 37.1 et seq. and pursuant to Magistrate Judge Maria A. Audero's Mandatory Telephonic Conference for Discovery Disputes. See http:// 23 www.cacd.uscourts.gov/honorable-maria-audero. 24 C.The burden of persuasion in any such challenge proceeding shall be on the 25 Designating Party. Frivolous challenges, and those made for an improper purpose 26 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 27 expose the Challenging Party to sanctions. Unless the Designating Party has waived 28 or withdrawn the confidentiality designation, all parties shall continue to afford the material in question the level of protec7t ion to which it is entitled under the Producing

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1 Party's designation until the Court rules on the challenge. 2 VIII.ACCESS TO AND USE OF PROTECTED MATERIAL 3 A.Basic Principles 4 1.A Receiving Party may use Protected Material that is disclosed or produced by 5 another Party or by a Non-Party in connection with this Action only for 6 prosecuting, defending, or attempting to settle this Action. Such Protected 7 Material may be disclosed only to the categories of persons and under the 8 conditions described in this Order. When the Action has been terminated, a 9 Receiving Party must comply with the provisions of Section XIV below. 10 2.Protected Material must be stored and maintained by a Receiving Party at a 11 location and in a secure manner that ensures that access is limited to the persons 12 authorized under this Order. 13 B.Disclosure of “CONFIDENTIAL” Information or Items 14 1.Unless otherwise ordered by the Court or permitted in writing by the 15 Designating Party, a Receiving Party may disclose any information or item 16 designated “CONFIDENTIAL” only to: 17 a.The Receiving Party’s Outside Counsel of Record in this Action, as well 18 as employees of said Outside Counsel of Record to whom it is reasonably 19 necessary to disclose the information for this Action; 20 b.The officers, directors, and employees (including House Counsel) of the 21 Receiving Party to whom disclosure is reasonably necessary for this 22 Action; 23 c.Experts (as defined in this Order) of the Receiving Party to whom 24 disclosure is reasonably necessary for this Action and who have signed the 25 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 26 d.The Court and its personnel; 27 e.Court reporters and their staff; 28 /// 8

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1 f.Professional jury or trial consultants, mock jurors, and Professional 2 Vendors to whom disclosure is reasonably necessary or this Action and 3 who have signed the “Acknowledgment and Agreement to be Bound” 4 attached as Exhibit A hereto; 5 g.The author or recipient of a document containing the information or a 6 custodian or other person who otherwise possessed or knew the 7 information; 8 h.During their depositions, witnesses, and attorneys for witnesses, in the 9 Action to whom disclosure is reasonably necessary provided: (i) the 10 deposing party requests that the witness sign the “Acknowledgment and 11 Agreement to Be Bound;” and (ii) they will not be permitted to keep any 12 confidential information unless they sign the “Acknowledgment and 13 Agreement to Be Bound,” unless otherwise agreed by the Designating 14 Party or ordered by the Court. Pages of transcribed deposition testimony 15 or exhibits to depositions that reveal Protected Material may be separately 16 bound by the court reporter and may not be disclosed to anyone except as 17 permitted under this Stipulated Protective Order; and 18 i.Any mediator or settlement officer, and their supporting personnel, 19 mutually agreed upon by any of the parties engaged in settlement 20 discussions. 21 IX.PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER 22 LITIGATION 23 A. If a Party is served with a subpoena or a court order issued in other litigation that 24 compels disclosure of any information or items designated in this Action as 25 “CONFIDENTIAL,” that Party must: 26 1.Promptly notify in writing the Designating Party. Such notification shall 27 include a copy of the subpoena or court order; 28 /// 9

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1 2.Promptly notify in writing the party who caused the subpoena or order to issue 2 in the other litigation that some or all of the material covered by the subpoena or 3 order is subject to this Protective Order. Such notification shall include a copy of 4 this Stipulated Protective Order; and 5 3.Cooperate with respect to all reasonable procedures sought to be pursued by the 6 Designating Party whose Protected Material may be affected. 7 B.If the Designating Party timely seeks a protective order, the Party served with the 8 subpoena or court order shall not produce any information designated in this action as 9 “CONFIDENTIAL” before a determination by the Court from which the subpoena or 10 order issued, unless the Party has obtained the Designating Party’s permission. The 11 Designating Party shall bear the burden and expense of seeking protection in that court of 12 its confidential material and nothing in these provisions should be construed as 13 authorizing or encouraging a Receiving Party in this Action to disobey a lawful directive 14 from another court. 15 X.A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN 16 THIS LITIGATION 17 A.The terms of this Order are applicable to information produced by a Non-Party in this 18 Action and designated as “CONFIDENTIAL.” Such information produced by Non- 19 Parties in connection with this litigation is protected by the remedies and relief provided 20 by this Order. Nothing in these provisions should be construed as prohibiting a Non- 21 Party from seeking additional protections. 22 B.In the event that a Party is required, by a valid discovery request, to produce a Non- 23 Party’s confidential information in its possession, and the Party is subject to an agreement 24 with the Non-Party not to produce the Non-Party’s confidential information, then the 25 Party shall: 26 1.Promptly notify in writing the Requesting Party and the Non-Party that some or 27 all of the information requested is subject to a confidentiality agreement with a 28 Non-Party; 10

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1 2.Promptly provide the Non-Party with a copy of the Stipulated Protective Order 2 in this Action, the relevant discovery request(s), and a reasonably specific 3 description of the information requested; and 4 3.Make the information requested available for inspection by the Non-Party, if 5 requested. 6 C.If the Non-Party fails to seek a protective order from this court within 14 days of 7 receiving the notice and accompanying information, the Receiving Party may produce the 8 Non-Party’s confidential information responsive to the discovery request. If the Non- 9 Party timely seeks a protective order, the Receiving Party shall not produce any 10 information in its possession or control that is subject to the confidentiality agreement 11 with the Non-Party before a determination by the court. Absent a court order to the 12 contrary, the Non-Party shall bear the burden and expense of seeking protection in this 13 court of its Protected Material. 14 XI.UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 15 A. If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 16 Protected Material to any person or in any circumstance not authorized under this 17 Stipulated Protective Order, the Receiving Party must immediately (1) notify in writing 18 the Designating Party of the unauthorized disclosures, (2) use its best efforts to retrieve 19 all unauthorized copies of the Protected Material, (3) inform the person or persons to 20 whom unauthorized disclosures were made of all the terms of this Order, and (4) request 21 such person or persons to execute the “Acknowledgment and Agreement to be Bound” 22 that is attached hereto as Exhibit A. 23 XII.INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 24 PROTECTED MATERIAL 25 A.When a Producing Party gives notice to Receiving Parties that certain inadvertently 26 produced material is subject to a claim of privilege or other protection, the obligations of 27 the Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). 28 This provision is not intended to modify whatever procedure may be established in an e- 11

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1 discovery order that provides for production without prior privilege review. Pursuant to 2 Federal Rule of Evidence 502(d) and (e), insofar as the parties reach an agreement on the 3 effect of disclosure of a communication or information covered by the attorney-client 4 privilege or work product protection, the parties may incorporate their agreement in the 5 Stipulated Protective Order submitted to the Court. 6 XIII.MISCELLANEOUS 7 A.Right to Further Relief 8 1.Nothing in this Order abridges the right of any person to seek its 9 modification by the Court in the future. 10 B.Right to Assert Other Objections 11 1.By stipulating to the entry of this Protective Order, no Party waives any right it 12 otherwise would have to object to disclosing or producing any information or item 13 on any ground not addressed in this Stipulated Protective Order. Similarly, no 14 Party waives any right to object on any ground to use in evidence of any of the 15 material covered by this Protective Order. 16 C.Filing Protected Material 17 1.A Party that seeks to file under seal any Protected Material must comply with 18 Civil Local Rule 79-5. Protected Material may only be filed under seal pursuant 19 to a court order authorizing the sealing of the specific Protected Material at issue. 20 If a Party's request to file Protected Material under seal is denied by the Court, 21 then the Receiving Party may file the information in the public record unless 22 otherwise instructed by the Court. 23 XIV.FINAL DISPOSITION 24 A.After the final disposition of this Action, as defined in Section V, within sixty (60) 25 days of a written request by the Designating Party, each Receiving Party must return all 26 Protected Material to the Producing Party or destroy such material. As used in this 27 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 28 summaries, and any other format reproducing or capturing any of the Protected Material. 12

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] Whether the Protected Material is returned or destroyed, the Receiving Party must submit 2 a written certification to the Producing Party (and, if not the same person or entity, to the 3 Designating Party) by the 60 day deadline that (1) identifies (by category, where 4 appropriate) all the Protected Material that was returned or destroyed and (2) affirms that 5 the Receiving Party has not retained any copies, abstracts, compilations, summaries or 6 any other format reproducing or capturing any of the Protected Material. 7 Notwithstanding this provision, Counsel are entitled to retain an archival copy of all 8 pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda, 9 correspondence, deposition and trial exhibits, expert reports, attorney work product, and 10 consultant and expert work product, even if such materials contain Protected Material. 11 Any such archival copies that contain or constitute Protected Material remain subject to 12 this Protective Order as set forth in Section V. 13 B. Any violation of this Order may be punished by any and all appropriate measures 14 including, without limitation, contempt proceedings and/or monetary sanctions. 15 ||} IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 16 17 || Dated:__September 27,2020 Attorney for Plaintiff, Alliance of Schools for 18 Cooperative Insurance Program 19 . Dated: September 27, 2022 DA wi C Cgebeeneate 20 Attorney for Defendant, Vornado Air, LLC 21 22

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED,

23 so 24 || Dated: September 30, 2022

HONO LE MARIA A. AUDERO

25 United States Magistrate Judge 26 27 28 13

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1 PROOF OF SERVICE 2 STATE OF CALIFORNIA, ) 3 COUNTY OF LOS ANGELES )ss. ) I am employed in the County of Los Angeles, State of California. I am over the age of 5 || eighteen years and not a party to the within action. My business address is: 777 South ‘ Figueroa Street, Suite 1507, Los Angeles, CA 90017.

7 On September 28, 2022, I served the foregoing document described as STIPULATED PROTECTIVE ORDER on interested parties in this action by placing g || true copies thereof enclosed in sealed envelopes addressed as follows: 9 || Katherine A. Sandoval, Esq.

MATTHIESEN, WICKET & LEHRER S.C.

10 || 1851 East First Stree, Suite 1150, 1 Santa Ana, CA 92705 Tel: (800) 637-9176 12. || Fax: (262) 673-3766 Authorized Address: 13 || ksandoval@mwl-law.com yvillela@mwl-law.com 14 Attorneys for Plaintiff, Alliance of Schools 15 Cooperative Insurance Programs 16 x] BY EMAIL OR ELECTRONIC TRANSMISSION [CRC Rule 2.260(c)]: Only by e- 17 mailing the document(s) to the persons at the authorized e-mail address(es) listed, in accordance with S.B. 1146, signed into law on September 18, 2020. I confirm that prior 18 to initially serving any represented party electronically, I confirmed by telephone or 19 email the appropriate electronic service address for the counsel being served. No electronic message or other indication that the transmission was unsuccessful was 20 received within a reasonable time after the transmission. 21 Xx] STATE - I declare under penalty of perjury under the laws of the State of California that 22 the above is true and correct. 23 Executed on September 28, 2022 in Los Angeles, California. _ : 24 5 Krystine Tally és 26 27 28 14

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