Case 2:22-cv-04195-MEMF-RAO Document 17 Filed 10/07/22 Page 1 of 16 Page ID #:946

1 *Matthew F. Batezel (State Bar No. 185147) 2 mbatezel@plawp.com (*lead counsel) Amanda C. Glenn (State Bar No. 326165) 3 aglenn@plawp.com 4 PACIFIC LAW PARTNERS, LLP 15615 Alton Parkway, Suite 240 5 Irvine, CA 92618 6 (949)242-2441 Fax (949)242-2446 7 Attorneys for Defendant 8 STATE FARM GENERAL INSURANCE COMPANY

9 10

UNITED STATES DISTRICT COURT

11 12 CENTRAL DISTRICT OF CALIFORNIA

13 14 BETTY JEAN COURTNEY, an ) Case No.: 2:22-cv-04195-MEMF-RAO individual ) 15 ) [Los Angeles Superior Court Case No. 16 ) 21STCV26089.] Plaintiff, ) 17 ) 18 vs. ) STIPULATED PROTECTIVE ) ORDER 19 )

20 STATE FARM GENERAL ) Complaint filed: May 7, 2021 INSURANCE COMPANY, an Illinois ) 21 Corporation, authorized to do business ) 22 in the State of California; and DOES 1 ) to 10, inclusive, ) 23 ) 24 Defendants. ) ) 25 26 27

28 Case 2:22-cv-04195-MEMF-RAO Document 17 Filed 10/07/22 Page 2 of 16 Page ID #:947

1 1. A. PURPOSES AND LIMITATIONS 2 Discovery in this action is likely to involve production of confidential, 3 proprietary or private information for which special protection from public 4 disclosure and from use for any purpose other than prosecuting this litigation may 5 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 6 enter the following Stipulated Protective Order. The parties acknowledge that this 7 Order does not confer blanket protections on all disclosures or responses to 8 discovery and that the protection it affords from public disclosure and use extends 9 only to the limited information or items that are entitled to confidential treatment 10 under the applicable legal principles. 11 12 B. GOOD CAUSE STATEMENT 13 This action is likely to involve trade secrets, customer and pricing lists and 14 other valuable research, development, commercial, financial, technical and/or 15 proprietary information for which special protection from public disclosure and 16 from use for any purpose other than prosecution of this action is warranted. Such 17 confidential and proprietary materials and information consist of, among other 18 things, confidential business or financial information, information regarding 19 confidential business practices, or other confidential research, development, or 20 commercial information (including information implicating privacy rights of third 21 parties), information otherwise generally unavailable to the public, or which may be 22 privileged or otherwise protected from disclosure under state or federal statutes, 23 court rules, case decisions, or common law. Accordingly, to expedite the flow of 24 information, to facilitate the prompt resolution of disputes over confidentiality of 25 discovery materials, to adequately protect information the parties are entitled to keep 26 confidential, to ensure that the parties are permitted reasonable necessary uses of 27 such material in preparation for and in the conduct of trial, to address their handling 28 at the end of the litigation, and serve the ends of justice, a protective order for such 2 Case 2:22-cv-04195-MEMF-RAO Document 17 Filed 10/07/22 Page 3 of 16 Page ID #:948

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 7 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 8 The parties further acknowledge, as set forth in Section 12.3, below, that this 9 Stipulated Protective Order does not entitle them to file confidential information 10 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed 11 and the standards that will be applied when a party seeks permission from the court 12 to file material under seal. 13 There is a strong presumption that the public has a right of access to judicial 14 proceedings and records in civil cases. In connection with non-dispositive motions, 15 good cause must be shown to support a filing under seal. See Kamakana v. City and 16 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006); Phillips v. Gen. Motors 17 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002); Makar-Welbon v. Sony Electrics, 18 Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders 19 require good cause showing), and a specific showing of good cause or compelling 20 reasons with proper evidentiary support and legal justification, must be made with 21 respect to Protected Material that a party seeks to file under seal. The parties’ mere 22 designation of Disclosure or Discovery Material as CONFIDENTIAL does not— 23 without the submission of competent evidence by declaration, establishing that the 24 material sought to be filed under seal qualifies as confidential, privileged, or 25 otherwise protectable—constitute good cause. 26 Further, if a party requests sealing related to a dispositive motion or trial, then 27 compelling reasons, not only good cause, for the sealing must be shown, and the 28 relief sought shall be narrowly tailored to serve the specific interest to be protected. 3 Case 2:22-cv-04195-MEMF-RAO Document 17 Filed 10/07/22 Page 4 of 16 Page ID #:949

1 See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For 2 each item or type of information, document, or thing sought to be filed or introduced 3 under seal in connection with a dispositive motion or trial, the party seeking 4 protection must articulate compelling reasons, supported by specific facts and legal 5 justification, for the requested sealing order. Again, competent evidence supporting 6 the application to file documents under seal must be provided by declaration. 7 Any document that is not confidential, privileged, or otherwise protectable in 8 its entirety will not be filed under seal if the confidential portions can be redacted. 9 If documents can be redacted, then a redacted version for public viewing, omitting 10 only the confidential, privileged, or otherwise protectable portions of the document 11 shall be filed. Any application that seeks to file documents under seal in their 12 entirety should include an explanation of why redaction is not feasible. 13 14 2. DEFINITIONS 15 2.1 Action: Betty Jean Courtney v. State Farm General Insurance 16 Company, United States District Court, Case No. 2:22-cv-04195-MEMF-RAO. 17 2.2 Challenging Party: a Party or Non-Party that challenges the 18 designation of information or items under this Order. 19 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 20 how it is generated, stored or maintained) or tangible things that qualify for 21 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 22 the Good Cause Statement. 23 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 24 their support staff). 25 2.5 Designating Party: a Party or Non-Party that designates information or 26 items that it produces in disclosures or in responses to discovery as 27 “CONFIDENTIAL.” 28 2.6 Disclosure or Discovery Material: all items or information, regardless 4 Case 2:22-cv-04195-MEMF-RAO Document 17 Filed 10/07/22 Page 5 of 16 Page ID #:950

1 of the medium or manner in which it is generated, stored, or maintained (including, 2 among other things, testimony, transcripts, and tangible things) that are produced or 3 generated in disclosures or responses to discovery in this matter. 4 2.7 Expert: a person with specialized knowledge or experience in a matter 5 pertinent to the litigation who has been retained by a Party or its counsel to serve as 6 an expert witness or as a consultant in this Action. 7 2.8 House Counsel: attorneys who are employees of a party to this Action. 8 House Counsel does not include Outside Counsel of Record or any other outside 9 counsel. 10 2.9 Non-Party: any natural person, partnership, corporation, association or 11 other legal entity not named as a Party to this action. 12 2.10 Outside Counsel of Record: attorneys who are not employees of a 13 party to this Action but are retained to represent or advise a party to this Action and 14 have appeared in this Action on behalf of that party or are affiliated with a law firm 15 that has appeared on behalf of that party, and includes support staff. 16 2.11 Party: any party to this Action, including all of its officers, directors, 17 employees, consultants, retained experts, and Outside Counsel of Record (and their 18 support staffs). 19 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 20 Discovery Material in this Action. 21 2.13 Professional Vendors: persons or entities that provide litigation 22 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 23 demonstrations, and organizing, storing, or retrieving data in any form or medium) 24 and their employees and subcontractors. 25 2.14 Protected Material: any Disclosure or Discovery Material that is 26 designated as “CONFIDENTIAL.” 27 2.15 Receiving Party: a Party that receives Disclosure or Discovery 28 Material from a Producing Party. 5 Case 2:22-cv-04195-MEMF-RAO Document 17 Filed 10/07/22 Page 6 of 16 Page ID #:951

1 2 3. SCOPE 3 The protections conferred by this Stipulation and Order cover not only 4 Protected Material (as defined above), but also (1) any information copied or 5 extracted from Protected Material; (2) all copies, excerpts, summaries, or 6 compilations of Protected Material; and (3) any testimony, conversations, or 7 presentations by Parties or their Counsel that might reveal Protected Material. 8 Any use of Protected Material at trial shall be governed by the orders of the 9 trial judge. This Order does not govern the use of Protected Material at trial. 10 11 4. DURATION 12 Once a case proceeds to trial, information that was designated as 13 CONFIDENTIAL or maintained pursuant to this protective order used or introduced 14 as an exhibit at trial becomes public and will be presumptively available to all 15 members of the public, including the press, unless compelling reasons supported by 16 specific factual findings to proceed otherwise are made to the trial judge in advance 17 of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” 18 showing for sealing documents produced in discovery from “compelling reasons” 19 standard when merits-related documents are part of court record). Accordingly, the 20 terms of this protective order do not extend beyond the commencement of the trial. 21 22 5. DESIGNATING PROTECTED MATERIAL 23 5.1 Exercise of Restraint and Care in Designating Material for Protection. 24 Each Party or Non-Party that designates information or items for protection under 25 this Order must take care to limit any such designation to specific material that 26 qualifies under the appropriate standards. The Designating Party must designate for 27 protection only those parts of material, documents, items or oral or written 28 communications that qualify so that other portions of the material, documents, items 6 Case 2:22-cv-04195-MEMF-RAO Document 17 Filed 10/07/22 Page 7 of 16 Page ID #:952

1 or communications for which protection is not warranted are not swept unjustifiably 2 within the ambit of this Order. 3 Mass, indiscriminate or routinized designations are prohibited. Designations 4 that are shown to be clearly unjustified or that have been made for an improper 5 purpose (e.g., to unnecessarily encumber the case development process or to impose 6 unnecessary expenses and burdens on other parties) may expose the Designating 7 Party to sanctions. 8 If it comes to a Designating Party’s attention that information or items that it 9 designated for protection do not qualify for protection, that Designating Party must 10 promptly notify all other Parties that it is withdrawing the inapplicable designation. 11 5.2 Manner and Timing of Designations. Except as otherwise provided in 12 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 13 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 14 under this Order must be clearly so designated before the material is disclosed or 15 produced. 16 Designation in conformity with this Order requires: 17 (a) for information in documentary form (e.g., paper or electronic 18 documents, but excluding transcripts of depositions or other pretrial or trial 19 proceedings), that the Producing Party affix at a minimum, the legend 20 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 21 contains protected material. If only a portion of the material on a page qualifies for 22 protection, the Producing Party also must clearly identify the protected portion(s) 23 (e.g., by making appropriate markings in the margins). 24 A Party or Non-Party that makes original documents available for inspection 25 need not designate them for protection until after the inspecting Party has indicated 26 which documents it would like copied and produced. During the inspection and 27 before the designation, all of the material made available for inspection shall be 28 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 7 Case 2:22-cv-04195-MEMF-RAO Document 17 Filed 10/07/22 Page 8 of 16 Page ID #:953

1 documents it wants copied and produced, the Producing Party must determine which 2 documents, or portions thereof, qualify for protection under this Order. Then, 3 before producing the specified documents, the Producing Party must affix the 4 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 5 portion of the material on a page qualifies for protection, the Producing Party also 6 must clearly identify the protected portion(s) (e.g., by making appropriate markings 7 in the margins). 8 (b) for testimony given in depositions that the Designating Party identifies 9 the Disclosure or Discovery Material on the record, before the close of the 10 deposition all protected testimony. 11 (c) for information produced in some form other than documentary and 12 for any other tangible items, that the Producing Party affix in a prominent place on 13 the exterior of the container or containers in which the information is stored the 14 legend “CONFIDENTIAL.” If only a portion or portions of the information 15 warrants protection, the Producing Party, to the extent practicable, shall identify the 16 protected portion(s). 17 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 18 failure to designate qualified information or items does not, standing alone, waive 19 the Designating Party’s right to secure protection under this Order for such material. 20 Upon timely correction of a designation, the Receiving Party must make reasonable 21 efforts to assure that the material is treated in accordance with the provisions of this 22 Order. 23 24 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 25 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 26 designation of confidentiality at any time that is consistent with the Court’s 27 Scheduling Order. 28 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 8 Case 2:22-cv-04195-MEMF-RAO Document 17 Filed 10/07/22 Page 9 of 16 Page ID #:954

1 resolution process under Local Rule 37.1 et seq. 2 6.3 The burden of persuasion in any such challenge proceeding shall be on 3 the Designating Party. Frivolous challenges, and those made for an improper 4 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 5 parties) may expose the Challenging Party to sanctions. Unless the Designating 6 Party has waived or withdrawn the confidentiality designation, all parties shall 7 continue to afford the material in question the level of protection to which it is 8 entitled under the Producing Party’s designation until the Court rules on the 9 challenge. 10 11 7. ACCESS TO AND USE OF PROTECTED MATERIAL 12 7.1 Basic Principles. A Receiving Party may use Protected Material that is 13 disclosed or produced by another Party or by a Non-Party in connection with this 14 Action only for prosecuting, defending or attempting to settle this Action. Such 15 Protected Material may be disclosed only to the categories of persons and under the 16 conditions described in this Order. When the Action has been terminated, a 17 Receiving Party must comply with the provisions of section 13 below (FINAL 18 DISPOSITION). 19 Protected Material must be stored and maintained by a Receiving Party at a 20 location and in a secure manner that ensures that access is limited to the persons 21 authorized under this Order. 22 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 23 otherwise ordered by the court or permitted in writing by the Designating Party, a 24 Receiving Party may disclose any information or item designated 25 “CONFIDENTIAL” only to: 26 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 27 well as employees of said Outside Counsel of Record to whom it is reasonably 28 necessary to disclose the information for this Action; 9 Case 2:22-cv-04195-MEMF-RAO Document 17 Filed 10/07/22 Page 10 of 16 Page ID #:955

1 (b) the officers, directors, and employees (including House Counsel) of 2 the Receiving Party to whom disclosure is reasonably necessary for this Action; 3 (c) Experts (as defined in this Order) of the Receiving Party to whom 4 disclosure is reasonably necessary for this Action and who have signed the 5 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 6 (d) the court and its personnel; 7 (e) court reporters and their staff; 8 (f) professional jury or trial consultants, mock jurors, and Professional 9 Vendors to whom disclosure is reasonably necessary for this Action and who have 10 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 11 (g) the author or recipient of a document containing the information or a 12 custodian or other person who otherwise possessed or knew the information; 13 (h) during their depositions, witnesses, and attorneys for witnesses, in the 14 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 15 requests that the witness sign the form attached as Exhibit A hereto; and (2) they 16 will not be permitted to keep any confidential information unless they sign the 17 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 18 agreed by the Designating Party or ordered by the court. Pages of transcribed 19 deposition testimony or exhibits to depositions that reveal Protected Material may 20 be separately bound by the court reporter and may not be disclosed to anyone except 21 as permitted under this Stipulated Protective Order; and 22 (i) any mediator or settlement officer, and their supporting personnel, 23 mutually agreed upon by any of the parties engaged in settlement discussions. 24 25 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 26 IN OTHER LITIGATION 27 If a Party is served with a subpoena or a court order issued in other litigation 28 that compels disclosure of any information or items designated in this Action as 10 Case 2:22-cv-04195-MEMF-RAO Document 17 Filed 10/07/22 Page 11 of 16 Page ID #:956

1 “CONFIDENTIAL,” that Party must: 2 (a) promptly notify in writing the Designating Party. Such notification 3 shall include a copy of the subpoena or court order; 4 (b) promptly notify in writing the party who caused the subpoena or order 5 to issue in the other litigation that some or all of the material covered by the 6 subpoena or order is subject to this Protective Order. Such notification shall include 7 a copy of this Stipulated Protective Order; and 8 (c) cooperate with respect to all reasonable procedures sought to be 9 pursued by the Designating Party whose Protected Material may be affected. 10 If the Designating Party timely seeks a protective order, the Party served with 11 the subpoena or court order shall not produce any information designated in this 12 action as “CONFIDENTIAL” before a determination by the court from which the 13 subpoena or order issued, unless the Party has obtained the Designating Party’s 14 permission. The Designating Party shall bear the burden and expense of seeking 15 protection in that court of its confidential material and nothing in these provisions 16 should be construed as authorizing or encouraging a Receiving Party in this Action 17 to disobey a lawful directive from another court. 18 19 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 20 PRODUCED IN THIS LITIGATION 21 (a) The terms of this Order are applicable to information produced by a 22 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 23 produced by Non-Parties in connection with this litigation is protected by the 24 remedies and relief provided by this Order. Nothing in these provisions should be 25 construed as prohibiting a Non-Party from seeking additional protections. 26 (b) In the event that a Party is required, by a valid discovery request, to 27 produce a Non-Party’s confidential information in its possession, and the Party is 28 subject to an agreement with the Non-Party not to produce the Non-Party’s 11 Case 2:22-cv-04195-MEMF-RAO Document 17 Filed 10/07/22 Page 12 of 16 Page ID #:957

1 confidential information, then the Party shall: 2 (1) promptly notify in writing the Requesting Party and the Non-Party 3 that some or all of the information requested is subject to a confidentiality 4 agreement with a Non-Party; 5 6 (2) promptly provide the Non-Party with a copy of the Stipulated 7 Protective Order in this Action, the relevant discovery request(s), and a reasonably 8 specific description of the information requested; and 9 (3) make the information requested available for inspection by the 10 Non-Party, if requested. 11 (c) If the Non-Party fails to seek a protective order from this court within 12 14 days of receiving the notice and accompanying information, the Receiving Party 13 may produce the Non-Party’s confidential information responsive to the discovery 14 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 15 not produce any information in its possession or control that is subject to the 16 confidentiality agreement with the Non-Party before a determination by the court. 17 Absent a court order to the contrary, the Non-Party shall bear the burden and 18 expense of seeking protection in this court of its Protected Material. 19 20 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 21 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 22 Protected Material to any person or in any circumstance not authorized under this 23 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 24 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 25 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 26 persons to whom unauthorized disclosures were made of all the terms of this Order, 27 and (d) request such person or persons to execute the “Acknowledgment and 28 Agreement to Be Bound” that is attached hereto as Exhibit A. 12 Case 2:22-cv-04195-MEMF-RAO Document 17 Filed 10/07/22 Page 13 of 16 Page ID #:958

1 2 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 3 PROTECTED MATERIAL 4 When a Producing Party gives notice to Receiving Parties that certain 5 inadvertently produced material is subject to a claim of privilege or other protection, 6 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 7 Procedure 26(b)(5)(B). This provision is not intended to modify whatever 8 procedure may be established in an e-discovery order that provides for production 9 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and 10 (e), insofar as the parties reach an agreement on the effect of disclosure of a 11 communication or information covered by the attorney-client privilege or work 12 product protection, the parties may incorporate their agreement in the stipulated 13 protective order submitted to the court. 14 15 12. MISCELLANEOUS 16 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 17 person to seek its modification by the Court in the future. 18 12.2 Right to Assert Other Objections. By stipulating to the entry of this 19 Protective Order, no Party waives any right it otherwise would have to object to 20 disclosing or producing any information or item on any ground not addressed in this 21 Stipulated Protective Order. Similarly, no Party waives any right to object on any 22 ground to use in evidence of any of the material covered by this Protective Order. 23 12.3 Filing Protected Material. A Party that seeks to file under seal any 24 Protected Material must comply with Local Civil Rule 79-5. Protected Material 25 may only be filed under seal pursuant to a court order authorizing the sealing of the 26 specific Protected Material at issue. If a Party’s request to file Protected Material 27 under seal is denied by the court, then the Receiving Party may file the information 28 in the public record unless otherwise instructed by the court. 13 Case 2:22-cv-04195-MEMF-RAO Document 17 Filed 10/07/22 Page 14 of 16 Page ID #:959

1 13. FINAL DISPOSITION 2 A. After the final disposition of this Action, as defined in paragraph 4, 3 within 60 days of a written request by the Designating Party, each Receiving Party 4 must return all Protected Material to the Producing Party or destroy such material. 5 As used in this subdivision, “all Protected Material” includes all copies, abstracts, 6 compilations, summaries, and any other format reproducing or capturing any of the 7 Protected Material. Whether the Protected Material is returned or destroyed, the 8 Receiving Party must submit a written certification to the Producing Party (and, if 9 not the same person or entity, to the Designating Party) by the 60 day deadline that 10 (1) identifies (by category, where appropriate) all the Protected Material that was 11 returned or destroyed and (2) affirms that the Receiving Party has not retained any 12 copies, abstracts, compilations, summaries or any other format reproducing or 13 capturing any of the Protected Material. Notwithstanding this provision, Counsel are 14 entitled to retain an archival copy of all pleadings, motion papers, trial, deposition, 15 and hearing transcripts, legal memoranda, correspondence, deposition and trial 16 exhibits, expert reports, attorney work product, and consultant and expert work 17 product, even if such materials contain Protected Material. Any such archival 18 copies that contain or constitute Protected Material remain subject to this Protective 19 Order as set forth in Section 4. 20 B. Nothing in this Order disallows State Farm's from: 21 a. complying with any state or federal law or regulation, including 22 reporting of information to a regulator or government entity as 23 permitted and/or required by applicable state and federal law; 24 b. adding information discovered that is relevant to a claim to the 25 relevant electronic record in its electronic claim system; 26 c. disclosing evidence of a crime or fraud; retaining information 27 necessary to meet mandated retention requirements; or, 28 d. retaining copies of Protected Material that may exists on back-up 14 Case 2:22-cv-04195-MEMF-RAO Document17 Filed 10/07/22 Page15of16 Page ID #:960

1 media or other computer or archive storage not regularly 2 accessed by business users in the ordinary course provided that 3 should a copy of the Confidential Information be accessed it will 4 not be used for a purpose inconsistent with this Order. 6 || 14. VIOLATION 7 || Any violation of this Order may be punished by appropriate measures including, 8 || without limitation, contempt proceedings and/or monetary sanctions. 9 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD. 10 11 |} DATED: October 5, 2022 12 13 /s/ Eileen Keusseyan (as authorized on 9/22/2022) 4 Attorneys for Plaintiff

15 16 || DATED: October 5, 2022 17 18 /s/ Matt Batezel 19 Attorneys for Defendant

20 21 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 22 23 || DATED: October 7, 2022 Repdes O, 25 26 || United States Magisirate Judge 27 28 15

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1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 I, _____________________________ [print or type full name], of 5 _________________ [print or type full address], declare under penalty of perjury 6 that I have read in its entirety and understand the Stipulated Protective Order that 7 was issued by the United States District Court for the Central District of California 8 on [date] in the case of Betty Jean Courtney v. State Farm General Insurance 9 Company, Case No. 2:22-cv-04195-MEMF-RAO. I agree to comply with and to be 10 bound by all the terms of this Stipulated Protective Order and I understand and 11 acknowledge that failure to so comply could expose me to sanctions and punishment 12 in the nature of contempt. I solemnly promise that I will not disclose in any manner 13 any information or item that is subject to this Stipulated Protective Order to any 14 person or entity 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 for the 16 Central District of California for enforcing the terms of this Stipulated Protective 17 Order, even if such enforcement proceedings occur after termination of this action. 18 I hereby appoint __________________________ [print or type full name] of 19 _______________________________________ [print or type full address and 20 telephone number] as my California agent for service of process in connection with 21 this action or any proceedings related to enforcement of this Stipulated Protective 22 Order. 23 Date: ______________________________________ 24 City and State where sworn and signed: _________________________________ 25 26 Printed name: _______________________________ 27 28 Signature: __________________________________ 16