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1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 SOUTHERN DIVISION 11 C.J. SEGERSTROM & SONS, Case No.: 8:22-cv-00466-MEMF-JDE 12 Plaintiff, Assigned to Judge Frimpong 13 v. STIPULATION AND PROTECTIVE

ORDER

14 LEXINGTON INSURANCE

COMPANY; STARR SURPLUS

15 DISCOVERY MATTER

LINES INSURANCE COMPANY,

16 Defendants. Complaint filed: March 29, 2022 17 18 Pursuant to the parties’ Stipulation (Dkt. 46) and for good cause shown, the 19 Court finds and orders as follows. 20 1. PURPOSES AND LIMITATIONS 21 Discovery in this action is likely to involve production of confidential, 22 proprietary or private information for which special protection from public 23 disclosure and from use for any purpose other than pursuing this litigation may be 24 warranted. Accordingly, the parties hereby stipulate to and petition the Court to 25 enter the following Stipulated Protective Order. The parties acknowledge that this 26 Order does not confer blanket protections on all disclosures or responses to 27 discovery and that the protection it affords from public disclosure and use extends 28

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1 only to the limited information or items that are entitled to confidential treatment 2 under the applicable legal principles. 3 2. GOOD CAUSE STATEMENT 4 This action is likely to involve trade secrets, customer and pricing lists and 5 other valuable research, development, commercial, financial, technical and/or 6 proprietary information for which special protection from public disclosure and 7 from use for any purpose other than prosecution of this action is warranted. Such 8 confidential and proprietary materials and information consist of, among other 9 things, confidential business or financial information, information regarding 10 confidential business practices, or other confidential research, development, or 11 commercial information (including information implicating privacy rights of third 12 parties), information otherwise generally unavailable to the public, or which may be 13 privileged or otherwise protected from disclosure under state or federal statutes, 14 court rules, case decisions, or common law. Accordingly, to expedite the flow of 15 information, to facilitate the prompt resolution of disputes over confidentiality of 16 discovery materials, to adequately protect information the parties are entitled to keep 17 confidential, to ensure that the parties are permitted reasonable necessary uses of 18 such material in preparation for and in the conduct of trial, to address their handling 19 at the end of the litigation, and serve the ends of justice, a protective order for such 20 information is justified in this matter. It is the intent of the parties that information 21 will not be designated as confidential for tactical reasons and that nothing be so 22 designated without a good faith belief that it has been maintained in a confidential, 23 non-public manner, and there is good cause why it should not be part of the public 24 record of this case. 25 3. ACKNOWLEDGMENT OF UNDER SEAL FILING PROCEDURE 26 The parties further acknowledge, as set forth in Section 14.3, below, that this 27 Stipulated Protective Order does not entitle them to file confidential information 28 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed 2

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1 and the standards that will be applied when a party seeks permission from the court 2 to file material under seal. There is a strong presumption that the public has a right 3 of access to judicial proceedings and records in civil cases. In connection with non- 4 dispositive motions, good cause must be shown to support a filing under seal. See 5 Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), 6 Phillips v. Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar- 7 Welbon v. Sony Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even 8 stipulated protective orders require good cause showing), and a specific showing of 9 good cause or compelling reasons with proper evidentiary support and legal 10 justification, must be made with respect to Protected Material that a party seeks to 11 file under seal. The parties’ mere designation of Disclosure or Discovery Material as 12 CONFIDENTIAL does not— without the submission of competent evidence by 13 declaration, establishing that the material sought to be filed under seal qualifies as 14 confidential, privileged, or otherwise protectable—constitute good cause. 15 Further, if a party requests sealing related to a dispositive motion or trial, then 16 compelling reasons, not only good cause, for the sealing must be shown, and the 17 relief sought will be narrowly tailored to serve the specific interest to be protected. 18 See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 2010). For 19 each item or type of information, document, or thing sought to be filed or introduced 20 under seal, the party seeking protection must articulate compelling reasons, 21 supported by specific facts and legal justification, for the requested sealing order. 22 Again, competent evidence supporting the application to file documents under seal 23 must be provided by declaration. 24 Any document that is not confidential, privileged, or otherwise protectable in 25 its entirety will not be filed under seal if the confidential portions can be redacted. If 26 documents can be redacted, then a redacted version for public viewing, omitting 27 only the confidential, privileged, or otherwise protectable portions of the document, 28 3

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1 will be filed. Any application that seeks to file documents under seal in their entirety 2 should include an explanation of why redaction is not feasible. 3 4. DEFINITIONS 4 4.1. Action: this pending federal lawsuit. 5 4.2. Challenging Party: a Party or Non-Party that challenges the designation 6 of information or items under this Order. 7 4.3. “CONFIDENTIAL” Information or Items: information (regardless of 8 how it is generated, stored or maintained) or tangible things that qualify for 9 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 10 the Good Cause Statement. 11 4.4. Counsel: Outside Counsel of Record and House Counsel (as well as 12 their support staff). 13 4.5. Designating Party: a Party or Non-Party that designates information or 14 items that it produces in disclosures or in responses to discovery as 15 “CONFIDENTIAL.” 16 4.6. Disclosure or Discovery Material: all items or information, regardless 17 of the medium or manner in which it is generated, stored, or maintained (including, 18 among other things, testimony, transcripts, and tangible things), that are produced or 19 generated in disclosures or responses to discovery. 20 4.7. Expert: a person with specialized knowledge or experience in a matter 21 pertinent to the litigation who has been retained by a Party or its counsel to serve as 22 an expert witness or as a consultant in this Action. 23 4.8. House Counsel: attorneys who are employees of a party to this Action. 24 House Counsel does not include Outside Counsel of Record or any other outside 25 counsel. 26 4.9. Non-Party: any natural person, partnership, corporation, association or 27 other legal entity not named as a Party to this action. 28 4

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1 4.10. Outside Counsel of Record: attorneys who are not employees of a party 2 to this Action but are retained to represent a party to this Action and have appeared 3 in this Action on behalf of that party or are affiliated with a law firm that has 4 appeared on behalf of that party, and includes support staff. 5 4.11. Party: any party to this Action, including all of its officers, directors, 6 employees, consultants, retained experts, and Outside Counsel of Record (and their 7 support staffs). 8 4.12. Producing Party: a Party or Non-Party that produces Disclosure or 9 Discovery Material in this Action. 10 4.13. Professional Vendors: persons or entities that provide litigation support 11 services (e.g., photocopying, videotaping, translating, preparing exhibits or 12 demonstrations, and organizing, storing, or retrieving data in any form or medium) 13 and their employees and subcontractors. 14 4.14. Protected Material: any “CONFIDENTIAL” Information or Items that 15 have been designated as “CONFIDENTIAL” 16 4.15. Receiving Party: a Party that receives Disclosure or Discovery Material 17 from a Producing Party. 18 5. SCOPE 19 The protections conferred by this Stipulation and Order cover not only 20 Protected Material (as defined above), but also (1) any information copied or 21 extracted from Protected Material; (2) all copies, excerpts, summaries, or 22 compilations of Protected Material; and (3) any testimony, conversations, or 23 presentations by Parties or their Counsel that might reveal Protected Material. 24 Any use of Protected Material during a court hearing or at trial will be 25 governed by the orders of the presiding judge. This Order does not govern the use of 26 Protected Material at trial. 27 28 5

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1 6. DURATION 2 Once a case proceeds to trial, information that was designated as 3 CONFIDENTIAL or maintained pursuant to this protective order used or introduced 4 as an exhibit at trial becomes public and will be presumptively available to all 5 members of the public, including the press, unless compelling reasons supported by 6 specific factual findings to proceed otherwise are made to the trial judge in advance 7 of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” 8 showing for sealing documents produced in discovery from “compelling reasons” 9 standard when merits-related documents are part of court record). Accordingly, the 10 terms of this protective order do not extend beyond the commencement of the trial. 11 7. DESIGNATING PROTECTED MATERIAL 12 7.1. Exercise of Restraint and Care in Designating Material for Protection. 13 Each Party or Non-Party that designates Disclosure or Discovery Material for 14 protection under this Order must take care to limit any such designation to specific 15 material that qualifies under the appropriate standards. The Designating Party must 16 designate for protection only those parts of Disclosure or Discovery Material that 17 qualify so that other portions of the Disclosure or Discovery Material for which 18 protection is not warranted are not swept unjustifiably within the ambit of this 19 Order. 20 7.2. Mass, indiscriminate, or routinized designations are prohibited. 21 Designations that are shown to be clearly unjustified or that have been made for an 22 improper purpose (e.g., to unnecessarily encumber the case development process or 23 to impose unnecessary expenses and burdens on other parties) may expose the 24 Designating Party to sanctions. 25 If it comes to a Designating Party’s attention that information or items that it 26 designated for protection do not qualify for protection, that Designating Party must 27 promptly notify all other Parties that it is withdrawing the inapplicable designation. 28 6

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1 7.3. Manner and Timing of Designations. Except as otherwise provided in 2 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 3 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 4 under this Order must be clearly so designated before the Disclosure or Discovery 5 Material is disclosed or produced. 6 Designation in conformity with this Order requires: 7 (a) for information in documentary form (e.g., paper or electronic 8 documents, but excluding transcripts of depositions or other pretrial or trial 9 proceedings), that the Producing Party affix at a minimum, the legend 10 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page 11 that contains protected material. If only a portion of the material on a page 12 qualifies for protection, the Producing Party also must clearly identify the 13 protected portion(s) (e.g., by making appropriate markings in the margins). 14 A Party or Non-Party that makes original documents available for 15 inspection need not designate them for protection until after the inspecting 16 Party has indicated which documents it would like copied and produced. 17 During the inspection and before the designation, all of the material made 18 available for inspection will be deemed confidential. After the inspecting 19 Party has identified the documents it wants copied and produced, the 20 Producing Party must determine which documents, or portions thereof, 21 qualify for protection under this Order. Then, before producing the specified 22 documents, the Producing Party must affix a CONFIDENTIAL legend to 23 each page that contains Protected Material. If only a portion of the material on 24 a page qualifies for protection, the Producing Party also must clearly identify 25 the protected portion(s) (e.g., by making appropriate markings in the 26 margins). 27 (b) for testimony given in depositions that the Designating Party 28 identify the Disclosure or Discovery Material on the record, before the close 7

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1 of the deposition all protected testimony, or within 30 days of receiving the 2 certified transcript. 3 (c) for information produced in some form other than documentary 4 and for any other tangible items, that the Producing Party affix the 5 CONFIDENTIAL legend in a prominent place on the exterior of the container 6 or containers in which the information is stored. If only a portion or portions 7 of the information warrants protection, the Producing Party, to the extent 8 practicable, will identify the protected portion(s). 9 7.4. Inadvertent Failures to Designate. If timely corrected, an inadvertent 10 failure to designate qualified Disclosure or Discovery Material does not, standing 11 alone, waive the Designating Party’s right to secure protection under this Order for 12 such material. Upon timely correction of a designation, the Receiving Party must 13 make reasonable efforts to assure that the Disclosure or Discovery Material is 14 treated in accordance with the provisions of this Order. 15 I. CHALLENGING CONFIDENTIALITY DESIGNATIONS 16 7.5. Timing of Challenges. Any Party or Non-Party may challenge a 17 designation of confidentiality at any time that is consistent with the Court’s 18 Scheduling Order. 19 7.6. Meet and Confer. The Challenging Party will initiate the dispute 20 resolution process under Local Rule 37-1 et seq. 21 7.7. Joint Stipulation. Any challenge submitted to the Court will be via a 22 joint stipulation pursuant to Local Rule 37-2. 23 7.8. The burden of persuasion in any such challenge proceeding will be on 24 the Designating Party. Frivolous challenges, and those made for an improper 25 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 26 parties) may expose the Challenging Party to sanctions. Unless the Designating 27 Party has waived or withdrawn the confidentiality designation, all parties will 28 continue to afford the Disclosure or Discovery Material in question the level of 8

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1 protection to which it is entitled under the Producing Party’s designation until the 2 Court rules on the challenge. 3 8. ACCESS TO AND USE OF PROTECTED MATERIAL 4 8.1. Basic Principles. A Receiving Party may use Protected Material that is 5 disclosed or produced by another Party or by a Non-Party in connection with this 6 Action only for prosecuting, defending or attempting to settle this Action. Such 7 Protected 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 14 below (FINAL 10 DISPOSITION). 11 Protected Material must be stored and maintained by a Receiving Party at a 12 location and in a secure manner that ensures that access is limited to the persons 13 authorized under this Order. 14 8.2. Disclosure of Protected Materials. Unless otherwise ordered by the 15 court or permitted in writing by the Designating Party, a Receiving Party may 16 disclose any Protected Material only to: 17 (a) the Receiving Party’s Outside Counsel of Record in this Action, 18 as well as employees of said Outside Counsel of Record to whom it is 19 reasonably necessary to disclose the information for this Action; 20 (b) the officers, directors, and employees (including House Counsel) 21 of the 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 24 whom disclosure is reasonably necessary for this Action; 25 (d) the court and its personnel; 26 (e) court reporters and their staff; 27 28 9

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1 (f) professional jury or trial consultants, mock jurors, and 2 Professional Vendors to whom disclosure is reasonably necessary for this 3 Action; 4 (g) the author or recipient of a document containing the information 5 or a custodian or other person who otherwise possessed or knew the 6 information; 7 (h) during their depositions, non-party witnesses, and attorneys for 8 non-party witnesses, to whom disclosure is reasonably necessary; 9 (i) any mediator or settlement officer, and their supporting 10 personnel, mutually agreed upon by any of the parties engaged in settlement 11 discussions; and 12 (j) any other person that the Designating Party agrees to in writing. 13 8.3. Before disclosure of Protected Material to any person in categories f, h, 14 and/or j above, each such person will be provided with a copy of this Protective 15 Order and shall execute a Non-Disclosure Agreement (Exhibit A). The qualified 16 persons listed above shall not distribute, disclose, or otherwise publish or make 17 available Protected Material to any third person unless consented to in writing by 18 the Designating Party, or permitted to do so by the Court. 19 9. PROTECTED MATERIAL SUBPOENAED OR ORDERED 20 PRODUCED IN OTHER LITIGATION 21 If a Party is served with a subpoena or a court order issued in other litigation 22 that compels disclosure of any Protected Material that Party must: 23 (a) promptly notify in writing the Designating Party. Such 24 notification will include a copy of the subpoena or court order; 25 (b) promptly notify in writing the party who caused the subpoena or 26 order to issue in the other litigation that some or all of the material covered by 27 the subpoena or order is subject to this Protective Order. Such notification 28 will include a copy of this Stipulated Protective Order; and 10

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1 (c) cooperate with respect to all reasonable procedures sought to be 2 pursued by the Designating Party whose Protected Material may be affected. 3 If the Designating Party timely seeks a protective order, the Party served with 4 the subpoena or court order will not produce any Protected Material before a 5 determination by the court from which the subpoena or order issued, unless 6 the Party has obtained the Designating Party’s permission. The Designating 7 Party will bear the burden and expense of seeking protection in that court of 8 its confidential material and nothing in these provisions should be construed 9 as authorizing or encouraging a Receiving Party in this Action to disobey a 10 lawful directive from another court. 11 10. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 12 PRODUCED IN THIS LITIGATION 13 10.1. The terms of this Order are applicable to information produced by a 14 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 15 produced by Non-Parties in connection with this litigation is protected by the 16 remedies and relief provided by this Order. Nothing in these provisions should be 17 construed as prohibiting a Non-Party from seeking additional protections. 18 10.2. In the event that a Party is required, by a valid discovery request, to 19 produce a Non-Party’s confidential information in its possession, and the Party is 20 subject to an agreement with the Non-Party not to produce the Non-Party’s 21 confidential information, then the Party will: 22 (a) promptly notify in writing the Requesting Party and the Non- 23 Party that some or all of the information requested is subject to a 24 confidentiality agreement with a Non-Party; 25 (b) promptly provide the Non-Party with a copy of the Stipulated 26 Protective Order in this Action, the relevant discovery request(s), and a 27 reasonably specific description of the information requested; and 28 11

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1 (c) make the information requested available for inspection by the 2 Non-Party, if requested. 3 10.3. If the Non-Party fails to seek a protective order from this court within 4 14 days of receiving the notice and accompanying information, the Receiving Party 5 may produce the Non-Party’s confidential information responsive to the discovery 6 request. If the Non-Party timely seeks a protective order, the Receiving Party will 7 not produce any information in its possession or control that is subject to the 8 confidentiality agreement with the Non-Party before a determination by the court. 9 Absent a court order to the contrary, the Non-Party will bear the burden and expense 10 of seeking protection in this court of its Protected Material. 11 11. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 12 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 13 Protected Material to any person or in any circumstance not authorized under this 14 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 15 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 16 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 17 persons to whom unauthorized disclosures were made of all the terms of this Order, 18 and (d) request such person or persons to execute the “Acknowledgment and 19 Agreement to Be Bound” attached hereto as Exhibit A. 20 12. INADVERTENT PRODUCTION OF PRIVILEGED OR 21 OTHERWISE PROTECTED MATERIAL 22 12.1. If a Producing Party inadvertently produces information or documents 23 that it considered privileged, in whole or in part, it may retrieve such information or 24 documents or parts thereof as follows: 25 (a) Within twenty (20) days of the discovery of the inadvertent 26 production, and no later than forty-five (45) days prior to trial, the Producing 27 Party must give written notice to all parties who received copies of the 28 produced document that the Producing Party claims said document, in whole 12

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1 or in part, to be privileged and must state the nature of the privilege; in the 2 event that only part(s) of document(s) are claimed to be privileged, the 3 Producing Party shall furnish redacted copies of such privileged documents, 4 removing only the part(s) thereof claimed to be privileged, to all parties 5 together with the notice (the “Inadvertent Production of Privileged Materials 6 Notice”). 7 (b) Upon receipt of such Inadvertent Production of Privileged 8 Materials Notice, all parties who have received copies of the inadvertently 9 produced document(s) shall promptly return them to the Producing Party and 10 destroy any other copies thereof except to the extent reasonably necessary to 11 promptly present the information to the court under seal for a determination 12 of the claim pursuant to Federal Rule of Civil Procedure 26(b)(5)(B). 13 (c) After service of such notice, no motion to compel the production 14 of the inadvertently produced privileged documents may rely on an allegation 15 that any privilege as to the document was waived solely by virtue of its 16 inadvertent production. 17 13. MISCELLANEOUS 18 13.1. Right to Further Relief. Nothing in this Order abridges the right of any 19 person to seek its modification by the Court in the future. 20 13.2. Right to Assert Other Objections. By stipulating to the entry of this 21 Protective Order, no Party waives any right it otherwise would have to object to 22 disclosing or producing any information or item on any ground not addressed in this 23 Stipulated Protective Order. Similarly, no Party waives any right to object on any 24 ground to use in evidence of any of the material covered by this Protective Order. 25 13.3. Filing Protected Material. A Party that seeks to file under seal any 26 Protected Material must comply with Local Civil Rule 79-5. Protected Material may 27 only be filed under seal pursuant to a court order authorizing the sealing of the 28 specific Protected Material. If a Party’s request to file Protected Material under seal 13

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1 is denied by the court, then the Receiving Party may file the information in the 2 public record unless otherwise instructed by the court. 3 14. FINAL DISPOSITION 4 After the final disposition of this Action, as defined in paragraph 6, within 60 5 days of a written request by the Designating Party, each Receiving Party must return 6 all Protected Material to the Producing Party, destroy such material, or continue to 7 maintain the documents pursuant to this Protective Order. As used in this 8 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 9 summaries, and any other format reproducing or capturing any of the Protected 10 Material. Whether the Protected Material is returned, destroyed, or maintained, the 11 Receiving Party must submit a written certification to the Producing Party (and, if 12 not the same person or entity, to the Designating Party) by the 60-day deadline that 13 (1) identifies (by category, where appropriate) all the Protected Material that was 14 returned, destroyed, or maintained and (2) affirms that the Receiving Party has not 15 retained any copies, abstracts, compilations, summaries or any other format 16 reproducing or capturing any of the Protected Material or, alternatively, affirms that 17 the Protected Material will be maintained in accordance with this Protective Order. 18 Notwithstanding this provision, Counsel are entitled to retain an archival copy of all 19 pleadings, motion papers, trial, deposition, and hearing transcripts, legal 20 memoranda, correspondence, deposition and trial exhibits, expert reports, attorney 21 work product, and consultant and expert work product, even if such materials 22 contain Protected Material. Any such archival copies that contain or constitute 23 Protected Material remain subject to this Protective Order as set forth in Section 6 24 (DURATION). 25 / / / 26 / / / 27 / / / 28 / / / 14

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1 15. VIOLATION 2 Any willful violation of this Order may be punished by appropriate measures 3 || including, without limitation, contempt proceedings and/or monetary sanctions. 4 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 5 || Dated: January 9, 2023 A i KE. 6 OF Sees 7 JOHN D. EARLY United States Magistrate Judge 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 15

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1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, _____________________________ [print or type full name], of 4 _________________ [print or type full address], declare under penalty of perjury 5 that I have read in its entirety and understand the Stipulated Protective Order that 6 was issued by the United States District Court for the Central District of California 7 in the case of C.J. Segerstrom & Sons v. Lexington Insurance Co., Case No. 8:22- 8 cv-00466-MEMF-JDE. I agree to comply with and to be bound by all the terms of 9 this Stipulated Protective Order. I understand and acknowledge that failure to so 10 comply could expose me to sanctions and punishment in the nature of contempt. I 11 solemnly promise that I will not disclose in any manner any information or item that 12 is subject to this Stipulated Protective Order to any person or entity except in strict 13 compliance with the provisions of this Order. I further agree to submit to the 14 jurisdiction of the United States District Court for the Central District of California 15 for the purpose of enforcing the terms of this Stipulated Protective Order, even if 16 such enforcement proceedings occur after termination of this Action. I hereby 17 appoint __________________________ [print or type full name] of 18 _______________________________________ [print or type full address and 19 telephone number] as my California agent for service of process in connection with 20 this Action or any proceedings related to enforcement of this Stipulated Protective 21 Order. 22 Date: 23 City and State where sworn and signed: 24 25 Printed name: 26 Signature: 27 28 16

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