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QUINN EMANUEL URQUHART & G. David Rubin (SBN 181293) 1 SULLIVAN, LLP Andrew K. Aaronian (SBN 318245) Christopher Tayback (Bar No. 145532) LITCHFIELD CAVO LLP 2 christayback@quinnemanuel.com 2 North Lake Avenue, Suite 400 Ryan Landes (Bar No. 252642) Pasadena, CA 91101 3 ryanlandes@quinnemanuel.com Tel: (626) 683-1100 Matthew Arrow (Bar No. 338273) Fax: (626) 683-1113 4 matthewarrow@quinnemanuel.com Email: rubin@litchfieldcavo.com 865 South Figueroa Street, 10th Floor aaronian@litchfieldcavo.com 5 Los Angeles, California 90017-2543 Telephone: (213) 443 3000 Attorneys for Defendant, 6 Facsimile: (213) 443 3100 INSURANCE CLAIMS

ASSOCIATES AGENCY INC.

7 Stephen R. Neuwirth (admitted pro hac vice) 8 stephenneuwirth@quinnemanuel.com David B. Adler (admitted pro hac vice) 9 davidadler@quinnemanuel.com 51 Madison Avenue, 22nd Floor 10 New York, New York 10010 Telephone: (212) 849-7000 11 Facsimile: (212) 849-7100 12 Attorneys for Go Maps, Inc. 13

UNITED STATES DISTRICT COURT

14

CENTRAL DISTRICT OF CALIFORNIA

15 16 GO MAPS, INC., Case No. 2:22-CV-01973-FLA-AGR 17 Plaintiff, STIPULATION AND PROTECTIVE 18 ORDER vs. 19 NOTE CHANGES MADE BY

INSURANCE CLAIMS ASSOCIATES COURT

20 AGENCY INC., 21 Defendant. The Hon. Fernando L. Aenlle-Rocha 22 Trial Date: August 23, 2023 23 24 25 26 27 28

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1. PURPOSES AND LIMITATION 1 2 Discovery in this action may involve production of confidential, proprietary, 3 or private information for which special protection from public disclosure and from 4 use for any purpose other than prosecuting this litigation may be warranted. 5 Accordingly, the parties hereby stipulate to and petition the Court to enter the 6 following Stipulated Protective Order. The parties acknowledge that this Order does 7 not confer blanket protections on all disclosures or responses to discovery and that 8 the protection it affords from public disclosure and use extends only to the limited 9 information or items that are entitled to confidential treatment under the applicable 10 legal principles. 1.1 GOOD CAUSE STATEMENT 11 12 This action may involve confidential, financial, and/or proprietary 13 information belonging to the parties or third parties, including personal identifying 14 information or other insurance claim information for insureds, for which special 15 protection from public disclosure and from use for any purpose other than 16 prosecution of this action is warranted. Such confidential and proprietary materials 17 and information consist of, among other things, confidential business or financial 18 information, information relating to the parties’ international distribution practices, 19 information regarding customers and prices, information regarding confidential 20 business practices, or other confidential, commercial information (including 21 information implicating privacy rights of third parties), information otherwise 22 generally unavailable to the public, or which may be privileged or otherwise 23 protected from disclosure under state or federal statutes, court rules, case decisions, 24 or common law. Accordingly, to expedite the flow of information, to facilitate the 25 prompt resolution of disputes over confidentiality of discovery materials, to 26 adequately protect information the parties are entitled to keep confidential, to ensure 27 that the parties are permitted reasonable necessary uses of such material in 28 -1-

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1 preparation for and in the conduct of trial, to address their handling at the end of the 2 litigation, and serve the ends of justice, a protective order for such information is 3 justified in this matter. It is the intent of the parties that information will not be 4 designated as confidential for tactical reasons and that nothing be so designated 5 without a good faith belief that it has been maintained in a confidential, non–public 6 manner, and there is good cause why it should not be part of the public record of this 7 case. 1.2 FILING UNDER SEAL PROCEDURE ACKNOWLEDGMENT 8 9 The parties further acknowledge, as set forth in Section 12.3, below, that this 10 Stipulated Protective Order does not entitle them to file confidential information 11 under seal; Local Civil Rule 79–5 sets forth the procedures that must be followed 12 and the standards that will be applied when a party seeks permission from the Court 13 to file material under seal. 14 There is a strong presumption that the public has a right of access to judicial 15 proceedings and records in civil cases. In connection with non–dispositive motions, 16 good cause must be shown to support a filing under seal, See Kamakana v. City and 17 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006); Phillips v. Gen. Motors 18 Corp., 307 F.3d 1206, 1210–11 (9th Cir. 2002), and a specific showing of good 19 cause or compelling reasons with proper evidentiary support and legal justification, 20 must be made with respect to Protected Material that a party seeks to file under seal. 21 The parties’ mere designation of Disclosure or Discovery Material as 22 CONFIDENTIAL or CONFIDENTIAL-ATTORNEYS’ EYES ONLY does 23 not—without the submission of competent evidence by declaration, establishing that 24 the 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 -2-

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1 relief sought shall be narrowly tailored to serve the specific interest to be protected. 2 See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677–79 (9th Cir. 2010). For 3 each item or type of information, document, or thing sought to be filed or introduced 4 under seal in connection with a dispositive motion or trial, the party seeking 5 protection must articulate compelling reasons, supported by specific facts and legal 6 justification, for the requested sealing order. Again, competent evidence supporting 7 the application to file documents under seal must be provided by declaration. 8 Any document that is not confidential, privileged, or otherwise protectable in 9 its entirety will not be filed under seal if the confidential portions can be redacted. If 10 documents can be redacted, then a redacted version for public viewing, omitting 11 only the confidential, privileged, or otherwise protectable portions of the document, 12 shall be filed. Any application that seeks to file documents under seal in their 13 entirety should include an explanation of why redaction is not feasible. 2. DEFINITIONS 14 15 2.1 Action: the above–captioned case. 16 2.2 Challenging Party: a Party or Non–Party that challenges the designation 17 of information or items under this Order. 18 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 19 how it is generated, stored or maintained) or tangible things that qualify for 20 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 21 the Good Cause Statement. 22 2.4 “CONFIDENTIAL-ATTORNEYS’ EYES ONLY (AEO)” Information 23 or Items: extremely sensitive proprietary “Confidential Information or Items,” that 24 qualify for protection under Federal Rule of Civil Procedure 26(c), and as specified 25 above in the Good Cause Statement, the direct disclosure of which to the Receiving 26 Party would create a substantial risk of harm to the Designating Party’s competitive 27 standing, provided that such harm could not be avoided by less restrictive means. 28 -3-

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1 2.5 Counsel (without qualifier): Outside Counsel of Record and House 2 Counsel (as well as their support staff, including regular or temporary employees 3 and service vendors of such Counsel). 4 2.6 Designating Party: a Party or Non–Party that designates information or 5 items produced in disclosures or in responses to discovery as “CONFIDENTIAL” or 6 “CONFIDENTIAL-AEO.” 7 2.7 Disclosure or Discovery Material: all items or information, regardless 8 of the medium or manner in which it is generated, stored, or maintained (including, 9 among other things, testimony, transcripts, and tangible things), that are produced or 10 generated in disclosures or responses to discovery in this matter. 11 2.8 Expert: a person with specialized knowledge or experience in a matter 12 pertinent to the litigation who has been retained by a Party or its counsel to serve as 13 an expert witness or as a consultant in this Action (as well as the Expert’s support 14 staff). 15 2.9 In-House Counsel: attorneys who are employees of a party to this 16 Action. In-House Counsel does not include Outside Counsel of Record or any other 17 outside counsel. 18 2.10 Non–Party: any natural person, partnership, corporation, association or 19 other legal entity not named as a Party to this action. 20 2.11 Outside Counsel of Record: attorneys who are not employees of a 21 party to this action but are retained to represent or advise a party to this Action and 22 have appeared in this action on behalf of that party or are affiliated with a law firm 23 which has appeared on behalf of that party, and includes support staff, including 24 regular or temporary employees and service vendors. 25 2.12 Party: any named party to this action, including all of its officers, 26 directors, employees, consultants or advisors assisting the party in this action, 27 retained experts, and Outside Counsel of Record (and their support staffs). 28 -4-

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1 2.13 Producing Party: a Party or Non–Party that produces Disclosure or 2 Discovery Material in this action. 3 2.14 Professional Vendors: persons or entities engaged by a Party (through 4 Outside Counsel of Record or otherwise) that provide litigation support services in 5 this Action (e.g., photocopying, videotaping, translating, preparing exhibits or 6 demonstrations, and organizing, storing, or retrieving data in any form or medium) 7 and their employees and subcontractors. 8 2.15 Protected Material: any Disclosure or Discovery Material that is 9 designated as “CONFIDENTIAL” or “CONFIDENTIAL-AEO.” 10 2.16 Receiving Party: a Party that receives Disclosure or Discovery Material 11 from a Producing Party. 3. SCOPE 12 13 The protections conferred by this Stipulation and Order cover not only 14 Disclosure and Discovery Material and Protected Material (as defined above), but 15 also (1) any information copied or extracted from Protected Material; (2) all copies, 16 excerpts, summaries, or compilations of Protected Material; and (3) any testimony, 17 conversations, or presentations by Parties or their Counsel that might reveal 18 Protected Material. 19 This Stipulation and Order also applies to all non-Parties that are served with 20 subpoenas or who otherwise produce documents or are noticed for depositions in the 21 Action, and all such non-Parties are entitled to the protections afforded hereby and 22 subject to the obligations herein, only upon signing a Declaration in the form 23 provided as Exhibit A. Any Party or its counsel serving a subpoena, after the date 24 this Protective Order is entered, which requires the production of documents or 25 testimony upon a non-Party shall serve a copy of this Order along with such 26 subpoena. 27 28 -5-

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1 However, the protections conferred by this Stipulation and Order do not cover 2 the following information: (a) any information that is in the public domain at the 3 time of disclosure to a Receiving Party or becomes part of the public domain after 4 its disclosure to a Receiving Party as a result of publication not involving a violation 5 of this Order, including becoming part of the public record through trial or 6 otherwise; and (b) any information known to the Receiving Party prior to the 7 disclosure or obtained by the Receiving Party after the disclosure from a source who 8 obtained the information lawfully and under no obligation of confidentiality to the 9 Designating Party. 10 Any use of Protected Material at trial shall be governed by the orders of the 11 trial judge. This Order does not govern the use of Protected Material at trial. 4. DURATION 12 13 Final Disposition of the action is defined as the later of (1) dismissal of all 14 claims and defenses in this action, with or without prejudice; and (2) final judgment 15 herein after the completion and exhaustion of all appeals, rehearings, remands, trials, 16 or reviews of this action, including the time limits for filing any motions or 17 applications for extension of time pursuant to applicable law. The terms of this 18 protective order shall survive Final Disposition of the action for any retained 19 Protected Material. The parties may stipulate that they will be contractually bound 20 by the terms of this agreement beyond Final Disposition, but will have to file a 21 separate action for enforcement of the agreement once all proceedings in this case 22 are complete, provided that they actually enter into such a stipulation. 23 Once a case proceeds to trial, information that was designated as 24 CONFIDENTIAL, CONFIDENTIAL-AEO or maintained pursuant to this 25 protective order that is used or introduced as an exhibit at trial becomes public and 26 will be presumptively available to all members of the public, including the press, 27 unless compelling reasons supported by specific factual findings to proceed 28 -6-

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1 otherwise are made to the trial judge in advance of the trial. See Kamakana, 2 447 F.3d at 1180–81 (distinguishing “good cause” showing for sealing documents 3 produced in discovery from “compelling reasons” standard when merits–related 4 documents are part of court record). 5. DESIGNATING PROTECTED MATERIAL 5 6 5.1 Exercise of Restraint and Care in Designating Material for Protection. 7 Each Party or Non–Party that designates information or items for protection under 8 this Order must take care to limit any such designation to specific material that 9 qualifies under the appropriate standards. The Designating Party must designate for 10 protection only the material, documents, items or oral or written communications 11 that qualify so that other material, documents, items or communications for which 12 protection is not warranted are not swept unjustifiably within the ambit of this 13 Order. Mass, indiscriminate or routinized designations are prohibited. Designations 14 that are shown to be clearly unjustified or that have been made for an improper 15 purpose (e.g., to unnecessarily encumber the case development process or to impose 16 unnecessary expenses and burdens on other parties) may expose the Designating 17 Party to sanctions. 18 If it comes to a Designating Party’s attention that information or items that it 19 designated for protection do not qualify for protection, that Designating Party 20 should promptly notify all other Parties that it is withdrawing the inapplicable 21 designation. 22 5.2 Manner and Timing of Designations. Except as otherwise provided in 23 this Order, or as otherwise stipulated or ordered, Disclosure or Discovery Material 24 that qualifies for protection under this Order must be clearly so designated at the 25 time the material is disclosed or produced. 26 Designation in conformity with this Order requires: 27 28 -7-

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1 (a) for information in documentary form (e.g., paper or electronic documents, 2 but excluding transcripts of depositions or other pretrial or trial proceedings), that 3 the Producing Party affix at a minimum, the legend “CONFIDENTIAL” or 4 “CONFIDENTIAL-AEO,” as the case may be, to each page that contains protected 5 material. 6 (b) for testimony given in deposition or in other pretrial or trial proceedings, 7 that the Designating Party identify it as “CONFIDENTIAL” or “CONFIDENTIAL- 8 AEO” on the record during the course of the deposition and then within thirty (30) 9 days of the receipt of the final transcript of the deposition, hearing, or other 10 proceeding, shall designate the specific portion(s) of the transcript which is 11 “CONFIDENTIAL” or “CONFIDENTIAL-AEO”. Until expiration of the 30-day 12 period, the entire deposition or hearing transcript shall be treated as 13 “CONFIDENTIAL-AEO,” provided that a preliminary designation to that effect 14 was made on the record during the course of the deposition. 15 (c) for information produced in some form other than documentary and for 16 any other tangible items, that the Producing Party affix in a prominent place on the 17 exterior of the container or containers in which the information is stored, or in an E- 18 Mail transmitting the materials, the legend “CONFIDENTIAL” or 19 “CONFIDENTIAL-AEO,” as the case may be. If only portions of the Information 20 or item warrant protection, the Designating Party, to the extent practicable, shall 21 identify the “CONFIDENTIAL” or “CONFIDENTIAL-AEO,” portions. 22 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 23 failure to designate qualified information or items does not, standing alone, waive 24 the Designating Party’s right to secure protection under this Order for such material. 25 26 In the event that any Disclosure or Discovery Material is inadvertently 27 produced without a “CONFIDENTIAL” or “CONFIDENTIAL-AEO” designation, 28 -8-

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1 the Party that inadvertently produced the document shall give written notice of such 2 inadvertent production within a reasonable time after discovery of the inadvertent 3 production, together with a further copy of the subject Disclosure or Discovery 4 Material designated as “CONFIDENTIAL” or “CONFIDENTIAL-AEO,” as the 5 case may be (the “Inadvertent Production Notice”). Upon receipt of such Inadvertent 6 Production Notice, the Party that received the inadvertently produced Disclosure or 7 Discovery Material shall promptly destroy the inadvertently produced Disclosure or 8 Discovery Material and all copies thereof, or, at the expense of the Producing Party, 9 return such together with all copies of such Disclosure or Discovery Material to 10 counsel for the Producing Party and shall retain only the “CONFIDENTIAL” or 11 “CONFIDENTIAL-AEO” materials. Should the Receiving Party choose to destroy 12 such inadvertently produced Disclosure or Discovery Material, the Receiving Party 13 shall notify the Producing Party in writing of such destruction within five (5) days 14 of receipt of written notice of the inadvertent production. This provision is not 15 intended to apply to any inadvertent production of any Disclosure or Discovery 16 Material protected by attorney-client or work product privileges, which is addressed 17 specifically in Section 11 below. In the event that this provision conflicts with any 18 applicable law regarding waiver of confidentiality through the inadvertent 19 production of Documents, Testimony or Information, such law shall govern. 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 20 21 6.1 Timing of Challenges. Any Party or Non–Party may challenge a 22 designation of confidentiality at any time that is consistent with the Court’s 23 Scheduling Order. 24 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 25 resolution process under Local Rule 37–1 et seq. 26 6.3 Joint Stipulation. Any challenge submitted to the Court shall be via a 27 joint stipulation pursuant to Local Rule 37–2 or as otherwise ordered by the Court. 28 -9-

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1 6.4 The burden of persuasion in any such challenge proceeding shall be on 2 the Designating Party. Frivolous challenges, and those made for an improper 3 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 4 parties) may expose the Challenging Party to sanctions. Unless the Designating 5 Party has waived or withdrawn the confidentiality designation, all parties shall 6 continue to afford the material in question the level of protection to which it is 7 entitled under the Producing Party’s designation until the Court rules on the 8 challenge. 7. ACCESS TO AND USE OF PROTECTED MATERIAL 9 10 7.1 Basic Principles. A Receiving Party may use Disclosure and Discovery 11 Material, including Protected Material, that is disclosed or produced by another 12 Party or by a Non–Party in connection with this Action only, for prosecuting, 13 defending or attempting to settle this Action. Such Protected Material may be 14 disclosed only to the categories of persons and under the conditions described in this 15 Order. When the Action has been terminated, a Receiving Party must comply with 16 the provisions of section 13 below (FINAL DISPOSITION). Protected Material 17 must be stored and maintained by a Receiving Party in a secure manner that ensures 18 that access is limited to the persons authorized under this Order. 19 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 20 otherwise ordered by the Court or permitted in writing by the Designating Party, a 21 Receiving Party may disclose any information or item designated 22 “CONFIDENTIAL” only to: 23 (a) the Receiving Party’s Outside Counsel of Record in this action, as well as 24 employees of said Outside Counsel of Record to whom it is reasonably necessary to 25 disclose the information for this Action; 26 27 28 -10-

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1 (b) the officers, directors, employees, and consultants or advisors assisting in 2 this Action (including In House Counsel) of the Receiving Party to whom disclosure 3 is reasonably necessary for this Action; 4 (c) Experts (as defined in this Order) of the Receiving Party, as well as 5 employees of said Experts, to whom disclosure is reasonably necessary for this 6 Action and who have signed the “Acknowledgment and Agreement to Be Bound” 7 (Exhibit A); 8 (d) the Court and its personnel; 9 (e) court reporters, stenographers, or videographers who record testimony in 10 connection with this Action; 11 (f) professional jury or trial consultants, mock jurors, and Professional 12 Vendors to whom disclosure is reasonably necessary for this Action and who have 13 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 14 (g) the author or recipient of a document containing the information or a 15 custodian or other person who otherwise possessed or knew the information; 16 (h) witnesses, noticed or subpoenaed, either at a deposition, through other 17 Discovery Requests, or in court proceedings, and the witness’s counsel, to the extent 18 that such disclosure is reasonably necessary for the proceedings or the resolution of 19 the Disputes, provided: (1) the deposing party requests that the witness sign the 20 form attached as Exhibit A hereto; and (2) the witness and his or her attorneys will 21 not be permitted to keep any confidential information unless they sign the 22 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 23 agreed by the Designating Party or ordered by the Court. Pages of transcribed 24 deposition testimony or exhibits to depositions that reveal Protected Material may 25 be separately bound by the court reporter and may not be disclosed to anyone except 26 as permitted under this Stipulated Protective Order; and 27 28 -11-

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1 (i) any mediator or settlement officer, and their supporting personnel, 2 mutually agreed upon by any of the parties engaged in settlement discussions, or 3 appointed by the Court. 4 (j) those insurers, including but not limited to insurance adjusters and their 5 clerical and secretarial staff, of all non-designating Parties that counsel for such 6 Parties deems necessary to aid counsel in the prosecution and defense of this 7 Proceeding, who have signed the “Acknowledgment and Agreement to Be Bound” 8 (Exhibit A). 9 7.3 Disclosure of “CONFIDENTIAL-AEO” Information or Items. Unless 10 otherwise ordered by the Court or permitted in writing by the Designating Party, a 11 Receiving Party may disclose any information or item designated 12 “CONFIDENTIAL-AEO” only to: 13 (a) the Receiving Party’s Outside Counsel of Record in this action, as well as 14 employees of said Outside Counsel of Record to whom it is reasonably necessary to 15 disclose the information for this litigation; 16 (b) Experts (as defined in this Order) of the Receiving Party, as well as 17 employees of said Experts, to whom disclosure is reasonably necessary for this 18 litigation and who have signed the “Acknowledgment and Agreement to Be Bound” 19 (Exhibit A); 20 (c) the Court and its personnel; 21 (d) court reporters and their staff, professional jury or trial consultants, mock 22 jurors, and Professional Vendors to whom disclosure is reasonably necessary for 23 this litigation and who have signed the “Acknowledgment and Agreement to Be 24 Bound” (Exhibit A); 25 (e) the author or recipient of a document containing the information or a 26 custodian or other person who otherwise possessed or knew the information; 27 28 -12-

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1 (f) one In-House Counsel for each Party, provided that disclosure to such 2 individual is reasonably necessary for this litigation, and provided that the 3 individual has signed the “Acknowledgment and Agreement to Be Bound” (Exhibit 4 A); 5 (g) witnesses being questioned, either at a deposition or in court proceedings, 6 and the witnesses’ counsel, where the witness is indicated on the face of the 7 document to have been an author, addressee, or copy recipient thereof, an actual or 8 intended recipient thereof, or in the case of meeting minutes, an attendee of the 9 meeting, in each case only to the extent such disclosure is reasonably necessary for 10 the proceedings or the resolution of the Action, provided that the witness has signed 11 or agreed on the record to sign a Declaration in the form of Exhibit A provided 12 hereto. Those witnesses and their counsel who are shown “CONFIDENTIAL- 13 AEO” material shall not be allowed to retain copies. 14 (h) Prior to disclosing the information or items designated 15 “CONFIDENTIAL-AEO” to a deposition witness who is not otherwise permitted to 16 see such material under sections 7.3(a)-(f), the Party taking the deposition must 17 notify the Party defending the deposition of the deposing-Party’s intent to use the 18 CONFIDENTIAL-AEO material with that witness at least five (5) business days 19 before commencement of the deposition. Furthermore, the CONFIDENTIAL-AEO 20 material to be used at deposition shall be identified with specificity and may be 21 reviewed by the deponent prior to the deposition, notwithstanding the 22 CONFIDENTIAL-AEO designation. 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 23 24 PRODUCED IN OTHER LITIGATION 25 If a Party is served with a subpoena or a court order issued in another 26 litigation or proceeding that compels disclosure of any information or items 27 28 -13-

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1 designated in this Action as “CONFIDENTIAL” or “CONFIDENTIAL-AEO” that 2 Party must: 3 (a) promptly notify in writing the Designating Party, and, if different, the 4 Producing Party. Such notification shall include a copy of the subpoena or court 5 order; 6 (b) promptly notify in writing the party who caused the subpoena or order to 7 issue in the other litigation that some or all of the material covered by the subpoena 8 or order is subject to this Protective Order. Such notification shall include a copy of 9 this Protective Order; and 10 (c) cooperate with respect to all reasonable procedures sought to be pursued 11 by the Designating Party whose Protected Material may be affected. If the 12 Designating Party timely seeks a protective order, the Party served with the 13 subpoena or court order shall not produce any information designated in this action 14 as “CONFIDENTIAL” or “CONFIDENTIAL-AEO” before a determination by the 15 court or other authorized body from which the subpoena or order issued, unless the 16 Party has obtained the Designating Party’s permission, or unless the applicable rules 17 or statutes do not permit withholding the production of documents pending court 18 order. The Designating Party shall bear the burden and expense of seeking 19 protection in that court or forum of its confidential material, including seeking relief 20 on an ex parte basis if necessary, and nothing in these provisions should be 21 construed as authorizing or encouraging a Receiving Party in this Action to disobey 22 a lawful directive from another court. 9. NON-PARTY’S PROTECTED MATERIAL 23 24 (a) The terms of this Order are applicable to information produced by a 25 Non–Party in this Action and designated as “CONFIDENTIAL” or 26 “CONFIDENTIAL-AEO.” Such information produced by Non–Parties in 27 connection with this litigation is protected by the remedies and relief provided by 28 -14-

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1 this Order. Nothing in these provisions should be construed as prohibiting a 2 Non–Party from seeking additional protections. 3 (b) In the event that a Party is required, by a valid discovery request, to 4 produce a Non–Party’s confidential information in its possession, and the Party is 5 subject to an agreement with the Non–Party not to produce the Non–Party’s 6 confidential information, then the Party shall: 7 1) promptly notify in writing the Requesting Party and the Non– Party 8 that some or all of the information requested is subject to a confidentiality 9 agreement with a Non–Party; 10 2) promptly notify in writing the Requesting Party and the Non– Party 11 that some or all of the information requested is subject to a confidentiality 12 agreement with a Non–Party; 13 3) make the information requested available for inspection by the 14 Non–Party, if requested. 15 (c) If the Non–Party fails to seek a protective order from this Court within 16 fourteen (14) days of receiving the notice and accompanying information, the 17 Receiving Party may produce the Non–Party’s confidential information responsive 18 to the discovery request. If the Non–Party timely seeks a protective order, the 19 Receiving Party shall not produce any information in its possession or control that is 20 subject to the confidentiality agreement with the Non–Party before a determination 21 by the Court. 22 Absent a court order to the contrary, the Non–Party shall bear the burden and 23 expense of seeking protection in this Court of its Protected Material. 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 24 25 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 26 Protected Material to any person or in any circumstance not authorized under this 27 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 28 -15-

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1 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 2 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 3 persons to whom unauthorized disclosures were made of all the terms of this Order, 4 and (d) request such person or persons to execute the “Acknowledgment and 5 Agreement to Be Bound” that is attached hereto as Exhibit A. 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 6 7 PROTECTED MATERIAL 8 If Disclosure or Discovery Material or other information subject to a claim of 9 attorney-client privilege, work-product immunity, or any other applicable claim of 10 privilege or immunity is inadvertently produced or otherwise disclosed to any Party 11 or Non-Party, such production or disclosure shall in no way prejudice or otherwise 12 constitute a waiver of, or estoppel as to, any claim of privilege or immunity for such 13 Disclosure or Discovery Material or other information. Disclosure or Discovery 14 Material or other information subject to a claim of privilege or immunity must be 15 returned as soon as it is discovered, without any need to show the production was 16 inadvertent. The Receiving Party shall not use the inadvertently produced 17 Disclosure or Discovery Material or other information for any purpose. 18 Upon request by the Producing Party pursuant to this Section, the Receiving 19 Party shall immediately return all copies of such document(s) or thing(s) and shall 20 destroy any derivative document such as a summary or comment on the 21 inadvertently produced information. The Receiving Party may then move the Court 22 for an order compelling production of such information, but the motion shall not 23 assert as a ground for production the fact or circumstances of the inadvertent 24 production. If a claim is disputed, the Receiving Party shall not use or disclose any 25 Disclosure or Discovery Material or other information for which a claim of privilege 26 or immunity is made pursuant to this Section for any purpose or until the matter is 27 resolved by agreement of the parties or by a decision of the Court. 28 -16-

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1 This order shall be interpreted to provide the maximum protection allowed by 2 Federal Rule of Evidence 502(d). Nothing contained herein is intended to or shall 3 serve to limit a party’s right to conduct a review of documents, ESI, or information 4 (including metadata) for relevance, responsiveness, and/or segregation of privileged 5 and/or protected information before production. 12. MISCELLANEOUS 6 7 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 8 Party or Non-Party producing documents subject to its terms to seek its modification 9 by the Court in the future. 10 12.2 Right to Assert Other Objections. By stipulating to the entry of this 11 Protective Order, no Party waives any right it otherwise would have to object to 12 disclosing or producing any information or item on any ground not addressed in this 13 Stipulated Protective Order. Similarly, no Party waives any right to object on any 14 ground to use in evidence of any of the material covered by this Protective Order. 15 12.3 Filing Protected Material. A Party that seeks to file under seal any 16 Protected Material must comply with Local Civil Rule 79–5. Protected Material may 17 only be filed under seal pursuant to a court order authorizing the sealing of the 18 specific Protected Material at issue. If a Party’s request to file Protected Material 19 under seal is denied by the Court, then the Receiving Party may file the information 20 in the public record unless otherwise instructed by the Court. 21 12.4 No Admissions. Entering into, agreeing to, and/or complying with the 22 terms of this Stipulation and Protective Order shall not: 23 a. operate as an admission by any person that any particular Document, 24 Testimony or Information marked “CONFIDENTIAL” or “CONFIDENTIAL- 25 AEO” contains or reflects trade secrets, proprietary, confidential or competitively 26 sensitive business, commercial, financial or personal information or is otherwise 27 subject to protection; or 28 -17-

STIPULATION AND PROTECTIVE ORDER

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1 b. prejudice in any way the right of any Party (or any other person subject 2 to the terms of this Stipulation and Protective Order): 3 i. to seek a determination by the Court of whether any particular 4 claimed Confidential Material should be subject to protection as 5 “CONFIDENTIAL” or “CONFIDENTIAL-AEO” under the terms of this 6 Stipulation and Protective Order and applicable law; or 7 ii. to seek relief from the Court on appropriate notice to all other 8 Parties to the Proceeding from any provision(s) of this Stipulation and 9 Protective Order, either generally or as to any particular Document, Material 10 or Information. 11 12.5 Waiver. This Stipulation and Protective Order is entered into without 12 prejudice to the right of any Party to knowingly waive the applicability of this 13 Stipulation and Protective Order to any Confidential Materials designated by that 14 Party. If the Designating Party uses Confidential Materials in a non-Confidential 15 manner, then the Designating Party shall advise that the designation no longer 16 applies. 17 12.6. Admissibility. Nothing in this Stipulation and Protective Order shall 18 affect the admissibility into evidence of Confidential Materials, or abridge the rights 19 of any person to seek judicial review or to pursue other appropriate judicial action 20 with respect to any ruling made by the Court concerning the issue of the status of 21 any Confidential Materials. 13. FINAL DISPOSITION 22 23 After the Final Disposition of this Action, as defined in paragraph 4, within 24 sixty (60) days of a written request by the Designating Party, each Receiving Party 25 must return all Protected Material to the Producing Party or destroy such material. 26 As used in this subdivision, “all Protected Material” includes all copies, abstracts, 27 compilations, summaries, and any other format reproducing or capturing any of the 28 -18-

STIPULATION AND PROTECTIVE ORDER

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1 Protected Material. Whether the Protected Material is returned or destroyed, the 2 Receiving Party must submit a written certification to the Producing Party (and, if 3 not the same person or entity, to the Designating Party) by the 60 day deadline that 4 (1) identifies (by category, where appropriate) all the Protected Material that was 5 returned or destroyed and (2) affirms that the Receiving Party has not retained any 6 copies, abstracts, compilations, summaries or any other format reproducing or 7 capturing any of the Protected Material. Notwithstanding this provision, Counsel are 8 entitled to retain an archival copy of all pleadings, motion papers, trial, deposition, 9 and hearing transcripts, legal memoranda, correspondence, deposition and trial 10 exhibits, expert reports, attorney work product, and consultant and expert work 11 product, even if such materials contain Protected Material. Any such archival copies 12 that contain or constitute Protected Material remain subject to this Protective Order 13 as set forth in Section 4. 14 /// 15 /// 16 /// 17 /// 18 /// 19 /// 20 /// 14. VIOLATION 21 22 Any violation of this Order may be addressed by appropriate measures, as 23 further determined by the Court and as supported by fact and/or law. 24 25 IT IS SO STIPULATED. 26 DATED: December 29, 2022 QUINN EMANUEL URQUHART & 27 28 -19-

STIPULATION AND PROTECTIVE ORDER

11064-00003/13807980.1 Case 2:22-cv-01973-FLA-AGR Document 31 Filed 01/25/23 Page 21 o0f22 Page ID #:293 2 /s/ Matthew Arrow By 3 Matthew Arrow 4 Attorneys for Go Maps, Inc. 6 DATED: December 29, 2022 LITCHFIELD CAVO LLP 8 /s/ G. David Rubin By 9 G. David Rubin (SBN 181293) 10 Andrew K. Aaronian (SBN 318245) 1l Attorneys for Defendant,

INSURANCE CLAIMS ASSOCIATES

12 AGENCY INC. 13 14 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 15 16 DATED: January 25, 2023 17 Ubi. A Keanna, 18 Hon. Alicia G. Rosenberg United States Magistrate Judge 19 20 21 22 23 24 25 26 27 28 -20-

STIPULATION AND PROTECTIVE ORDER

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1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, ______________________________________________[print or type full 4 name], of ____________________________________________[print or type full 5 address], declare under penalty of perjury that I have read in its entirety and 6 understand the Stipulated Protective Order that was issued by the United States 7 District Court for the Central District of California on _____, 20__ in the case of Go 8 Maps, Inc. v. Insurance Claims Associates Agency Inc., Case No. 2:22-CV-01973- 9 FLA-AGR. I agree to comply with and to be bound by all the terms of this 10 Stipulated Protective Order, and I understand and acknowledge that failure to so 11 comply could expose me to sanctions and punishment in the nature of contempt. I 12 solemnly promise that I will not disclose in any manner any information or item that 13 is subject to this Stipulated Protective Order to any person or entity except in strict 14 compliance with the provisions of this Order. I further agree to submit to the 15 jurisdiction of the United States District Court for the Central District of California 16 for enforcing the terms of this Stipulated Protective Order, even if such enforcement 17 proceedings occur after termination of this action. 18 Date: ______________________________________ 19 City and State where sworn and signed: __________________________ 20 Printed name: _______________________________ 21 Signature: __________________________________ 22 23 24 25 26 27 28 -21-

STIPULATION AND PROTECTIVE ORDER

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