Case 8:22-cv-01300-JWH-KES Document 41 Filed 03/07/23 Page 1 of 14 Page ID #:691

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7 8 UNITED STATES DISTRICT COURT

9 CENTRAL DISTRICT OF CALIFORNIA – SOUTHERN DIVISION

10 SCOTTSDALE INSURANCE ) Case No.: 8:22-cv-01300-JWH-KES_ 11 COMPANY, an Ohio corporation, ) ) 12 Plaintiff, ) [PROPOSED] PROTECTIVE ORDER ) 13 v. ) [Filed Concurrently with Stipulation for a ) Protective Order] 14 BEACHCOMBER MANAGMENT ) CRYSTAL COVE, LLC, a California ) 15 limited liability company, et. al., ) ) 16 Defendants. ) ) 17 ) RICHARD A. MARSHACK, Chapter ) 18 7 Trustee, ) ) 19 Cross-Plaintiff, ) ) 20 v. ) ) 21 SCOTTSDALE INSURANCE ) COMPANY, an Ohio corporation, ) 22 ) Cross-Defendant. ) 23 ) 24 1. PURPOSES AND LIMITATIONS 25 Discovery in this action is likely to involve production of confidential, 26 proprietary or private information for which special protection from public disclosure 27 and from use for any purpose other than prosecuting this litigation may be warranted. 28 Accordingly, the parties hereby stipulate to and petition the Court to enter the - 1 -

PROTECTIVE ORDER

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1 following Stipulated Protective Order. The parties acknowledge that this Order does 2 not confer blanket protections on all disclosures or responses to discovery and that the 3 protection it affords from public disclosure and use extends only to the limited 4 information or items that are entitled to confidential treatment under the applicable 5 legal principles. 6 2. GOOD CAUSE STATEMENT 7 This action is likely to involve documentation and information relating to 8 confidential and proprietary business practices or commercial information, including 9 but not limited to confidential and proprietary reserve information, underwriting 10 information and financial information, and settlement communications for which 11 special protection from public disclosure and from use for any purpose other than 12 prosecution of this action is warranted. Such confidential and proprietary materials 13 and information may be otherwise unavailable to the public, or may be privileged or 14 otherwise protected from disclosure under state or federal statutes, court rules, case 15 decisions or common law. Accordingly, to expedite the flow of information, to 16 facilitate the prompt resolution of disputes over confidentiality of discovery materials, 17 to adequately protect information the parties are entitled to keep confidential, to ensure 18 that the parties are permitted reasonable necessary uses of such material in preparation 19 for and in the conduct of trial, to address their handling at the end of the litigation, and 20 serve the ends of justice, a protective order for such information is justified in this 21 matter. It is the intent of the parties that information will not be designated as 22 confidential for tactical reasons and that nothing be so designated without a good faith 23 belief that it has been maintained in a confidential, non-public manner, and there is 24 good cause why it should not be part of the public 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 under 28 seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the - 2 -

PROTECTIVE ORDER

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

PROTECTIVE ORDER

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1 include an explanation of why redaction is not feasible. 2 4. DEFINITIONS 3 4.1 Action: the above-captioned action pending in the United States District 4 Court for the Central District of California and styled as Scottsdale Insurance 5 Company v. Beachcomber Management Crystal Cove, LLC, et al., Case No. 8:22-cv- 6 01300-JWH-KES. 7 4.2 Challenging Party: a Party or Non-Party that challenges the designation 8 of information or items under this Order. 9 4.3 “CONFIDENTIAL” Information or Items: information (regardless of 10 how it is generated, stored or maintained) or tangible things that qualify for protection 11 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 12 Statement. 13 4.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 14 support staff). 15 4.5 Designating Party: a Party or Non-Party that designates information or 16 items that it produces in disclosures or in responses to discovery as 17 “CONFIDENTIAL.” 18 4.6 Disclosure or Discovery Material: all items or information, regardless of 19 the medium or manner in which it is generated, stored, or maintained (including, 20 among other things, testimony, transcripts, and tangible things), that are produced or 21 generated in disclosures or responses to discovery. 22 4.7 Expert: a person with specialized knowledge or experience in a matter 23 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 24 expert witness or as a consultant in this Action. 25 4.8 House Counsel: attorneys who are employees of a party to this Action. 26 House Counsel does not include Outside Counsel of Record or any other outside 27 counsel. 28 4.9 Non-Party: any natural person, partnership, corporation, association or - 4 -

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

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

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1 material is disclosed or produced. 2 Designation in conformity with this Order requires: 3 (a) for information in documentary form (e.g., paper or electronic 4 documents, but excluding transcripts of depositions or other pretrial or trial 5 proceedings), that the Producing Party affix at a minimum, the legend 6 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 7 contains protected material. If only a portion of the material on a page qualifies for 8 protection, the Producing Party also must clearly identify the protected portion(s) (e.g., 9 by making appropriate markings in the margins). 10 A Party or Non-Party that makes original documents available for inspection 11 need not designate them for protection until after the inspecting Party has indicated 12 which documents it would like copied and produced. During the inspection and before 13 the designation, all of the material made available for inspection shall be deemed 14 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 15 copied and produced, the Producing Party must determine which documents, or 16 portions thereof, qualify for protection under this Order. Then, before producing the 17 specified documents, the Producing Party must affix the “CONFIDENTIAL legend” to 18 each page that contains Protected Material. If only a portion of the material on a page 19 qualifies for protection, the Producing Party also must clearly identify the protected 20 portion(s) (e.g., by making appropriate markings in the margins). 21 (b) for testimony given in depositions, either that the Designating Party 22 identifies the Disclosure or Discovery Material on the record, before the close of the 23 deposition all protected testimony, or within fifteen (15) days of receipt of the 24 deposition transcript, whichever is later. During the first fifteen (15) days after receipt 25 of the deposition transcript, the deposition transcript shall be deemed 26 “CONFIDENTIAL.” 27 (c) for information produced in some form other than documentary and 28 for any other tangible items, that the Producing Party affix in a prominent place on the - 7 -

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1 exterior of the container or containers in which the information is stored the legend 2 “CONFIDENTIAL.” If only a portion or portions of the information warrants 3 protection, the Producing Party, to the extent practicable, shall identify the protected 4 portion(s). 5 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 6 failure to designate qualified information or items does not, standing alone, waive the 7 Designating Party’s right to secure protection under this Order for such material. 8 Upon timely correction of a designation, the Receiving Party must make reasonable 9 efforts to assure that the material is treated in accordance with the provisions of this 10 Order. 11 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS 12 8.1 Timing of Challenges. Any Party or Non-Party may challenge a 13 designation of confidentiality at any time that is consistent with the Court’s Scheduling 14 Order. 15 8.2 Meet and Confer. The Challenging Party shall initiate the dispute 16 resolution process under Local Rule 37.1 et seq. 17 8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a 18 joint stipulation pursuant to Local Rule 37-2. 19 8.4 The burden of persuasion in any such challenge proceeding shall be on the 20 Designating Party. Frivolous challenges, and those made for an improper purpose 21 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 22 expose the Challenging Party to sanctions. Unless the Designating Party has waived or 23 withdrawn the confidentiality designation, all parties shall continue to afford the 24 material in question the level of protection to which it is entitled under the Producing 25 Party’s designation until the Court rules on the challenge. 26 9. ACCESS TO AND USE OF PROTECTED MATERIAL 27 9.1 Basic Principles. A Receiving Party may use Protected Material that is 28 disclosed or produced by another Party or by a Non-Party in connection with this - 8 -

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1 Action only for prosecuting, defending or attempting to settle this Action. Such 2 Protected Material may be disclosed only to the categories of persons and under the 3 conditions described in this Order. When the Action has been terminated, a Receiving 4 Party must comply with the provisions of section 15 below (FINAL DISPOSITION). 5 Protected Material must be stored and maintained by a Receiving Party at a 6 location and in a secure manner that ensures that access is limited to the persons 7 authorized under this Order. 8 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 9 otherwise ordered by the court or permitted in writing by the Designating Party, a 10 Receiving Party may disclose any information or item designated “CONFIDENTIAL” 11 only to: 12 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 13 well as employees of said Outside Counsel of Record to whom it is reasonably 14 necessary to disclose the information for this Action; 15 (b) the officers, directors, and employees (including House Counsel) of 16 the Receiving Party to whom disclosure is reasonably necessary for this Action; 17 (c) Experts (as defined in this Order) of the Receiving Party to whom 18 disclosure is reasonably necessary for this Action and who have signed the 19 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 20 (d) the court and its personnel; 21 (e) court reporters and their staff; 22 (f) professional jury or trial consultants, mock jurors, and Professional 23 Vendors to whom disclosure is reasonably necessary for this Action and who have 24 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 25 (g) 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 (h) during their depositions, witnesses, and attorneys for witnesses, in the 28 Action to whom disclosure is reasonably necessary provided: (1) the deposing party - 9 -

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1 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will 2 not be permitted to keep any confidential information unless they sign the 3 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed 4 by the Designating Party or ordered by the court. Pages of transcribed deposition 5 testimony or exhibits to depositions that reveal Protected Material may be separately 6 bound by the court reporter and may not be disclosed to anyone except as permitted 7 under this Stipulated Protective Order; 8 (i) any mediators or settlement officers and their supporting personnel, 9 mutually agreed upon by any of the parties engaged in settlement discussions; 10 (j) the Receiving Party’s auditors, insurers, reinsurers, insurance 11 representatives, and regulators of the Parties to whom disclosure is reasonably 12 necessary for this Action; and 13 (k) any other person as to whom the Producing Party agrees in writing. 14 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED 15 PRODUCED IN OTHER LITIGATION 16 If a Party is served with a subpoena or a court order issued in other litigation that 17 compels disclosure of any information or items designated in this Action as 18 “CONFIDENTIAL,” that Party must: 19 (a) promptly notify in writing the Designating Party. Such notification 20 shall include a copy of the subpoena or court order; 21 (b) promptly notify in writing the party who caused the subpoena or order 22 to issue in the other litigation that some or all of the material covered by the subpoena 23 or order is subject to this Protective Order. Such notification shall include a copy of 24 this Stipulated Protective Order; and 25 (c) cooperate with respect to all reasonable procedures sought to be 26 pursued by the Designating Party whose Protected Material may be affected. If the 27 Designating Party timely seeks a protective order, the Party served with the subpoena 28 or court order shall not produce any information designated in this action as - 10 -

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

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1 request. If the Non-Party timely seeks a protective order, the Receiving Party shall not 2 produce any information in its possession or control that is subject to the 3 confidentiality agreement with the Non-Party before a determination by the court. 4 Absent a court order to the contrary, the Non-Party shall bear the burden and expense 5 of seeking protection in this court of its Protected Material. 6 12. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 7 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 8 Protected Material to any person or in any circumstance not authorized under this 9 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 10 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 11 all unauthorized copies of the Protected Material, (c) inform the person or persons to 12 whom unauthorized disclosures were made of all the terms of this Order, and (d) 13 request such person or persons to execute the “Acknowledgment and Agreement to Be 14 Bound” that is attached hereto as Exhibit A. 15 13. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 16 PROTECTED MATERIAL 17 When a Producing Party gives notice to Receiving Parties that certain 18 inadvertently produced material is subject to a claim of privilege or other protection, 19 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 20 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 21 may be established in an e-discovery order that provides for production without prior 22 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 23 parties reach an agreement on the effect of disclosure of a communication or 24 information covered by the attorney-client privilege or work product protection, the 25 parties may incorporate their agreement in the stipulated protective order submitted to 26 the court. 27 28 14. MISCELLANEOUS - 12 -

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1 14.1 Right to Further Relief. Nothing in this Order abridges the right of any 2 || person to seek its modification by the Court in the future. 3 14.2 Right to Assert Other Objections. By stipulating to the entry of this 4 || Protective Order, no Party waives any right it otherwise would have to object to 5 || disclosing or producing any information or item on any ground not addressed in this 6 || Stipulated Protective Order. Similarly, no Party waives any right to object on any 7 || ground to use in evidence of any of the material covered by this Protective Order. 8 14.3 Filing Protected Material. A Party that seeks to file under seal any 9 || Protected Material must comply with Local Civil Rule 79-5. Protected Material may 10 || only be filed under seal pursuant to a court order authorizing the sealing of the specific 11 || Protected Material at issue. If a Party’s request to file Protected Material under seal is 12 || denied by the court, then the Receiving Party may file the information in the public 13 || record unless otherwise instructed by the court. 14 15. FINAL DISPOSITION 15 The obligations of the Parties under this Order shall survive the resolution of 16 || this action such that the Parties agree to maintain all Confidential Material as 17 || “CONFIDENTIAL” during the pendency of and after the conclusion of this action. 18 16. VIOLATION 19 Any violation of this Order may be punished by appropriate measures including, 20 || without limitation, contempt proceedings and/or monetary sanctions. 21 >) || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 23 94 || DATED: March 7, 2023 25 "Vern 6. Scot 2% JUDGE KAREN E. SCOTT 7 United States Magistrate Judge

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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 that I 5 have read in its entirety and understand the Stipulated Protective Order that was issued 6 by the United States District Court for the Central District of California on [date] in the 7 case of Scottsdale Insurance Company v. Beachcomber Management Crystal Cove, 8 LLC, et al., Case No. 8:22-cv-01300-JWH-KES. I agree to comply with and to be 9 bound by all the terms of this Stipulated Protective Order and I understand and 10 acknowledge that failure to so comply could expose me to sanctions and punishment in 11 the nature of contempt. I solemnly promise that I will not disclose in any manner any 12 information or item that is subject to this Stipulated Protective Order to any person or 13 entity except in strict compliance with the provisions of this Order. 14 I further agree to submit to the jurisdiction of the United States District Court for 15 the Central District of California for enforcing the terms of this Stipulated Protective 16 Order, even if such enforcement proceedings occur after termination of this action. I 17 hereby 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 Printed name: _______________________________ 25 26 Signature: __________________________________

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