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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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11 TRACEY BREGMAN; Case No. 2:20-CV-06207-SVW-GJS 12 (Case assigned to Hon. Stephen V. 13 Plaintiff, Wilson)

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15 CERTAIN UNDERWRITERS AT STIPULATED PROTECTIVE

LLOYD’S, LONDON SUBSCRIBING

ORDER1

16 TO POLICY NOS. HGB0135371; Does 1 through 50 inclusive, 17 Defendants. Magistrate: Gail J. Standish 18 Trial Date: February 23, 2021

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20 IT IS HEREBY STIPULATED by and between the parties to Tracey 21 Bregman v. Certain Underwriters at Lloyd’s, London Subscribing to Policy Nos. 22 HGB0135371, by and through their respective counsel of record (“Parties”), that in 23 order to facilitate the exchange of information and documents which may be subject 24 to confidentiality limitations on disclosure due to federal laws, state laws, and privacy 25 26

27 1 This Stipulated Protective Order is substantially based on the model protective order provided under Magistrate Judge Gail J. Standish’s Procedures. 1 r ights, the Parties stipulate and to the following Stipulated Protective Order 2 applicable to this litigation. 3 In the event that the Court modifies this Stipulated Protective Order, or in the 4 event that the Court enters a different Protective Order, the Parties agree to be bound 5 by this Stipulation and Protective Order until such time as the Court may enter such 6 a different Order. It is the Parties’ intent to be bound by the terms of this Stipulated 7 Protective Order pending its entry so as to allow for immediate production of 8 Confidential Materials under the terms herein. 9 10 1. A. PURPOSES AND LIMITATIONS 11 Discovery in this action is likely to involve production of confidential, 12 proprietary or private information for which special protection from public 13 disclosure and from use for any purpose other than prosecuting this litigation may 14 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 15 enter the following Stipulated Protective Order. The parties acknowledge that this 16 Order does not confer blanket protections on all disclosures or responses to 17 discovery and that the protection it affords from public disclosure and use extends 18 only to the limited information or items that are entitled to confidential treatment 19 under the applicable legal principles. 20 B. GOOD CAUSE STATEMENT 21 This action is likely to involve trade secrets, customer and pricing lists and 22 other valuable research, development, commercial, financial, technical and/or 23 proprietary information for which special protection from public disclosure and 24 from use for any purpose other than prosecution of this action is warranted. Such 25 confidential and proprietary materials and information consist of, among other 26 things, confidential business or financial information, information regarding 27 confidential business practices, or other confidential research, development, or 1 c ommercial information (including information implicating privacy rights of third 2 parties), information otherwise generally unavailable to the public, or which may be 3 privileged or otherwise protected from disclosure under state or federal statutes, 4 court rules, case decisions, or common law. Specifically, some of the documents to 5 be produced in connection with this action will contain or reflect 6 trade secrets, proprietary, confidential or competitively sensitive business, 7 commercial, financial or personal information that is of such a nature that public 8 disclosure would cause substantial and/or irreparable harm to the Designating 9 Party’s business operations and/or would create a substantial risk of serious 10 financial harm that cannot be avoided by less restrictive means. Accordingly, to 11 expedite the flow of information, to facilitate the prompt resolution of disputes over 12 confidentiality of discovery materials, to adequately protect information the parties 13 are entitled to keep confidential, to ensure that the parties are permitted reasonable 14 necessary uses of such material in preparation for and in the conduct of trial, to 15 address their handling at the end of the litigation, and serve the ends of justice, a 16 protective order for such information is justified in this matter. It is the intent of the 17 parties that information will not be designated as confidential for tactical reasons 18 and that nothing be so designated without a good faith belief that it has been 19 maintained in a confidential, non-public manner, and there is good cause why it 20 should not be part of the public record of this case. 21 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 22 The parties further acknowledge, as set forth in Section 12.3, below, that this 23 Stipulated Protective Order does not entitle them to file confidential information 24 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed 25 and the standards that will be applied when a party seeks permission from the court 26 to file material under seal. 27 1 There is a strong presumption that the public has a right of access to judicial 2 proceedings and records in civil cases. In connection with non-dispositive motions, 3 good cause must be shown to support a filing under seal. See Kamakana v. City and 4 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors 5 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, 6 Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders 7 require good cause showing), and a specific showing of good cause or compelling 8 reasons with proper evidentiary support and legal justification, must be made with 9 respect to Protected Material that a party seeks to file under seal. The parties’ mere 10 designation of Disclosure or Discovery Material as CONFIDENTIAL does not— 11 without the submission of competent evidence by declaration, establishing that the 12 material sought to be filed under seal qualifies as confidential, privileged, or 13 otherwise protectable—constitute good cause. 14 Further, if a party requests sealing related to a dispositive motion or trial, then 15 compelling reasons, not only good cause, for the sealing must be shown, and the 16 relief sought shall be narrowly tailored to serve the specific interest to be protected. 17 See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For 18 each item or type of information, document, or thing sought to be filed or introduced 19 under seal in connection with a dispositive motion or trial, the party seeking 20 protection must articulate compelling reasons, supported by specific facts and legal 21 justification, for the requested sealing order. Again, competent evidence supporting 22 the application to file documents under seal must be provided by declaration. 23 Any document that is not confidential, privileged, or otherwise protectable in 24 its entirety will not be filed under seal if the confidential portions can be redacted. 25 If documents can be redacted, then a redacted version for public viewing, omitting 26 only the confidential, privileged, or otherwise protectable portions of the document, 27 shall be filed. Any application that seeks to file documents under seal in their 1 e ntirety should include an explanation of why redaction is not feasible. 2 2. DEFINITIONS 3 2.1 Action: Tracey Bregman v. Certain Underwriters at Lloyd’s, London 4 Subscribing to Policy Nos. HGB0135371, United States District Court, Central 5 District of California Case No. 2:20-CV-06207-SVW-GJS. 6 2.2 Challenging Party: a Party or Non-Party that challenges the 7 designation of information or items under this Order. 8 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 9 how it is generated, stored or maintained) or tangible things that qualify for 10 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 11 the Good Cause Statement. 12 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 13 their support staff). 14 2.5 Designating Party: a Party or Non-Party that designates information or 15 items that it produces in disclosures or in responses to discovery as 16 “CONFIDENTIAL.” 17 2.6 Disclosure or Discovery Material: all items or information, regardless 18 of the medium or manner in which it is generated, stored, or maintained (including, 19 among other things, testimony, transcripts, and tangible things), that are produced or 20 generated in disclosures or responses to discovery in this matter. 21 2.7 Expert: a person with specialized knowledge or experience in a matter 22 pertinent to the litigation who has been retained by a Party or its counsel to serve as 23 an expert witness or as a consultant in this Action. 24 2.8 House Counsel: attorneys who are employees of a party to this Action. 25 House Counsel does not include Outside Counsel of Record or any other outside 26 counsel. 27 2.9 Non-Party: any natural person, partnership, corporation, association or 1 o ther legal entity not named as a Party to this action. 2 2.10 Outside Counsel of Record: attorneys who are not employees of a 3 party to this Action but are retained to represent or advise a party to this Action and 4 have appeared in this Action on behalf of that party or are affiliated with a law firm 5 that has appeared on behalf of that party, and includes support staff. 6 2.11 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 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 10 Discovery Material in this Action. 11 2.13 Professional Vendors: persons or entities that provide litigation 12 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 13 demonstrations, and organizing, storing, or retrieving data in any form or medium) 14 and their employees and subcontractors. 15 2.14 Protected Material: any Disclosure or Discovery Material that is 16 designated as “CONFIDENTIAL.” 17 2.15 Receiving Party: a Party that receives Disclosure or Discovery 18 Material from a Producing Party. 19 3. SCOPE 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 at trial shall be governed by the orders of the 25 trial judge. This Order does not govern the use of Protected Material at trial. 26 4. DURATION 27 FINAL DISPOSITION of the action is defined as the conclusion of any 1 a ppellate proceedings, or, if no appeal is taken, when the time for filing of an appeal 2 has run. Except as set forth below, the terms of this protective order apply through 3 FINAL DISPOSITION of the action. The parties may stipulate that the they will be 4 contractually bound by the terms of this agreement beyond FINAL DISPOSITION, 5 but will have to file a separate action for enforcement of the agreement once all 6 proceedings in this case are complete. 7 Once a case proceeds to trial, information that was designated as 8 CONFIDENTIAL or maintained pursuant to this protective order used or introduced 9 as an exhibit at trial becomes public and will be presumptively available to all 10 members of the public, including the press, unless compelling reasons supported by 11 specific factual findings to proceed otherwise are made to the trial judge in advance 12 of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” 13 showing for sealing documents produced in discovery from “compelling reasons” 14 standard when merits-related documents are part of court record). Accordingly, for 15 such materials, the terms of this protective order do not extend beyond the 16 commencement of the trial. 17 5. DESIGNATING PROTECTED MATERIAL 18 5.1 Exercise of Restraint and Care in Designating Material for Protection. 19 Each Party or Non-Party that designates information or items for protection under 20 this Order must take care to limit any such designation to specific material that 21 qualifies under the appropriate standards. The Designating Party must designate for 22 protection only those parts of material, documents, items or oral or written 23 communications that qualify so that other portions of the material, documents, items 24 or communications for which protection is not warranted are not swept unjustifiably 25 within the ambit of this Order. 26 Mass, indiscriminate or routinized designations are prohibited. Designations 27 that are shown to be clearly unjustified or that have been made for an improper 1 p urpose (e.g., to unnecessarily encumber the case development process or to impose 2 unnecessary expenses and burdens on other parties) may expose the Designating 3 Party to sanctions. 4 If it comes to a Designating Party’s attention that information or items that it 5 designated for protection do not qualify for protection, that Designating Party must 6 promptly notify all other Parties that it is withdrawing the inapplicable designation. 7 5.2 Manner and Timing of Designations. Except as otherwise provided in 8 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 9 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 10 under this Order must be clearly so designated before the material is disclosed or 11 produced. 12 Designation in conformity with this Order requires: 13 (a) for information in documentary form (e.g., paper or electronic 14 documents, but excluding transcripts of depositions or other pretrial or trial 15 proceedings), that the Producing Party affix at a minimum, the legend 16 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 17 contains protected material. If only a portion of the material on a page qualifies for 18 protection, the Producing Party also must clearly identify the protected portion(s) 19 (e.g., by making appropriate markings in the margins). 20 A Party or Non-Party that makes original documents available for inspection 21 need not designate them for protection until after the inspecting Party has indicated 22 which documents it would like copied and produced. During the inspection and 23 before the designation, all of the material made available for inspection shall be 24 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 25 documents it wants copied and produced, the Producing Party must determine which 26 documents, or portions thereof, qualify for protection under this Order. Then, 27 before producing the specified documents, the Producing Party must affix the 1 “ CONFIDENTIAL legend” to each page that contains Protected Material. If only a 2 portion of the material on a page qualifies for protection, the Producing Party also 3 must clearly identify the protected portion(s) (e.g., by making appropriate markings 4 in the margins). 5 (b) for testimony given in depositions that the Designating Party identifies 6 the Disclosure or Discovery Material on the record, before the close of the 7 deposition all protected testimony. 8 (c) for information produced in some form other than documentary and 9 for any other tangible items, that the Producing Party affix in a prominent place on 10 the exterior of the container or containers in which the information is stored the 11 legend “CONFIDENTIAL.” If only a portion or portions of the information 12 warrants protection, the Producing Party, to the extent practicable, shall identify the 13 protected portion(s). 14 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 15 failure to designate qualified information or items does not, standing alone, waive 16 the Designating Party’s right to secure protection under this Order for such material. 17 Upon timely correction of a designation, the Receiving Party must make reasonable 18 efforts to assure that the material is treated in accordance with the provisions of this 19 Order. 20 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 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 The burden of persuasion in any such challenge proceeding shall be on 27 the Designating Party. Frivolous challenges, and those made for an improper 1 p urpose (e.g., to harass or impose unnecessary expenses and burdens on other 2 parties) may expose the Challenging Party to sanctions. Unless the Designating 3 Party has waived or withdrawn the confidentiality designation, all parties shall 4 continue to afford the material in question the level of protection to which it is 5 entitled under the Producing Party’s designation until the Court rules on the 6 challenge. 7 7. ACCESS TO AND USE OF PROTECTED MATERIAL 8 7.1 Basic Principles. A Receiving Party may use Protected Material that is 9 disclosed or produced by another Party or by a Non-Party in connection with this 10 Action only for prosecuting, defending or attempting to settle this Action. Such 11 Protected Material may be disclosed only to the categories of persons and under the 12 conditions described in this Order. When the Action has been terminated, a 13 Receiving Party must comply with the provisions of section 13 below (FINAL 14 DISPOSITION). 15 Protected Material must be stored and maintained by a Receiving Party at a 16 location and in a secure manner that ensures that access is limited to the persons 17 authorized under this Order. 18 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 19 otherwise ordered by the court or permitted in writing by the Designating Party, a 20 Receiving Party may disclose any information or item designated 21 “CONFIDENTIAL” only to: 22 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 23 well as employees of said Outside Counsel of Record to whom it is reasonably 24 necessary to disclose the information for this Action; 25 (b) the officers, directors, and employees (including House Counsel) of 26 the Receiving Party to whom disclosure is reasonably necessary for this Action; 27 (c) Experts (as defined in this Order) of the Receiving Party to whom 1 d isclosure is reasonably necessary for this Action and who have signed the 2 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 3 (d) the court and its personnel; 4 (e) court reporters and their staff; 5 (f) professional jury or trial consultants, mock jurors, and Professional 6 Vendors to whom disclosure is reasonably necessary for this Action and who have 7 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 8 (g) the author or recipient of a document containing the information or a 9 custodian or other person who otherwise possessed or knew the information; 10 (h) during their depositions, witnesses, and attorneys for witnesses, in the 11 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 12 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will 13 not be permitted to keep any confidential information unless they sign the 14 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 15 agreed by the Designating Party or ordered by the court. Pages of transcribed 16 deposition testimony or exhibits to depositions that reveal Protected Material may 17 be separately bound by the court reporter and may not be disclosed to anyone except 18 as permitted under this Stipulated Protective Order; and 19 (i) any mediator or settlement officer, and their supporting personnel, 20 mutually agreed upon by any of the parties engaged in settlement discussions. 21 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 22 IN OTHER LITIGATION 23 If a Party is served with a subpoena or a court order issued in other litigation 24 that compels disclosure of any information or items designated in this Action as 25 “CONFIDENTIAL,” that Party must: 26 (a) promptly notify in writing the Designating Party. Such notification 27 shall include a copy of the subpoena or court order; 1 (b) promptly notify in writing the party who caused the subpoena or order 2 to issue in the other litigation that some or all of the material covered by the 3 subpoena or order is subject to this Protective Order. Such notification shall include 4 a copy of this Stipulated Protective Order; and 5 (c) cooperate with respect to all reasonable procedures sought to be 6 pursued by the Designating Party whose Protected Material may be affected. 7 If the Designating Party timely seeks a protective order, the Party served with 8 the subpoena or court order shall not produce any information designated in this 9 action as “CONFIDENTIAL” before a determination by the court from which the 10 subpoena or order issued, unless the Party has obtained the Designating Party’s 11 permission. The Designating Party shall bear the burden and expense of seeking 12 protection in that court of its confidential material and nothing in these provisions 13 should be construed as authorizing or encouraging a Receiving Party in this Action 14 to disobey a lawful directive from another court. 15 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 16 PRODUCED IN THIS LITIGATION 17 (a) The terms of this Order are applicable to information produced by a 18 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 19 produced by Non-Parties in connection with this litigation is protected by the 20 remedies and relief provided by this Order. Nothing in these provisions should be 21 construed as prohibiting a Non-Party from seeking additional protections. 22 (b) In the event that a Party is required, by a valid discovery request, to 23 produce a Non-Party’s confidential information in its possession, and the Party is 24 subject to an agreement with the Non-Party not to produce the Non-Party’s 25 confidential information, then the Party shall: 26 (1) promptly notify in writing the Requesting Party and the Non-Party 27 that some or all of the information requested is subject to a confidentiality 1 a greement with a Non-Party; 2 (2) promptly provide the Non-Party with a copy of the Stipulated 3 Protective Order in this Action, the relevant discovery request(s), and a reasonably 4 specific description of the information requested; and 5 (3) make the information requested available for inspection by the 6 Non-Party, if requested. 7 (c) If the Non-Party fails to seek a protective order from this court within 8 14 days of receiving the notice and accompanying information, the Receiving Party 9 may produce the Non-Party’s confidential information responsive to the discovery 10 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 11 not produce any information in its possession or control that is subject to the 12 confidentiality agreement with the Non-Party before a determination by the court. 13 Absent a court order to the contrary, the Non-Party shall bear the burden and 14 expense of seeking protection in this court of its Protected Material. 15 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 16 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 17 Protected Material to any person or in any circumstance not authorized under this 18 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 19 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 20 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 21 persons to whom unauthorized disclosures were made of all the terms of this Order, 22 and (d) request such person or persons to execute the “Acknowledgment and 23 Agreement to Be Bound” that is attached hereto as Exhibit A. 24 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 25 PROTECTED MATERIAL 26 When a Producing Party gives notice to Receiving Parties that certain 27 inadvertently produced material is subject to a claim of privilege or other protection, 1 t he obligations of the Receiving Parties are those set forth in Federal Rule of Civil 2 Procedure 26(b)(5)(B). This provision is not intended to modify whatever 3 procedure may be established in an e-discovery order that provides for production 4 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and 5 (e), insofar as the parties reach an agreement on the effect of disclosure of a 6 communication or information covered by the attorney-client privilege or work 7 product protection, the parties may incorporate their agreement in the stipulated 8 protective order submitted to the court. 9 12. MISCELLANEOUS 10 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 11 person to seek its modification by the Court in the future. 12 12.2 Right to Assert Other Objections. By stipulating to the entry of this 13 Protective Order, no Party waives any right it otherwise would have to object to 14 disclosing or producing any information or item on any ground not addressed in this 15 Stipulated Protective Order. Similarly, no Party waives any right to object on any 16 ground to use in evidence of any of the material covered by this Protective Order. 17 12.3 Filing Protected Material. A Party that seeks to file under seal any 18 Protected Material must comply with Local Civil Rule 79-5. Protected Material 19 may only be filed under seal pursuant to a court order authorizing the sealing of the 20 specific Protected Material at issue. If a Party’s request to file Protected Material 21 under seal is denied by the court, then the Receiving Party may file the information 22 in the public record unless otherwise instructed by the court. 23 13. FINAL DISPOSITION 24 After the final disposition of this Action, as defined in paragraph 4, within 60 25 days of a written request by the Designating Party, each Receiving Party must return 26 all Protected Material to the Producing Party or destroy such material. As used in 27 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 1 s ummaries, and any other format reproducing or capturing any of the Protected 2 Material. Whether the Protected Material is returned or destroyed, the Receiving 3 Party must submit a written certification to the Producing Party (and, if not the same 4 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 5 (by category, where appropriate) all the Protected Material that was returned or 6 destroyed and (2) affirms that the Receiving Party has not retained any copies, 7 abstracts, compilations, summaries or any other format reproducing or capturing any 8 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 9 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 10 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 11 reports, attorney work product, and consultant and expert work product, even if such 12 materials contain Protected Material. Any such archival copies that contain or 13 constitute Protected Material remain subject to this Protective Order as set forth in 14 Section 4 (DURATION). 15 16 17 18 19 20 21 22 23 24 25 26 27 1))14. VIOLATION 2 Any violation of this Order may be punished by appropriate measures 3 |lincluding, without limitation, contempt proceedings and/or monetary sanctions. 4//IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 5 || DATED: October 19, 2020 6 ||_/s/ Derek S. Chaiken 4 Derek S. Chaiken Attorneys for Plaintiff Tracey Bregman 9 10 DATED: October 18, 2020 /s/ Jonathan Dutton 11 1 Jonathan Dutton 12 Attorneys for Defendant Certain Underwriters at Lloyd’s, London Subscribing to 13 || Policy Nos. HGBO135371 14

ATTESTATION

15 Pursuant to this Court’s Local Rules, I hereby certify that the content of this 16 document is acceptable to Jonathan Dutton, counsel for Defendant, and that I have 17 obtained Mr. Dutton’s authorization to affix his electronic signature to this 18 document. 19 20 /s/ Derek S. Chaiken 3 Derek S. Chaiken

29 DATED: October 19, 2020 23 24 25 | OOOO

GAIL J. STANDISH

26 || UNITED STATES MAGISTRATE JUDGE 27 28 16

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 on [date] in the case of Tracey Bregman v. Certain Underwriters at Lloyd’s, 8 London Subscribing to Policy Nos. HGB0135371, United States District Court, 9 Central District of California Case No. 2:20-CV-06207-SVW-GJS. I agree to 10 comply with and to be bound by all the terms of this Stipulated Protective Order and 11 I understand and acknowledge that failure to so comply could expose me to 12 sanctions and punishment in the nature of contempt. I solemnly promise that I will 13 not disclose in any manner any information or item that is subject to this Stipulated 14 Protective Order to any person or entity except in strict compliance with the 15 provisions of this Order. 16 I further agree to submit to the jurisdiction of the United States District Court for the 17 Central District of California for enforcing the terms of this Stipulated Protective 18 Order, even if such enforcement proceedings occur after termination of this action. 19 I hereby appoint __________________________ [print or type full name] of 20 _______________________________________ [print or type full address and 21 telephone number] as my California agent for service of process in connection with 22 this action or any proceedings related to enforcement of this Stipulated Protective 23 Order. 24 Date: ______________________________________ 25 City and State where sworn and signed: _________________________________ 26 Printed name: _______________________________ 27 Signature: __________________________________