The opinion
EEE EEE SE NEE am A eee Na eS wT ee .
1 | LAURIE E. SHERWOOD, State Bar No. 155312 □□
Isherwood@wfbm.com
|| WFBM, LLP □
601 Montgomery Street, Ninth Floor
3 ?
San Francisco, California 94111-2612 MANDATORY
_ 41lTelephone: (415) 781-7072
imile: 15) 391- □□ □□□
5 ||Facsimile: (415) 391-6258 CHAMBERS COPY
6 || SAGE R. KNAUFT, State Bar No. 194396
7 sknauft@wfbm.com
REEMA ABBOUD, State Bar No. 301841
8 || rabboud@wfbm.com
9 || WFBM, LLP
One City Boulevard West, Fifth Floor
10 || Orange, California 92868-3677
il Telephone: (714) 634-2522
Facsimile: (714) 634-0686
12
= 8
13 || Attorneys for Defendant,
Es STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY
bia
15 || A: JACOB NALBANDYAN, State Bar No. 272023
5 8 jnalbandyan@Intriallawyers.com
16 || TANGANICA J. TURNER, State Bar No. 315716 □
17 || tturer@lntriallawyers.com vee
LEVIN & NALBANDYAN, LLP
18]/811 Wilshire Boulevard, Suite 800 .
19 || Los Angeles, California 90017 _
Telephone: (213) 232-4848 . .
20|/Facsimile: (213) 232-4849 NOTE CHANGES MADE 3Y THE COURT
Attorneys for Plaintiff,
ANNA ANUSH KHACHATRYAN □
UNITED STATES DISTRICT COURT
23 CENTRAL DISTRICT OF CALIFORNIA
2A ANNA ANUSH KHACHATRYAN, an Case No. 2:18-cv-9084 PSG (AGR)
25 || individual, .
Los Angeles County Superior Court
26 Plaintiff, es No. BC752280]
27 STIPULATED PROTECTIVE
v. ORDER.
28
5 NOTE CHANGES MADE BY THE COURT
IIE IIIIIE IIIS IDE BIDE NIPSEIAGONAS SEN Ow NN Be TAY LS □□
1 STATE FARM MUTUAL AUTOMOBILE
INSURANCE COMPANY, an Illinois
9 || Corporation, and DOES 1 through 20, Inclusive,
3 Defendants.
4 1. PURPOSES AND LIMITATIONS
5 Discovery in this action is likely to involve production of confidential,
6 || Proprietary or private information for which special protection from public
7 || disclosure and from use for any purpose other than pursuing this litigation may be
g || warranted. Accordingly, the parties hereby stipulate to and petition the Court to
g|jenter the following Stipulated Protective Order. The parties acknowledge that this
10 || Order does not confer blanket protections on all disclosures or responses to
11 || discovery and that the protection it affords from public disclosure and use extends
12 || only to the limited information or items that are entitled to confidential treatment
; 13 || under the applicable legal principles. ~
; 4 2. GOODCAUSE STATEMENT
38 15 This action is likely to involve trade secrets, medical information, third party
ES 16 || identification and other valuable confidential or proprietary information for which
17 || Special protection from public disclosure and from use for any purpose other than
18 ||Prosecution of this action is warranted. Such confidential and proprietary materials
19 || and information consist of, among other things, confidential business or financial
40 || information, information regarding confidential business practices, or other
21 || confidential research, development, or commercial information (including
22 || information implicating privacy rights of third parties), information otherwise
23 || generally unavailable to the public, or which may be privileged or otherwise
24 || protected from disclosure under state or federal statutes, court rules, case decisions,
25 || or common law. Accordingly, to expedite the flow of information, to facilitate the
26 || prompt resolution of disputes over confidentiality of discovery materials, to
27 || adequately protect information the parties are entitled to keep confidential, to ensure
28 || that the parties are permitted reasonable necessary uses of such material in
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IEE OIRO EIEN. Ge NEE ils WP MM eR AY OP □□
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.
8 3. | ACKNOWLEDGMENT OF UNDER SEAL FILING PROCEDURE
9 The parties further acknowledge, as set forth in Section 14.3, 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. |Fhere-is-a-streng_presumption that the-public has- righ
14 |Ofaccess to judicial proceedings and records in civil cases. In connection with non
8 15 ne on good cause must be shown to support a filing under‘seal. See
: 5 16 ||\Kamakana City and County of Honolulu 447 F.3d 1172, 1176(9th Cir. 2006),
17 Phillips v. Gen. M otors Corp., 307 F.3d 1206, 1210-11 (9#fCir. 2002), Makar-
18||hwelbon v. Sony BleStrios, Inc., 187 FD. 576, STI(E.D. Wis. 1999) (even
19 || Stipulated protective orders require good causeShowing), and a specific showing of
20 || good cause or compelling reason3nwith pr6per evidentiary support andlegal
21 |justification, must be made with respechto Protected Material that a party seeks to
22 || file under seal. The parties’ m€ére designatiotof Disclosure or Discovery Material 5
23 || CONFIDENTIAL does fot— without the submission of competent evidence by
24 || declaration, establishing that the material sought to be fied under seal qualifies as
25 || confidential Privileged, or otherwise protectable—constitute 2aod cause.
26 || Rurther,if a party requests sealing related to a dispositive motion or tial, then
|| govhpelling reasons, not only good cause, for the sealing must be shown, and 16
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EIEIO IIE OIE IN ae OTT □ □□□ □□ oe
1 lIrettefs ought shall be narrowly tailored to serve the specific interest to be proteCted.
2 Creditors Ass’n., 605 F.3d 665, 677-79 (9trCir. 2010). For
3]!each item or type of informatton,document, or thing Sought to be filed or introduced
4 under seal, the party seeking protectierr mustasticulate compelling reasons, □
|lsupported by specific faets“and legal justification, for thé 2 jested sealing order.
6 ||Again, competént evidence supporting the application to file documents.under seal
7 |Ipust 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.
10 || If documents can be redacted, then a redacted version for public viewing, omitting
§ 11 || only the confidential, privileged, or otherwise protectable portions of the document,
: : a 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.
14 4. DEFINITIONS
15 4.1. Action: Anna Anush Khachatryan, an individual v. State Farm Mutual
5 16 || Automobile Insurance Company; et al., Case No. 2:18-cv-9084 PSG (AGR);
4.2 Challenging Party: a Party or Non-Party that challenges the ~~
18 || designation of information or items under this Order.
- 4.3 “CONFIDENTIAL” Information or Items: information
20 || (regardless of how it is generated, stored or maintained) or tangible things that
21 || qualify for protection under Federal Rule of Civil Procedure 26(c), and as specified
22]/above in the Good Cause Statement.
44 Counsel: Outside Counsel of Record and House Counsel (as well.
24 |! as their support staff). □
25 4.5 Designating Party: a Party or Non-Party that designates
26 || information or items that it produces in disclosures or in responses to discovery as
27 || “CONFIDENTIAL.”
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-4.
IIE III IIE ONES OR NEE ONE NN me TE □ □□□□ □ □□
1 4.6 Disclosure or Discovery Material: all items or information,
2 ||regardless of the medium or manner in which it is generated, stored, or maintained
3 || (including, among other things, testimony, transcripts, and tangible
4 || things), that are produced or generated in disclosures or responses to discovery.
5 4.7 Expert: a person with specialized knowledge or experience in a
6 || matter pertinent to the litigation who has been retained by a Party or its counsel
7 || to serve as an expert witness or as a consultant in this Action.
8 4.8 | House Counsel: attorneys who are employees of a party to this
9 || Action. House Counsel does not include Outside Counsel of Record or any other
10.|| outside counsel. .
11 4.9 Non-Party: any natural person, partnership, corporation,
: 12 || association or other legal entity not named as a Party to this action.
13 4.10 Outside Counsel of Record: attorneys who are not employees of a party
14|\to this Action but are retained to represent a party to this Action and have appeared
15 || in this Action on behalf of that party or are affiliated with a law firm that has
16 || appeared on behalf of that party, and includes support staff.
17 4.11 Party: any party to this Action, including all of its officers, directors,
18 || employees, consultants, retained experts, and Outside Counsel of Record (and
19 || their support staffs).
20 4.12 Producing Party: a Party or Non-Party that produces Disclosure or
21 || Discovery Material in this Action.
22 4.13 Professional Vendors: persons or entities that provide litigation
|| support services (e.g., photocopying, videotaping, translating, preparing exhibits
or demonstrations, and organizing, storing, or retrieving data in any form or
25 ||medium) and their employees and subcontractors.
26 4.14 Protected Material: any Disclosure or Discovery Material that is
27 || designated as “CONFIDENTIAL.”
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III EIEIO IIIS ISTE IERIE RE NES 0SWNAE Ws SAE NERY OF TY
1 4.15 Receiving Party: a Party that receives Disclosure or Discovery Material
2 || from a Producing Party.
3 5. SCOPE
4 The protections conferred by this Stipulation and Order cover not only □
5 || Protected Material (as defined above), but also (1) any information copied or
6 || extracted from Protected Material; (2) all copies, excerpts, summaries, or
7 || compilations of Protected Material; and (3) any testimony, conversations, or
8 presentations by Parties or their Counsel that might reveal Protected Material.
9 || Any use of Protected Material at trial shall be governed by the orders of the trial
10 || judge and other applicable authorities. This Order does not govern the use of
5 11 Protected Material at trial.
12 6. DURATION _ □
: 13 | Once a case proceeds to trial, information that was designated as
: || CONFIDENTIAL or maintained pursuant to this protective order used or introduced
15.||as an exhibit at trial becomes public and will be presumptively available to all
: 16 ||members of the public, including the press, unless compelling reasons supported by
17 || specific factual findirigs to proceed otherwise are made to the trial judge in advance
18 || of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause”
19 showing for sealing documents produced in discovery from “compelling reasons”
20 || standard when merits-related documents are part of court record). Accordingly, the
21 ||terms of this protective order do not extend beyond the commencement of the trial.
221 7. | DESIGNATING PROTECTED MATERIAL
7.1 Exercise of Restraint and Care in Designating Material for Protection.
/||Bach Party or Non-Party that designates information or items for protection under
25 || this Order must take care to limit any such designation to specific material that
26 || qualifies under the appropriate standards. The Designating Party must designate for
27 protection only those parts of material, documents, items or oral or written □
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6.
EEE IEEE II III I INES ONSEN NAS AT NN Ele OP OP
1 || communications that qualify so that other portions of the material, documents,
2 || items or communications for which protection is not warranted are not swept
3 || unjustifiably within the ambit of this Order.
4 Mass, indiscriminate or routinized designations are prohibited. Designations
5 || that are shown to be clearly unjustified or that have been made for an improper
6 || purpose (e.g., to unnecessarily encumber the case development process or to impose
7 || unnecessary expenses and burdens on other parties) may expose the Designating
8 || Party to sanctions.
9 If it comes to a Designating Party’s attention that information or items that it
10 || designated for protection do not qualify for protection, that Designating Party must
11 |) promptly notify all other Parties that it is withdrawing the inapplicable designation.
12 7.2 | Manner and Timing of Designations. Except as otherwise provided
g 13 || in this Order, or as otherwise stipulated or ordered, Disclosure of Discovery
3 14'|| Material that qualifies for protection under this Order must be clearly so
15 || designated. before the material is disclosed or produced.
5 16 Designation in conformity with this Order requires:
17 (a) for information in documentary form (e.g., paper or electronic
18 || documents, but excluding transcripts of depositions or other pretrial or trial
19 || proceedings), that the Producing Party affix at a minimum, the legend
20 || “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
21 contains protected material. If only a portion of the material on a page qualifies for
22 || protection, the Producing Party also must clearly identify the protected portion(s)
-23'||(e.g., by making appropriate markings in the margins). == □
241 A Party or Non-Party that makes original documents available for inspection
25 || need not designate them for protection until after the inspecting Party has indicated
26 || which documents it would like copied and produced.
27|)
28 ||
I IEEE IIE III EORE IIE NENG Bw Af NN NE TAY OT
1 || During the inspection and before the designation, all of the material made available
for inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has
3 || identified the documents it wants copied and produced, the Producing Party must
4 || determine which documents, or portions thereof, qualify for protection under this
5 || Order. Then, before producing the specified documents, the Producing Party must
6 || affix the “CONFIDENTIAL legend” to each page that contains Protected Material.
7 || If only a portion of the material on a page qualifies for protection, the Producing
8 || Party also must clearly identify the protected portion(s) (e.g., by making appropriate
9 | markings in the margins).
10 (b) for testimony given in depositions that the Designating Party
11 || identifies the Disclosure or Discovery Material on the record, before the close of
12 || the deposition all protected testimony.
13 (c) for information produced in some form other than documentary and
14 || for any other tangible items, that the Producing Party affix in a prominent place on
8 15 || the exterior of the container or containers in which the information is stored the
: 16 || legend “CONFIDENTIAL.” If only a portion or portions of the information
‘17 || warrants protection, the Producing Party, to the extent practicable, shall identify the
18 || protected portion(s). _
19 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
20 || failure to designate qualified information or items does not, standing alone, waive
21 || the Designating Party’s right to secure protection under this Order for such
22 || material. Upon timely correction of a designation, the Receiving Party must make
23 ||reasonable efforts to assure that the material is treated in accordance with the
24 |I provisions of this Order.
\/// □□
26|{/// .
27/11
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IIE EEE IE □□□ IIT Un IIA NANA Eom NIV Wile WO OMT RYN TT
1 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS
2 8.1. Timing of Challenges. Any Party or Non-Party may challenge a
3 || designation of confidentiality at any time that is consistent with the Court’s
4 || Scheduling Order. . □
5 8.2 Meet and Confer. The Challenging Party shall initiate the dispute
6 || resolution process under Local Rule 37-1 et seq.
7 8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a
8 || joint stipulation pursuant to Local Rule 37-2.
9 8.4 The burden of persuasion in any such challenge proceeding shall be on
10 || the Designating Party. Frivolous challenges, and those made for an improper
11 | purpose (e.g., to harass or impose unnecessary expenses and burdens on other
: a 12 || parties) may expose the Challenging Party to sanctions. Unless.the Designating
13)/Party has waived or withdrawn the confidentiality designation, all parties □□□□□□ .
continue to afford the material in question the level of protection to which it is. -_
15 || entitled under the Producing Party’s designation until the Court rulesonthe □□
; 16 || challenge.
9,
18 9.1 Basic Principles, A Receiving Party may use Protected Material that is
19 || disclosed or produced by another Party or by a Non-Party in connection with
20 || this Action only for prosecuting, defending or attempting to settle this Action.
21 || Such Protected Material may be disclosed only to the categories of persons and □
22 || under the conditions described in this Order. When the Action hasbeen.
23 || terminated, a Receiving Party must comply with the provisions of section 15
||below (FINAL DISPOSITION). _
25 Protected Material must be stored and maintained by a Receiving Party
26 || at a location and in a secure manner that ensures that access is limited to the
27 || persons authorized under this Order. :
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EE EEE IT IIE □□□
1 9.2 Disclosure of “CONFIDENTIAL” Information or Items.
“2 Unless otherwise ordered by the court or permitted in writing by the
3 || Designating Party, a Receiving Party may disclose any information or item
4 || designated “CONFIDENTIAL” only to:
5 (a) the Receiving Party’s Outside Counsel of Record in this Action,
6 || as well as employees of said Outside Counsel of Record to whom it is
7 || reasonably necessary to disclose the information for this Action;
8 (b) the officers, directors, and employees (including House
9 || Counsel) of the Receiving Party to whom disclosure is reasonably necessary
for this Action;
eve Li (c) Experts (as defined in this Order) of the Receiving Party to
12 || whom disclosure is reasonably necessary for this Action and who have signed
E 13 || the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
3 14 (d) the court and its personnel;
15 (e) court reporters and their staff,
; 16 (f) professional jury or trial consultants, mock jurors, and
17 || Professional Vendors to whom disclosure is reasonably necessary for this
18 | Action and who have signed the “Acknowledgment and Agreement to Be
Bound” (Exhibit A);
20 (g) the author or recipient of a document containing the .
21 || information or a custodian or other person who otherwise possessed or knew
22 || the information;
23'| (h) during their depositions, witnesses, and attorneys for witnesses,
in the Action to whom disclosure is reasonably necessary provided: □□□ □□□ □□□□□
25 || deposing party requests that the witness sign the form attached as Exhibit A
26 || hereto; and (2) they will not be permitted to keep any confidential information
27 | unless they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit
28
I IIE IIIIEE IRIOE ISIE PN QR in an NAN Em ne SA TE □□
1 || A), unless otherwise agreed by the Designating Party or ordered by the court.
2 || Pages of transcribed deposition testimony or exhibits to depositions that reveal
3 || Protected Material may be separately bound by the court reporter and may not
4 |!be disclosed to anyone except as permitted under this Stipulated Protective
5 || Order; and
_ (i) any mediators or settlement officers and their supporting
personnel, mutually agreed upon by any of the parties engaged in settlement
8 || discussions.
9 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED
10. PRODUCED IN OTHER LITIGATION
11 Ifa Party is served with a subpoena or a court order issued in other
12 || litigation that compels disclosure of any information or items designated in this
: Action as “CONFIDENTIAL,” that Party must:
3 14]. (a) promptly notify in writing the Designating Party. Such
15 || notification shall include a copy of the subpoena or court order; .
16]| (b) promptly notify in writing the party who caused the subpoena
]/or order to issue in the other litigation that some or all of the material covered
18 by the subpoena or order is subject to this Protective Order. Such notification
19 || shall include a copy of this Stipulated Protective Order; and
(c) cooperate with respect to all reasonable procedures sought to be
21 || pursued by the Designating Party whose Protected Material may be affected. If
22 || the Designating Party timely seeks a protective order, the Party served with the
23 || subpoena or court order shall not produce any information designated in this
24 || action as “CONFIDENTIAL?” before a determination by the court from which
25 || the subpoena or order issued, unless the Party. has obtained the Designating |
26 || Party’s permission. The Designating Party shall bear the burden and expense of
27 || seeking protection in that court of its confidential material and nothing in these
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IEEE II IIIS EE IOIOIRD SOOSEIEID NEE ONAN ie me AE RK MAYS Oe TT ee
1 || provisions should be construed as authorizing or encouraging a Receiving Party
2 |lin this Action to disobey a lawful directive from another court.
3 11. ANON-PARTY'S PROTECTED MATERIAL SOUGHT TO BE
4 PRODUCED IN THIS LITIGATION
5 (a) The terms of this Order are applicable to information produced
6 a Non-Party in this Action and designated as “CONFIDENTIAL.” Such
7 || information produced by Non-Parties in connection with this litigation is
8 || protected by the remedies and relief provided by this Order. Nothing in these □
9 || provisions should be construed as prohibiting a Non-Party from seeking
. 10 || additional protections.
11. (b) In the event that a Party is required, by a valid discovery
: 12 || request, to produce a Non-Party’s confidential information in its possession,
13 || and the Party is subject.to an agreement with the Non-Party not to produce the
E 14]/Non-Party’s confidential information, then the Party shall: oe
15 (1) promptly notify in writing the Requesting Party and the Non- .
53 16||Party that some or all of the information requested is subjecttoa
| 17 || confidentiality agreement with a Non-Party;
18 . (2) promptly provide the Non-Party with a copy of the Stipulated
19 | Protective Order in this Action, the relevant discovery request(s), and
20 || reasonably specific description of the information requested; and
21 (3) make the information requested available for inspection by the
22 || Non-Party, if requested. □
23 (c) If the Non-Party fails to seek a protective order from this court
within 14 days of receiving the notice and accompanying information, the
25 || Receiving Party may produce the Non-Party’s confidential information
26 || responsive to the discovery request. If the Non-Party timely seeks a protective
27 || order, the Receiving Party shall not produce any information in its possession or
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IEEE III IS IIIS DENI SENG IRIN ONAN NAT MY OM □□ □□
1 | control that is subject to the confidentiality agreement with the Non-Party
2 || before a determination by the court. Absent a court order to the contrary, the
3 || Non-Party shall bear the burden and expense of seeking protection in this court
4 || of its Protected Material.
5 12. UNAUTHORIZED DISCLOSURE OF PROTECTED
6 MATERIAL
7H Ifa Receiving Party learns that, by inadvertence or otherwise, it has
8 || disclosed Protected Material to any person or in any circumstance not
9 || authorized under this Stipulated Protective Order, the Receiving Party must
10 || immediately (a) notify in writing the Designating Party of the unauthorized
5 11 || disclosures, (b) use its best efforts to retrieve all unauthorized copies of the
12 Protected Material, (c) inform the person or persons to whom unauthorized
13 |; disclosures were made of all the terms of this Order, and (d) request such
3 14/]/person or persons to execute the “Acknowledgment an Agreement to Be
15|[Bound” attached hereto as Exhibit A.
16 13. INADVERTENT PRODUCTION OF PRIVILEGED OR
OTHERWISE PROTECTED MATERIAL
18 || When a Producing Party gives notice to Receiving Parties that certain
19 || inadvertently produced material is subject to a claim of privilege or other
20 || protection, the obligations of the Receiving Parties are those set forth in Federal
21 || Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify
22 || whatever procedure may be established in an e-discovery order that provides
23 || for production without prior privilege review. Pursuant to Federal Rule of
24 Evidence 502(d) and (e), insofar as the parties reach an agreement on the effect —
25 || of disclosure of a communication or information covered by the attorney-client
26 || privilege or work product protection, the parties may incorporate their
27 || agreement in the stipulated protective order submitted to the-court.
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EI ENED SEOUL IGE OVE NE EEE OA ee eee
1 14. MISCELLANEOUS
2 14.1 Right to Further Relief. Nothing in this Order abridges the right of
3 || any person to seek its modification by the Court in the future.
4 14.2 Right to Assert Other Objections. By stipulating to the entry of this
5 || Protective Order, no Party waives any right it otherwise would have to object to
6 || disclosing or producing any information or item on any ground not addressed in
7 || this Stipulated Protective Order. Similarly, no Party waives any right to object
8 On any ground to use in evidence of any of the material covered by this
9 || Protective Order.
10 14.3 Filing Protected Material. A Party that seeks to file under seal any
11 || Protected Material must comply with Local Civil Rule 79-5. Protected Material
12 ||may only be filed under seal pursuant to a court order authorizing the sealing of
13 || the specific Protected Material. If a Party’s request to file Protected Material
3 |) under seal is denied by the court, then the Receiving Party may file the
8 15 || information in the public record unless otherwise instructed by the court.
(16 15. FINAL DISPOSITION
After the final disposition of this Action, as defined in paragraph 6,
18 |) within 60 days of a written request by the Designating Party, each Receiving _
19 || Party must return all Protected Material to the Producing Party or destroy
20 ||such material. As used in this subdivision, “all Protected Material” includes
21 || all copies, abstracts, compilations, summaries, and any other format
22 || reproducing or capturing any of the Protected Material. Whether the
23 || Protected Material is returned or destroyed, the Receiving Party must submit
24 || written certification to the Producing Party (and, ifnot the same person
25 || entity, to the Designating Party) by the 60-day deadline that (1) identifies (by
26 || category, where appropriate) all the Protected Material that was returned or
27 || destroyed and (2) affirms that the Receiving Party has not retained any copies,
EI IIS IGE! ENE NN NN Oe OTE □ □□□ □□
1 || abstracts, compilations, summaries or any other format reproducing or. .
2 || capturing any of the Protected Material. Notwithstanding this provision,
3 || Counsel are entitled to retain an archival copy of all pleadings, motion papers,
4/||trial, deposition, and hearing transcripts, legal memoranda, correspondence,
5 || deposition and trial exhibits, expert reports, attorney work product, and
6 || consultant and expert work product, even if such materials contain Protected
7 || Material. Any such archival copies that contain or constitute Protected
8 || Material: remain subject to this Protective Order as set forth in Section 6
9 || (DURATION). .
~~ 16. VIOLATION
§ 11 Any violation of this Order may be punished by appropriate
: 12 || measures including, without limitation, contempt proceedings and/ or
i 13 |}monetary sanctions. . .
5 14 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
15
||Dated: August 26,2019. LEVIN & NALBANDYAN, LLP
4 eo □
18 By: /s/ Tanganica J. Turner .
19] JACOB NALBANDYAN □ .
20 TANGANICA J. TURNER
: Attorneys for Plaintiff -
21 oo ANNA ANUSH KHACHATRYAN
22 .
25 . .
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28 . .
oo Eo ee Ee ee ON eR NANA NATE AEE Se FOR UN Be er OL gv su Vet IY □□□
Dated: August 26, 2019 WFBM, LLP
2 .
4 By: /s/Reema Abboud
5 LAURIE E. SHERWOOD
SAGE R. KNAUFT
6 REEMA ABBOUD
7 Attorneys for Defendant
□ STATE FARM MUTUAL AUTOMOBILE
8 INSURANCE COMPANY
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IEE EE IEE EO a” —_—anmeiseee ee fe NE Bee eae ' gw at MI ee BRAWN PR □□ □□
1 ATTORNEY ATTESTATION.
2 Pursuant to Central District Local Rule 5-4.3.4(a)(2), 1, Reema Abboud, attest
that all other signatories listed, and on whose behalf the filling is submitted, concur
4 |j in the filing’s content and have authorized the filing.
5 Executed on August 26, 2019, in Orange, California.
7 Dated: August 26, 2019 WFBM, LLP
9
By: /s/ Reema Abboud
10 REEMA ABBOUD
11 Attorneys for Defendant
STATE FARM MUTUAL AUTOMOBILE
pga 2 INSURANCE COMPANY
She 15
sig
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IEEE III IEEE MEONRE We SABB ND NM Ee AY OLY TPL
FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
3 || DATED: ‘| 6|2014 (be: 2-L\. UNL
4 U.S. DISTRICT COURT TAG TRATE JUDGE
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_ EXHIBIT "A"
EXHIBIT A □
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
I, [name], of
_ [address], declare under penalty of
perjury that I have read in its entirety and understand the Stipulated Protective
Order that was issued by the United States District Court for the Central District of
California in the case of Khachatryan v. State Farm, Case No. 2:18-cv-9084 PSG
(AGR). I agree to comply with and to be bound by all the terms of this Stipulated
Protective Order and I understand and acknowledge that failure to so comply could
expose me to sanctions and punishment in the nature of contempt. I solemnly
promise that I will not disclose in any manner any information or item that is
subject to this Stipulated Protective Order to any person or entity except in strict
compliance with the provisions of this Order. I further agree to submit to the
jurisdiction of the United States District Court for the Central District of California
for the purpose of enforcing the terms of this Stipulated Protective Order, even if
such enforcement proceedings occur after termination of this action. I hereby
appoint. snare] of
[address and telephone number]
as my California agent for service of process in connection with this action or any
_ proceedings related to enforcement of this Stipulated Protective Order.
Date:
City and State:
Printed name:
Signature:
4995-3 4951