The opinion
JOAN E. COCHRAN, ESQ., SBN 128251
1
joan@cochranlaw1.com
2 LISA KRALIK HANSEN, ESQ., SBN 149455
lisa@cochranlaw1.com
3
COCHRAN, DAVIS & ASSOCIATES, P.C.
4 36 Malaga Cove Plaza, Suite 206
Palos Verdes Estates, CA 90274
5
(310) 373-0900 - telephone
6 (310) 373-0244 – facsimile
7
Attorneys for Defendants CERTAIN UNDERWRITERS AT LLOYD'S,
8 LONDON, PIONEER SYNDICATE 1980 and PIONEER SPECIAL RISK
SERVICES, INC.
9
10
UNITED STATES DISTRICT COURT FOR THE
11
12 CENTRAL DISTRICT OF CALIFORNIA
13 WESTERN DIVISION
14
15 1800 ROSECRANS PARTNERS, ) Case No. 2:24-cv-04803-RGK (AJRx)
16 L LC, ) ) )
17 Plaintiff, ) )
v. ) [PROPOSED] STIPULATED
18 ) PROTECTIVE ORDER
)
19 CERTAIN UNDERWRITERS AT )
LLOYD'S, LONDON, PIONEER )
20 )
SYNDICATE 1980 and PIONEER
)
21 SPECIAL RISK SERVICES, INC. )
)
22 )
Defendants. )
23 )
24
25
26
27 1
___________________________________________________________________________________________
1. GENERAL
1
2 1.1 Purposes and Limitations. Discovery in this action is likely to involve
3
production of confidential, proprietary, or private information for which special
4
protection from public disclosure and from use for any purpose other than
5
6 prosecuting this litigation may be warranted. Accordingly, the parties hereby
7
stipulate to and petition the Court to enter the following Stipulated Protective
8
Order. The parties acknowledge that this Order does not confer blanket protections
9
10 on all disclosures or responses to discovery and that the protection it affords from
11
public disclosure and use extends only to the limited information or items that are
12
entitled to confidential treatment under the applicable legal principles. The parties
13
14 further acknowledge, as set forth in Section 12.3, below, that this Stipulated
15
Protective Order does not entitle them to file confidential information under seal;
16
17 Civil Local Rule 79-5 sets forth the procedures that must be followed and the
18 standards that will be applied when a party seeks permission from the court to file
19
material under seal.
20
21 1.2 Good Cause Statement. This action is likely to involve material that
22 at least one of the parties contends qualifies as trade secrets, confidential, financial,
23
proprietary and/or commercially sensitive business information for which special
24
25 protection from public disclosure and from use for any purpose other than
26 prosecution of this action is actually or allegedly warranted, specifically including
27 2
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(a) insurance claims manuals and guidelines that may apply to the claim at issue in
1
2 this lawsuit, (b) insurance underwriting manuals and guidelines that may apply to
3
the insurance policy at issue in this lawsuit, (c) training manuals or materials that
4
would apply to the handling of the insurance claim and/or the issuance of the
5
6 insurance policies at issue in this lawsuit, and (d) financial information of the
7
parties which is not available to the general public for which the responding party
8
seeks to maintain the confidentiality of such financial information. Such actually
9
10 or allegedly confidential and proprietary materials and information could also
11
consist of, among other things, information regarding confidential business
12
practices, confidential research, development, or commercial information
13
14 (including information implicating privacy rights of third parties), information
15
otherwise generally unavailable to the public, or which may be privileged or
16
17 otherwise protected from disclosure under state or federal statutes, court rules, case
18 decisions, or common law. Accordingly, to expedite the flow of information, to
19
facilitate the prompt resolution of disputes over confidentiality of discovery
20
21 materials, to adequately protect information the parties are entitled to keep
22 confidential, to ensure that the parties are permitted reasonable necessary uses of
23
such material in preparation for and in the conduct of trial, to address their
24
25 handling at the end of the litigation, and serve the ends of justice, a protective order
26 for such information is justified in this matter. It is the intent of the parties that
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information will not be designated as confidential for tactical reasons and that
1
2 nothing be so designated without a good faith belief that it has been maintained in
3
a confidential, non-public manner, and there is good cause why it should not be
4
part of the public record of this case.
5
6 2. DEFINITIONS
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2.1 Action: this pending federal lawsuit.
8
2.2 Challenging Party: a Party or Non-Party that challenges the
9
10 designation of information or items under this Order.
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2.3 “CONFIDENTIAL” Information or Items: information (regardless of
12
how it is generated, stored or maintained) or tangible things that qualify for
13
14 protection under Federal Rule of Civil Procedure 26(c), and as specified above in
15
the Good Cause Statement.
16
17 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as
18 their support staff).
19
2.5 Designating Party: a Party or Non-Party that designates information
20
21 or items that it produces in disclosures or in responses to discovery as
22 “CONFIDENTIAL.”
23
2.6 Disclosure or Discovery Material: all items or information, regardless
24
25 of the medium or manner in which it is generated, stored, or maintained (including,
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among other things, testimony, transcripts, and tangible things), that are produced
1
2 or generated in disclosures or responses to discovery in this matter.
3
2.7 Expert: a person with specialized knowledge or experience in a
4
matter pertinent to the litigation who has been retained by a Party or its counsel to
5
6 serve as an expert witness or as a consultant in this Action.
7
2.8 House Counsel: attorneys who are employees of a party to this
8
Action. House Counsel does not include Outside Counsel of Record or any other
9
10 outside counsel.
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2.9 Non-Party: any natural person, partnership, corporation, association,
12
or other legal entity not named as a Party to this action.
13
14 2.10 Outside Counsel of Record: attorneys who are not employees of a
15
party to this Action but are retained to represent or advise a party to this Action
16
17 and have appeared in this Action on behalf of that party or are affiliated with a law
18 firm that has appeared on behalf of that party, including support staff.
19
2.11 Party: any party to this Action, including all of its officers, directors,
20
21 employees, consultants, retained experts, and Outside Counsel of Record (and their
22 support staffs).
23
2.12 Producing Party: a Party or Non-Party that produces Disclosure or
24
25 Discovery Material in this Action.
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2.13 Professional Vendors: persons or entities that provide litigation
1
2 support services (e.g., photocopying, videotaping, translating, preparing exhibits or
3
demonstrations, and organizing, storing, or retrieving data in any form or medium)
4
and their employees and subcontractors.
5
6 2.14 Protected Material: any Disclosure or Discovery Material that is
7
designated as “CONFIDENTIAL.”
8
2.15 Receiving Party: a Party that receives Disclosure or Discovery
9
10 Material from a Producing Party.
11
12
3. SCOPE
13
14 The protections conferred by this Stipulation and Order cover not only
15
Protected Material (as defined above), but also (1) any information copied or
16
17 extracted from Protected Material; (2) all copies, excerpts, summaries, or
18 compilations of Protected Material; and (3) any testimony, conversations, or
19
presentations by Parties or their Counsel that might reveal Protected Material.
20
21 Any use of Protected Material at trial shall be governed by the orders of the
22 trial judge. This Order does not govern the use of Protected Material at trial.
23
24
25 4. DURATION
26 Once a case proceeds to trial, all of the court-filed information to be
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introduced that was previously designated as confidential or maintained pursuant
1
2 to this protective order becomes public and will be presumptively available to all
3
members of the public, including the press, unless compelling reasons supported
4
by specific factual findings to proceed otherwise are made to the trial judge in
5
6 advance of the trial. See Kamakana v. City and Cty. of Honolulu, 447 F.3d 1172,
7
1180-81 (9th Cir. 2006) (distinguishing “good cause” showing for sealing
8
documents produced in discovery from “compelling reasons” standard when
9
10 merits-related documents are part of court record). Accordingly, the terms of this
11
protective order do not extend beyond the commencement of the trial.
12
13
14 5. DESIGNATING PROTECTED MATERIAL
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5.1 Exercise of Restraint and Care in Designating Material for Protection.
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17 Each Party or Non-Party that designates information or items for protection under
18 this Order must take care to limit any such designation to specific material that
19
qualifies under the appropriate standards. The Designating Party must designate for
20
21 protection only those parts of material, documents, items, or oral or written
22 communications that qualify so that other portions of the material, documents,
23
items, or communications for which protection is not warranted are not swept
24
25 unjustifiably within the ambit of this Order.
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Mass, indiscriminate, or routinized designations are prohibited.
1
2 Designations that are shown to be clearly unjustified or that have been made for an
3
improper purpose (e.g., to unnecessarily encumber the case development process
4
or to impose unnecessary expenses and burdens on other parties) may expose the
5
6 Designating Party to sanctions.
7
If it comes to a Designating Party’s attention that information or items that it
8
designated for protection do not qualify for protection, that Designating Party must
9
10 promptly notify all other Parties that it is withdrawing the inapplicable designation.
11
5.2 Manner and Timing of Designations. Except as otherwise provided in
12
this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
13
14 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
15
under this Order must be clearly so designated before the material is disclosed or
16
17 produced.
18 Designation in conformity with this Order requires:
19
(a) for information in documentary form (e.g., paper or electronic
20
21 documents, but excluding transcripts of depositions or other pretrial or trial
22 proceedings), that the Producing Party affix, at a minimum, the legend
23
“CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
24
25 contains protected material. If only a portion or portions of the material on a page
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qualifies for protection, the Producing Party also must clearly identify the
1
2 protected portion(s) (e.g., by making appropriate markings in the margins).
3
A Party or Non-Party that makes original documents available for inspection
4
need not designate them for protection until after the inspecting Party has indicated
5
6 which documents it would like copied and produced. During the inspection and
7
before the designation, all of the material made available for inspection shall be
8
deemed “CONFIDENTIAL.” After the inspecting Party has identified the
9
10 documents it wants copied and produced, the Producing Party must determine
11
which documents, or portions thereof, qualify for protection under this Order.
12
Then, before producing the specified documents, the Producing Party must affix
13
14 the “CONFIDENTIAL legend” to each page that contains Protected Material. If
15
only a portion or portions of the material on a page qualifies for protection, the
16
17 Producing Party also must clearly identify the protected portion(s) (e.g., by making
18 appropriate markings in the margins).
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(b) for testimony given in depositions that the Designating Party
20
21 identify the Disclosure or Discovery Material on the record, before the close of the
22 deposition.
23
(c) for information produced in some form other than documentary
24
25 and for any other tangible items, that the Producing Party affix in a prominent
26 place on the exterior of the container or containers in which the information is
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stored the legend “CONFIDENTIAL.” If only a portion or portions of the
1
2 information warrants protection, the Producing Party, to the extent practicable,
3
shall identify the protected portion(s).
4
5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
5
6 failure to designate qualified information or items does not, standing alone, waive
7
the Designating Party’s right to secure protection under this Order for such
8
material. Upon timely correction of a designation, the Receiving Party must make
9
10 reasonable efforts to assure that the material is treated in accordance with the
11
provisions of this Order.
12
13
14 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
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6.1 Timing of Challenges. Any Party or Non-Party may challenge a
16
17 designation of confidentiality at any time that is consistent with the Court’s
18 Scheduling Order.
19
6.2 Meet and Confer. The Challenging Party shall initiate the dispute
20
21 resolution process under Local Rule 37-1, et seq. Any discovery motion must
22 strictly comply with the procedures set forth in Local Rules 37-1, 37-2, and 37-3.
23
6.3 Burden. The burden of persuasion in any such challenge proceeding
24
25 shall be on the Designating Party. Frivolous challenges, and those made for an
26 improper purpose (e.g., to harass or impose unnecessary expenses and burdens on
27 10
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other parties) may expose the Challenging Party to sanctions. Unless the
1
2 Designating Party has waived or withdrawn the confidentiality designation, all
3
parties shall continue to afford the material in question the level of protection to
4
which it is entitled under the Producing Party’s designation until the Court rules on
5
6 the challenge.
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8
7. ACCESS TO AND USE OF PROTECTED MATERIAL
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10 7.1 Basic Principles. A Receiving Party may use Protected Material that
11
is disclosed or produced by another Party or by a Non-Party in connection with this
12
Action only for prosecuting, defending, or attempting to settle this Action. Such
13
14 Protected Material may be disclosed only to the categories of persons and under
15
the conditions described in this Order. When the Action has been terminated, a
16
17 Receiving Party must comply with the provisions of section 13 below (FINAL
18 DISPOSITION).
19
Protected Material must be stored and maintained by a Receiving Party at a
20
21 location and in a secure manner that ensures that access is limited to the persons
22 authorized under this Order.
23
7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
24
25 otherwise ordered by the Court or permitted in writing by the Designating Party, a
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Receiving Party may disclose any information or item designated
1
2 “CONFIDENTIAL” only to:
3
(a) the Receiving Party’s Outside Counsel of Record in this Action,
4
as well as employees of said Outside Counsel of Record to whom it is reasonably
5
6 necessary to disclose the information for this Action;
7
(b) the officers, directors, and employees (including House Counsel)
8
of the Receiving Party to whom disclosure is reasonably necessary for this Action;
9
10 (c) Experts (as defined in this Order) of the Receiving Party to whom
11
disclosure is reasonably necessary for this Action and who have signed the
12
“Acknowledgment and Agreement to Be Bound” (Exhibit A);
13
14 (d) the Court and its personnel;
15
(e) court reporters and their staff;
16
17 (f) professional jury or trial consultants, mock jurors, and
18 Professional Vendors to whom disclosure is reasonably necessary for this Action
19
and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit
20
21 A);
22 (g) the author or recipient of a document containing the information
23
or a custodian or other person who otherwise possessed or knew the information;
24
25 (h) during their depositions, witnesses, and attorneys for witnesses, in
26 the Action to whom disclosure is reasonably necessary provided: (1) the deposing
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party requests that the witness sign the form attached as Exhibit A hereto; and (2)
1
2 they will not be permitted to keep any confidential information unless they sign the
3
“Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
4
agreed by the Designating Party or ordered by the Court. Pages of transcribed
5
6 deposition testimony or exhibits to depositions that reveal Protected Material may
7
be separately bound by the court reporter and may not be disclosed to anyone
8
except as permitted under this Stipulated Protective Order; and
9
10 (i) any mediator or settlement officer, and their supporting personnel,
11
mutually agreed upon by any of the parties engaged in settlement discussions.
12
13
14 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
15
PRODUCED IN OTHER LITIGATION
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17 If a Party is served with a subpoena or a court order issued in other litigation
18 that compels disclosure of any information or items designated in this Action as
19
“CONFIDENTIAL,” that Party must:
20
21 (a) promptly notify in writing the Designating Party. Such notification shall
22 include a copy of the subpoena or court order;
23
(b) promptly notify in writing the party who caused the subpoena or order to
24
25 issue in the other litigation that some or all of the material covered by the subpoena
26
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or order is subject to this Protective Order. Such notification shall include a copy
1
2 of this Stipulated Protective Order; and
3
(c) cooperate with respect to all reasonable procedures sought to be pursued
4
by the Designating Party whose Protected Material may be affected.
5
6 If the Designating Party timely seeks a protective order, the Party served
7
with the subpoena or court order shall not produce any information designated in
8
this action as “CONFIDENTIAL” before a determination by the court from which
9
10 the 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
14 should be construed as authorizing or encouraging a Receiving Party in this Action
15
to disobey a lawful directive from another court.
16
17
18 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
19
PRODUCED IN THIS LITIGATION
20
21 (a) The terms of this Order are applicable to information produced by a
22 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
23
produced by Non-Parties in connection with this litigation is protected by the
24
25 remedies and relief provided by this Order. Nothing in these provisions should be
26 construed as prohibiting a Non-Party from seeking additional protections.
27 14
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(b) In the event that a Party is required, by a valid discovery request, to
1
2 produce a Non-Party’s confidential information in its possession, and the Party is
3
subject to an agreement with the Non-Party not to produce the Non-Party’s
4
confidential information, then the Party shall:
5
6 (1) promptly notify in writing the Requesting Party and the Non-
7
Party that some or all of the information requested is subject to a confidentiality
8
agreement with a Non-Party;
9
10 (2) promptly provide the Non-Party with a copy of the Stipulated
11
Protective Order in this Action, the relevant discovery request(s), and a reasonably
12
specific description of the information requested; and
13
14 (3) make the information requested available for inspection by the
15
Non-Party, if requested.
16
17 (c) If the Non-Party fails to seek a protective order from this Court within
18 14 days of receiving the notice and accompanying information, the Receiving
19
Party may produce the Non-Party’s confidential information responsive to the
20
21 discovery request. If the Non-Party timely seeks a protective order, the Receiving
22 Party shall not produce any information in its possession or control that is subject
23
to the confidentiality agreement with the Non-Party before a determination by the
24
25 Court. Absent a court order to the contrary, the Non-Party shall bear the burden
26 and expense of seeking protection in this Court of its Protected Material.
27 15
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10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
1
2 If a Receiving Party learns that, by inadvertence or otherwise, it has
3
disclosed Protected Material to any person or in any circumstance not authorized
4
under this Stipulated Protective Order, the Receiving Party must immediately (a)
5
6 notify in writing the Designating Party of the unauthorized disclosures, (b) use its
7
best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform
8
the person or persons to whom unauthorized disclosures were made of all the terms
9
10 of this Order, and (d) request such person or persons to execute the
11
“Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit
12
A.
13
14
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11. INADVERTENT PRODUCTION OF PRIVILEGED OR
16
17 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
21 protection, the obligations of the Receiving Parties are those set forth in Federal
22 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify
23
whatever procedure may be established in an e-discovery order that provides for
24
25 production without prior privilege review. Pursuant to Federal Rule of Evidence
26 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure
27 16
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of a communication or information covered by the attorney-client privilege or
1
2 work product protection, the parties may incorporate their agreement in the
3
stipulated protective order submitted to the Court.
4
5
6 12. MISCELLANEOUS
7
12.1 Right to Further Relief. Nothing in this Order abridges the right of
8
any person to seek its modification by the Court in the future.
9
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
13
14 this Stipulated Protective Order. Similarly, no Party waives any right to object on
15
any ground to use in evidence of any of the material covered by this Protective
16
17 Order.
18 12.3 Filing Protected Material. A Party that seeks to file under seal any
19
Protected Material must comply with Civil Local Rule 79-5. Protected Material
20
21 may only be filed under seal pursuant to a court order authorizing the sealing of the
22 specific Protected Material at issue; good cause must be shown in the request to
23
file under seal. If a Party’s request to file Protected Material under seal is denied
24
25 by the Court, then the Receiving Party may file the information in the public record
26 unless otherwise instructed by the Court.
27 17
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13. FINAL DISPOSITION
1
2 After the final disposition of this Action, within 60 days of a written request
3
by the Designating Party, each Receiving Party must return all Protected Material
4
to the Producing Party or destroy such material. As used in this subdivision, “all
5
6 Protected Material” includes all copies, abstracts, compilations, summaries, and
7
any other format reproducing or capturing any of the Protected Material. Whether
8
the Protected Material is returned or destroyed, the Receiving Party must submit a
9
10 written certification to the Producing Party (and, if not the same person or entity, to
11
the Designating Party) by the 60 day deadline that (1) identifies (by category,
12
where appropriate) all the Protected Material that was returned or destroyed, and
13
14 (2) affirms that the Receiving Party has not retained any copies, abstracts,
15
compilations, summaries or any other format reproducing or capturing any of the
16
17 Protected Material. Notwithstanding this provision, counsel are entitled to retain
18 an archival copy of all pleadings, motion papers, trial, deposition, and hearing
19
transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
20
21 reports, attorney work product, and consultant and expert work product, even if
22 such materials contain Protected Material. Any such archival copies that contain
23
or constitute Protected Material remain subject to this Protective Order as set forth
24
25 in Section 4 (DURATION).
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14. VIOLATION OF ORDER
2 Any violation of this Order may be punished by any and all appropriate
3
measures including, without limitation, contempt proceedings and/or monetary
4
5 sanctions.
6 IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
7
8 Geilfey A Kibaity
9 Dated: October 11, 2024
Jeffrey A. Kiburtz, Esq.
10 PILLSBURY WINTHROP SHAW
11 PITTMAN LLP
Attorneys for Plaintiff 1800 ROSECRANS
12 PARTNERS, LLC
13
Lita Kiratik Plansen
14 |! Dated: October 11, 2024
15 Lisa Kralik Hansen, Esq.
COCHRAN, DAVIS & ASSOCIATES,
16 P.C.
17 Attorneys for Defendants CERTAIN
UNDERWRITERS AT LLOYD'S,
18 LONDON, PIONEER SYNDICATE 1980,
19 and PIONEER SPECIAL RISK
20 INSURANCE SERVICES, INC.
21
FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
23
24 Dated: 10/15/24 \ otk ( ,
25 HON.\4. JOEL RICHLIN
26 United States Magistrate Judge
7 19
28 STIPULATED PROTECTIVE ORDE
Case No. 2:24-cv-04803-RGK-AJ
EXHIBIT A
1
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3
I, _____________________________ [full name], of
4
__________________________________________________ [full address],
5
6 declare under penalty of perjury that I have read in its entirety and understand the
7
Stipulated Protective Order that was issued by the United States District Court for
8
the Central District of California on ____________ [date] in the case of 1800
9
10 Rosecrans Partners, LLC v. Certain Underwriters at Lloyd’s, London, et al.,
11
USDC-Central District of California Case No. 2:24-cv-04803-RGK (AJR). I agree
12
to comply with and to be bound by all the terms of this Stipulated Protective Order
13
14 and I understand and acknowledge that failure to so comply could expose me to
15
sanctions and punishment in the nature of contempt. I solemnly promise that I will
16
17 not disclose in any manner any information or item that is subject to this Stipulated
18 Protective Order to any person or entity except in strict compliance with the
19
provisions of this Order.
20
21 I further agree to submit to the jurisdiction of the United States District
22 Court for the Central District of California for the purpose of enforcing the terms
23
of this Stipulated Protective Order, even if such enforcement proceedings occur
24
25 after termination of this action. I hereby appoint __________________________
26 [full name] of _______________________________________ [full address and
27 20
___________________________________________________________________________________________
telephone number] as my California agent for service of process in connection
1
2 with this action or any proceedings related to enforcement of this Stipulated
3
Protective Order.
4
5
6 Date: ______________________________________
7
City and State where signed: _________________________________
8
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10 Printed name: _______________________________
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Signature: __________________________________
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