even stipulated 21 22 protective orders require good cause showing
How later courts described this case
- even stipulated 21 22 protective orders require good cause showing
Written by the judges who cited it.
The opinion
1
2
3
4
5
6
7
8
IN THE UNITED STATES DISTRICT COURT
9
FOR THE CENTRAL DISTRICT OF CALIFORNIA – WESTERN
10
DIVISION
11
12 JERIE PETROSIAN, as Trustee of the ) Case No.: 2:24-cv-06963-FLA-SSC
PETROSIAN TRUST; JKP )
13 APARTMENTS, ) STIPULATED PROTECTIVE
)
14 ) ORDER1
Plaintiffs, )
15 )
v. )
16 )
STATE NATIONAL INSURANCE )
17 COMPANY; and DOES 1 through )
10, inclusive, )
18 )
Defendants. )
19 )
)
20 )
)
21 )
AND RELATED COUNTERCLAIMS.
)
22 )
/ / /
23
24
25
26
27
1 This Stipulated Protective Order is substantially based on the model
protective order provided under Magistrate Judge Stephanie S.
1 1. INTRODUCTION
2 1.1 Purposes and Limitations. Discovery in this action is likely to
3
involve production of confidential, proprietary, or private information for
4
which special protection from public disclosure and from use for any
5
6 purpose other than prosecuting this litigation may be warranted.
7
Accordingly, the parties hereby stipulate to and petition the court to
8
9 enter the following Stipulated Protective Order. The parties
10
acknowledge that this Order does not confer blanket protections on all
11
disclosures or responses to discovery and that the protection it affords
12
13 from public disclosure and use extends only to the limited information or
14
items that are entitled to confidential treatment under the applicable
15
16 legal principles.
17
1.2 Good Cause Statement.
18
This action is likely to involve material that at least one party
19
20 contends qualifies as trade secrets, confidential, financial, proprietary
21
and/or commercially sensitive business information for which special
22
23 protection from public disclosure and from use for any purpose other
24
than prosecution of this action is warranted, possibly including
25
insurance underwriting manuals and guidelines that may apply to the
26
27 insurance policies at issue in this lawsuit and financial information of
1 the parties, which is not available to the general public for which the
2
responding party seeks to maintain the confidentiality of such financial
3
information. Such confidential and proprietary materials and
4
5 information consist of, among other things, confidential business or
6
financial information, information regarding confidential business
7
8 practices, or other confidential research, development, or commercial
9
information (including information implicating privacy rights of third
10
parties), information otherwise generally unavailable to the public, or
11
12 which may be privileged or otherwise protected from disclosure under
13
state or federal statutes, court rules, case decisions, or common law.
14
15 Accordingly, to expedite the flow of information, to facilitate the prompt
16
resolution of disputes over confidentiality of discovery materials, to
17
adequately protect information the parties are entitled to keep
18
19 confidential, to ensure that the parties are permitted reasonable
20
necessary uses of such material in preparation for and in the conduct of
21
22 trial, to address their handling at the end of the litigation, and serve the
23
ends of justice, a protective order for such information is justified in this
24
matter. It is the intent of the parties that information will not be
25
26 designated as confidential for tactical reasons and that nothing be so
27
designated without a good faith belief that it has been maintained in a
1 confidential, non-public manner, and there is good cause why it should
2
not be part of the public record of this case.
3
1.3 Acknowledgment of Procedure for Filing Under Seal. The
4
5 parties further acknowledge, as set forth in Section 12.3, below, that this
6
Stipulated Protective Order does not entitle them to file confidential
7
8 information under seal; Local Rule 79-5 sets forth the procedures that
9
must be followed and the standards that will be applied when a party
10
seeks permission from the court to file material under seal.
11
12 There is a strong presumption that the public has a right of access
13
to judicial proceedings and records in civil cases. In connection with
14
15 non-dispositive motions, good cause must be shown to support a filing
16
under seal. See Kamakana v. City and Cnty. of Honolulu, 447 F.3d
17
1172, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd v. Gen. Motors
18
19 Corp., 307 F.3d 1206, 1210–11 (9th Cir. 2002), Makar-Welbon v. Sony
20
Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated
21
22 protective orders require good cause showing), and a specific showing of
23
good cause or compelling reasons with proper evidentiary support and
24
legal justification, must be made with respect to Protected Material that
25
26 a party seeks to file under seal. The parties’ mere designation of
27
Disclosure or Discovery Material as CONFIDENTIAL does not—
1 without the submission of competent evidence by declaration,
2
establishing that the material sought to be filed under seal qualifies as
3
confidential, privileged, or otherwise protectable—constitute good cause.
4
5 Further, if a party requests sealing related to a dispositive motion
6
or trial, then compelling reasons, not only good cause, for the sealing
7
8 must be shown, and the relief sought shall be narrowly tailored to serve
9
the specific interest to be protected. See Pintos v. Pac. Creditors Ass’n,
10
605 F.3d 665, 677–79 (9th Cir. 2010). For each item or type of
11
12 information, document, or thing sought to be filed or introduced under
13
seal in connection with a dispositive motion or trial, the party seeking
14
15 protection must articulate compelling reasons, supported by specific
16
facts and legal justification, for the requested sealing order. Again,
17
competent evidence supporting the application to file documents under
18
19 seal must be provided by declaration.
20
Any document that is not confidential, privileged, or otherwise
21
22 protectable in its entirety will not be filed under seal if the confidential
23
portions can be redacted. If documents can be redacted, then a redacted
24
version for public viewing, omitting only the confidential, privileged, or
25
26 otherwise protectable portions of the document, shall be filed. Any
27
application that seeks to file documents under seal in their entirety
1 should include an explanation of why redaction is not feasible.
2
2. DEFINITIONS
3
2.1 Action: Jerie Petrosian, as Trustee of the Petrosian Trust, and
4
5 JKP Apartments v. State National Insurance Company, et al.
6
2.2 Challenging Party: a Party or Non-Party that challenges the
7
8 designation of information or items under this Order.
9
2.3 “CONFIDENTIAL” Information or Items: information
10
(regardless of how it is generated, stored or maintained) or tangible
11
12 things that qualify for protection under Rule 26(c) of the Federal Rules of
13
Civil Procedure, and as specified above in the Good Cause Statement.
14
15 2.4 Counsel: Outside Counsel of Record and House Counsel (as
16
well as their support staff).
17
2.5 Designating Party: a Party or Non-Party that designates
18
19 information or items that it produces in disclosures or in responses to
20
discovery as “CONFIDENTIAL.”
21
22 2.6 Disclosure or Discovery Material: all items or information,
23
regardless of the medium or manner in which it is generated, stored, or
24
maintained (including, among other things, testimony, transcripts, and
25
26 tangible things), that are produced or generated in disclosures or
27
responses to discovery in this matter.
1 2.7 Expert: a person with specialized knowledge or experience in
2
a matter pertinent to the litigation who has been retained by a Party or
3
its counsel to serve as an expert witness or as a consultant in this Action.
4
5 2.8 Final Disposition: the later of (1) dismissal of all claims and
6
defenses in this Action, with or without prejudice; and (2) final judgment
7
8 herein after the completion and exhaustion of all appeals, rehearings,
9
remands, trials, or reviews of this Action, including the time limits for
10
filing any motions or applications for extension of time pursuant to
11
12 applicable law.
13
2.9 In-House Counsel: attorneys who are employees of a party to
14
15 this Action. In-House Counsel does not include Outside Counsel of
16
Record or any other outside counsel.
17
2.10 Non-Party: any natural person, partnership, corporation,
18
19 association, or other legal entity not named as a Party to this action.
20
2.11 Outside Counsel of Record: attorneys who are not employees
21
22 of a party to this Action but are retained to represent or advise a party to
23
this Action and have appeared in this Action on behalf of that party or
24
are affiliated with a law firm which has appeared on behalf of that party,
25
26 and includes support staff.
27
///
1 2.12 Party: any party to this Action, including all of their officers,
2
directors, employees, consultants, retained experts, claims counsel, In-
3
House Counsel, and Outside Counsel of Record (and their support staffs).
4
5 2.13 Producing Party: a Party or Non-Party that produces
6
Disclosure or Discovery Material in this Action.
7
8 2.14 Professional Vendors: persons or entities that provide
9
litigation- support services (e.g., photocopying, videotaping, translating,
10
preparing exhibits or demonstrations, and organizing, storing, or
11
12 retrieving data in any form or medium) and their employees and
13
subcontractors.
14
15 2.15 Protected Material: any Disclosure or Discovery Material that
16
is designated as “CONFIDENTIAL.”
17
2.16 Receiving Party: a Party that receives Disclosure or Discovery
18
19 Material from a Producing Party.
20
3. SCOPE
21
22 The protections conferred by this Stipulation and Order cover not
23
only Protected Material (as defined above), but also (1) any information
24
copied or extracted from Protected Material; (2) all copies, excerpts,
25
26 summaries, or compilations of Protected Material; and (3) any
27
testimony, conversations, or presentations by Parties or their Counsel
1 that might reveal Protected Material.
2
Any use of Protected Material at trial shall be governed by the
3
orders of the trial judge. This Stipulated Protective Order does not
4
5 govern the use of Protected Material at trial.
6
4. TRIAL AND DURATION
7
8 The terms of this Stipulated Protective Order apply through Final
9
Disposition of the Action.
10
Once a case proceeds to trial, information that was designated as
11
12 CONFIDENTIAL or maintained pursuant to this Stipulated Protective
13
Order and used or introduced as an exhibit at trial becomes public and
14
15 will be presumptively available to all members of the public, including
16
the press, unless compelling reasons supported by specific factual
17
findings to proceed otherwise are made to the trial judge in advance of
18
19 the trial. See Kamakana, 447 F.3d at 1180–81 (distinguishing “good
20
cause” showing for sealing documents produced in discovery from
21
22 “compelling reasons” standard when merits-related documents are part
23
of court record). Accordingly, for such materials, the terms of this
24
Stipulated Protective Order do not extend beyond the commencement of
25
26 the trial.
27
///
1 Even after Final Disposition of this litigation, the confidentiality
2
obligations imposed by this Stipulated Protective Order shall remain in
3
effect until a Designating Party agrees otherwise in writing or a court
4
5 order otherwise directs.
6
5. DESIGNATING PROTECTED MATERIAL
7
8 5.1 Exercise of Restraint and Care in Designating Material for
9
Protection. Each Party or Non-Party that designates information or
10
items for protection under this Order must take care to limit any such
11
12 designation to specific material that qualifies under the appropriate
13
standards. The Designating Party must designate for protection only
14
15 those parts of material, documents, items, or oral or written
16
communications that qualify so that other portions of the material,
17
documents, items, or communications for which protection is not
18
19 warranted are not swept unjustifiably within the ambit of this Order.
20
Mass, indiscriminate, or routinized designations are prohibited.
21
22 Designations that are shown to be clearly unjustified or that have been
23
made for an improper purpose (e.g., to unnecessarily encumber the case
24
development process or to impose unnecessary expenses and burdens on
25
26 other parties) may expose the Designating Party to sanctions.
27
///
1 If it comes to a Designating Party’s attention that information or
2
items that it designated for protection do not qualify for protection, that
3
Designating Party must promptly notify all other Parties that it is
4
5 withdrawing the inapplicable designation.
6
5.2 Manner and Timing of Designations. Except as otherwise
7
8 provided in this Stipulated Protective Order (see, e.g., second paragraph
9
of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure
10
or Discovery Material that qualifies for protection under this Stipulated
11
12 Protective Order must be clearly so designated before the material is
13
disclosed or produced.
14
15 Designation in conformity with this Stipulated Protective Order
16
requires:
17
(a) for information in documentary form (e.g., paper or electronic
18
19 documents, but excluding transcripts of depositions or other pretrial or
20
trial proceedings), that the Producing Party affix at a minimum, the
21
22 legend “CONFIDENTIAL” to each page that contains protected
23
material. If only a portion or portions of the material on a page
24
qualifies for protection, the Producing Party also must clearly identify
25
26 the protected portion(s) (e.g., by making appropriate markings in the
27
margins).
1 A Party or Non-Party that makes original documents available for
2
inspection need not designate them for protection until after the
3
inspecting Party has indicated which documents it would like copied
4
5 and produced. During the inspection and before the designation, all of
6
the material made available for inspection shall be deemed
7
8 CONFIDENTIAL. After the inspecting Party has identified the
9
documents it wants copied and produced, the Producing Party must
10
determine which documents, or portions thereof, qualify for protection
11
12 under this Stipulated Protective Order. Then, before producing the
13
specified documents, the Producing Party must affix the
14
15 “CONFIDENTIAL” legend to each page that contains Protected
16
Material. If only a portion or portions of the material on a page
17
qualifies for protection, the Producing Party also must clearly identify
18
19 the protected portion(s) (e.g., by making appropriate markings in the
20
margins).
21
22 (b) for testimony given in depositions that the Designating Party
23
identify the Disclosure or Discovery Material on the record, before the
24
close of the deposition all protected testimony.
25
26 (c) for information produced in some form other than
27
documentary and for any other tangible items, that the Producing Party
1 affix in a prominent place on the exterior of the container or containers
2
in which the information is stored the “CONFIDENTIAL” legend. If only
3
a portion or portions of the information warrants protection, the
4
5 Producing Party, to the extent practicable, shall identify the protected
6
portion(s).
7
8 5.3 Inadvertent Failures to Designate. If timely corrected, an
9
inadvertent failure to designate qualified information or items does not,
10
standing alone, waive the Designating Party’s right to secure protection
11
12 under this Order for such material. Upon timely correction of a
13
designation, the Receiving Party must make reasonable efforts to assure
14
15 that the material is treated in accordance with the provisions of this
16
Stipulated Protective Order.
17
6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
18
19 6.1 Timing of Challenges. Any Party or Non-Party may
20
challenge a designation of confidentiality at any time that is consistent
21
22 with the court’s Scheduling Order.
23
6.2 Meet and Confer. The Challenging Party shall initiate the
24
dispute resolution process under Local Rule 37.1 et seq. and with
25
26 Section 2 of Judge Christensen’s Civil Procedures titled “Brief Pre-
27
1 Discovery Motion Conference.”2
2
6.3 The burden of persuasion in any such challenge proceeding
3
shall be on the Designating Party. Frivolous challenges, and those
4
5 made for an improper purpose (e.g., to harass or impose unnecessary
6
expenses and burdens on other parties) may expose the Challenging
7
8 Party to sanctions. Unless the Designating Party has waived or
9
withdrawn the confidentiality designation, all parties shall continue to
10
afford the material in question the level of protection to which it is
11
12 entitled under the Producing Party’s designation until the court rules on
13
the challenge.
14
15 7. ACCESS TO AND USE OF PROTECTED MATERIAL
16
7.1 Basic Principles. A Receiving Party may use Protected
17
Material that is disclosed or produced by another Party or by a Non-
18
19 Party in connection with this Action only for prosecuting, defending, or
20
attempting to settle this Action. Such Protected Material may be
21
22 disclosed only to the categories of persons and under the conditions
23
described in this Order. When the Action reaches a Final Disposition, a
24
Receiving Party must comply with the provisions of section 13 below.
25
26
27
2 Judge Christensen’s Procedures are available at
1 Protected Material must be stored and maintained by a Receiving
2
Party at a location and in a secure manner that ensures that access is
3
limited to the persons authorized under this Stipulated Protective
4
5 Order.
6
7.2 Disclosure of “CONFIDENTIAL” Information or Items.
7
8 Unless otherwise ordered by the court or permitted in writing by the
9
Designating Party, a Receiving Party may disclose any information or
10
item designated “CONFIDENTIAL” only:
11
12 (a) to the Receiving Party’s Outside Counsel of Record in this
13
Action, as well as employees of said Outside Counsel of Record to whom
14
15 it is reasonably necessary to disclose the information for this Action;
16
(b) to the officers, directors, and employees (including House
17
Counsel) of the Receiving Party to whom disclosure is reasonably
18
19 necessary for this Action;
20
(c) to Experts (as defined in this Order) of the Receiving Party to
21
22 whom disclosure is reasonably necessary for this Action and who have
23
signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
24
(d) to the court and its personnel;
25
26 (e) to court reporters and their staff;
27
(f) to professional jury or trial consultants, mock jurors, and
1 Professional Vendors to whom disclosure is reasonably necessary for
2
this Action and who have signed the “Acknowledgment and Agreement
3
to Be Bound” (Exhibit A);
4
5 (g) to the author or recipient of a document containing the
6
information or a custodian or other person who otherwise possessed or
7
8 knew the information;
9
(h) during their depositions, to witnesses, and attorneys for
10
witnesses, in the Action to whom disclosure is reasonably necessary,
11
12 provided: (1) the deposing party requests that the witness sign the
13
“Acknowledgment and Agreement to Be Bound” (Exhibit A); and (2) the
14
15 witness will not be permitted to keep any confidential information
16
unless they sign the “Acknowledgment and Agreement to Be Bound”
17
(Exhibit A), unless otherwise agreed by the Designating Party or
18
19 ordered by the court. Pages of transcribed deposition testimony or
20
exhibits to depositions that reveal Protected Material may be separately
21
22 bound by the court reporter and may not be disclosed to anyone except
23
as permitted under this Stipulated Protective Order; and
24
(i) to any mediator or settlement officer, and their supporting
25
26 personnel, mutually agreed upon by any of the parties engaged in
27
settlement discussions.
1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
2
PRODUCED IN OTHER LITIGATION
3
If a Party is served with a subpoena or a court order issued in
4
5 other litigation that compels disclosure of any information or items
6
designated in this Action as “CONFIDENTIAL,” that Party must:
7
8 (a) promptly notify in writing the Designating Party. Such
9
notification shall include a copy of the subpoena or court order;
10
(b) promptly notify in writing the party who caused the
11
12 subpoena or order to issue in the other litigation that some or all of the
13
material covered by the subpoena or order is subject to this Protective
14
15 Order. Such notification shall include a copy of this Stipulated
16
Protective Order; and
17
(c) cooperate with respect to all reasonable procedures sought to
18
19 be pursued by the Designating Party whose Protected Material may be
20
affected.
21
22 If the Designating Party timely seeks a protective order, the
23
Party served with the subpoena or court order shall not produce any
24
information designated in this action as “CONFIDENTIAL” before a
25
26 determination by the court from which the subpoena or order issued,
27
unless the Party has obtained the Designating Party’s permission. The
1 Designating Party shall bear the burden and expense of seeking
2
protection in that court of its confidential material and nothing in these
3
provisions should be construed as authorizing or encouraging a
4
5 Receiving Party in this Action to disobey a lawful directive from another
6
court.
7
8 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
9
PRODUCED IN THIS LITIGATION
10
9.1 Application. The terms of this Stipulated Protective Order
11
12 are applicable to information produced by a Non-Party in this Action and
13
designated as “CONFIDENTIAL.” Such information produced by Non-
14
15 Parties in connection with this litigation is protected by the remedies
16
and relief provided by this Order. Nothing in these provisions should be
17
construed as prohibiting a Non-Party from seeking additional
18
19 protections.
20
9.2 Notification. In the event that a Party is required, by a valid
21
22 discovery request, to produce a Non-Party’s confidential information in
23
its possession, and the Party is subject to an agreement with the Non-
24
Party not to produce the Non-Party’s confidential information, then the
25
26 Party shall:
27
(a) promptly notify in writing the Requesting Party and the
1 Non-Party that some or all of the information requested is subject to a
2
confidentiality agreement with a Non-Party;
3
(b) make the information requested available for inspection by
4
5 the Non-Party, if requested.
6
9.3 Conditions of Production. If the Non-Party fails to seek a
7
8 protective order from this court within 14 days of receiving the notice
9
and accompanying information, the Receiving Party may produce the
10
Non-Party’s confidential information responsive to the discovery request.
11
12 If the Non-Party timely seeks a protective order, the Receiving Party
13
shall not produce any information in its possession or control that is
14
15 subject to the confidentiality agreement with the Non-Party before a
16
determination by the court. Absent a court order to the contrary, the
17
Non-Party shall bear the burden and expense of seeking protection in
18
19 this court of its Protected Material.
20
10. UNAUTHORIZED DISCLOSURE OF PROTECTED
21
22 MATERIAL
23
If a Receiving Party learns that, by inadvertence or otherwise, it
24
has disclosed Protected Material to any person or in any circumstance
25
26 not authorized under this Stipulated Protective Order, the Receiving
27
Party must immediately (a) notify in writing the Designating Party of
1 the unauthorized disclosures, (b) use its best efforts to retrieve all
2
unauthorized copies of the Protected Material, (c) inform the person or
3
persons to whom unauthorized disclosures were made of all the terms of
4
5 this Order, and (d) request such person or persons to execute the
6
“Acknowledgment and Agreement to Be Bound” (Exhibit A).
7
8 11. INADVERTENT PRODUCTION OF PRIVILEGED OR
9
OTHERWISE PROTECTED MATERIAL
10
When a Producing Party gives notice to Receiving Parties that
11
12 certain inadvertently produced material is subject to a claim of privilege
13
or other protection, the obligations of the Receiving Parties are those set
14
15 forth in Rule 26(b)(5)(B) of the Federal Rules of Civil Procedure. This
16
provision is not intended to modify whatever procedure may be
17
established in an e-discovery order that provides for production without
18
19 prior privilege review. Pursuant to Rules 502(d) and (e) of the Federal
20
Rules of Evidence, insofar as the parties reach an agreement on the
21
22 effect of disclosure of a communication or information covered by the
23
attorney-client privilege or work product protection, the parties may
24
incorporate their agreement in the stipulated protective order
25
26 submitted to the court.
27
///
1 12. MISCELLANEOUS
2
12.1 Right to Further Relief. Nothing in this Stipulated
3
Protective Order abridges the right of any person to seek its
4
5 modification by the court in the future.
6
12.2 Right to Assert Other Objections. By stipulating to the entry
7
8 of this Stipulated Protective Order no Party waives any right it
9
otherwise would have to object to disclosing or producing any
10
information or item on any ground not addressed in this Stipulated
11
12 Protective Order. Similarly, no Party waives any right to object on any
13
ground to use in evidence of any of the material covered by this
14
15 Stipulated Protective Order.
16
12.3 Filing Protected Material. A Party that seeks to file under
17
seal any Protected Material must comply with Local Rule 79-5.
18
19 Protected Material may only be filed under seal pursuant to a court
20
order authorizing the sealing of the specific Protected Material at issue.
21
22 If a Party's request to file Protected Material under seal is denied by the
23
court, then the Receiving Party may file the information in the public
24
record unless otherwise instructed by the court.
25
26 13. FINAL DISPOSITION
27
After the Final Disposition of this Action, as defined in paragraph
1 4, within 60 days of a written request by the Designating Party, each
2
Receiving Party must return all Protected Material to the Producing
3
Party or destroy such material. As used in this subdivision, “all
4
5 Protected Material” includes all copies, abstracts, compilations,
6
summaries, and any other format reproducing or capturing any of the
7
8 Protected Material. Whether the Protected Material is returned or
9
destroyed, the Receiving Party must submit a written certification to
10
the Producing Party (and, if not the same person or entity, to the
11
12 Designating Party) by the 60 day deadline that (1) identifies (by
13
category, where appropriate) all the Protected Material that was
14
15 returned or destroyed and (2) affirms that the Receiving Party has not
16
retained any copies, abstracts, compilations, summaries or any other
17
format reproducing or capturing any of the Protected Material.
18
19 Notwithstanding this provision, Counsel is entitled to retain an archival
20
copy of all pleadings, motion papers, trial, deposition, and hearing
21
22 transcripts, legal memoranda, correspondence, deposition and trial
23
exhibits, expert reports, attorney work product, and consultant and
24
expert work product, even if such materials contain Protected Material.
25
26 Any such archival copies that contain or constitute Protected Material
27
remain subject to this Protective Order as set forth in Section 4.
1 14. VIOLATION
2
Any violation of this Stipulated Protective Order may be punished
3
by any and all appropriate measures including, without limitation,
4
5 contempt proceedings and/or monetary sanctions.
6
7
IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
8
9
DATED: May 6, 2025 /s/ Sharon A. Huerta
10
________________________________
11 Attorneys for Plaintiffs
12
13
DATED: May 6, 2025 /s/ Gregory Kirakosian
14
________________________________
15 Attorneys for Plaintiffs
16
17
/s/ Michelle R. Press
18
DATED: May 6, 2025 ______________________________
19
MICHELLE R. PRESS, ESQ.
20
` ROBERT DENNISON, ESQ.
21 Attorneys for Defendant and
22 Counterclaimant STATE NATIONAL
INSURANCE COMPANY IN
23 CONNECTION WITH POLICY NOS.
24 QJT-SN002553-00, QJT-SN002553-01,
QJT-SN002553-02, AND INTERESTS
25 THEREUNDER
26
27
1 DATED: May 6, 2025 /s/ Lisa Kralik Hansen
3 JOAN E. COCHRAN, ESQ.
4 LISA KRALIK HANSEN, ESQ.
Attorneys for Defendant and
5 Counterclaimant STATE NATIONAL
6 INSURANCE COMPANY FOR
POLICY NO. OPJ-CR000511-01
ONLY AND INTERESTS
8 THEREUNDER
9
10
1]
12
FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
14
DATED: May 12, 2025
15 STEPHANIE 8S. CHRISTENSEN
16 United States Magistrate Judge
17
18
19
20
21
22
23
24
25
26
27
28
1 EXHIBIT A
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
2
3
I,____________________________________________________________
4
________________________________________, declare under penalty of
5
6 perjury that I have read in its entirety and understand the Stipulated
7
Protective Order that was issued by the United States District Court
8
9 for the Central District of California on [date] in the case of Jerie
10
Petrosian, as Trustee of the Petrosian Trust, and JKP Apartments v.
11
State National Insurance Company, et al. Case No.: 2:24-cv-06963-
12
13 FLA-SSC. I agree to comply with and to be bound by all the terms of
14
this Stipulated Protective Order and I understand and acknowledge
15
16 that failure to so comply could expose me to sanctions and punishment
17
in the nature of contempt. I solemnly promise that I will not disclose
18
19 in any manner any information or item that is subject to this
20 Stipulated Protective Order to any person or entity except in strict
21
compliance with the provisions of this Order.
22
23 I further agree to submit to the jurisdiction of the United States
24
District Court for the Central District of California for the purpose of
25
26 enforcing the terms of this Stipulated Protective Order, even if such
27
enforcement proceedings occur after termination of this action. I
1 hereby appoint
2
__________________________________________________________________
3
__________________________________________________________________
4
5 as my California agent for service of process in connection with this
6
action or any proceedings related to enforcement of this Stipulated
7
8 Protective Order.
9
10
Date:___________________________
11
12 City and State where sworn and signed: ___________________________
13
Printed name: ___________________________
14
15 Signature: ___________________________
16
17
18
19
20
21
22
23
24
25
26
27