Opinion

1 BZERDDR@ICdk Mml. aDwAgLroIuSpA.cYo m(C A SBN 805744)

2 ZMD@dkmlawgroup.com

DKM Law Group, LLP

3 50 California Street, Suite 1500

San Francisco, CA 94111

4 Telephone: (415) 421-1100

Facsimile: (415) 842-0095

5

Attorneys for Defendant,

6 HOMESITE INSURANCE COMPANY

OF THE MIDWEST

7

8 UNITED STATES DISTRICT COURT

9 CENTRAL DISTRICT OF CALIFORNIA

10 WESTERN DIVISION

11

CONNOR MORGAN HUFF, an

12 individual, WILLIAM HUFF, an

individual Case No. 2:25-cv-08645-FLA-AYP

13

Plaintiff, STIPULATED PROTECTIVE

14 v. ORDER

15 HOMESITE INSURANCE

[WITH COURT MODIFICATIONS]

COMPANY OF THE MIDWEST a

16 foreign corporation; and DOES 1-10,

inclusive

17 Defendant.

18

19 1. GENERAL

20 1.1 Purposes and Limitations. Discovery in this action is likely to involve

21 production of confidential, proprietary, or private information for which special

22 protection from public disclosure and from use for any purpose other than prosecuting

23 this litigation may be warranted. Accordingly, the parties hereby stipulate to and

24 petition the Court to enter the following Stipulated Protective Order. The parties

25 acknowledge that this Order does not confer blanket protections on all disclosures or

26 responses to discovery and that the protection it affords from public disclosure and

27 use extends only to the limited information or items that are entitled to confidential

28 treatment under the applicable legal principles. The parties further acknowledge, as

1 set forth in Section 12.3, below, that this Stipulated Protective Order does not entitle

2 them to file confidential information under seal; Civil Local Rule 79-5 sets forth the

3 procedures that must be followed and the standards that will be applied when a party

4 seeks permission from the court to file material under seal.

5 1.2 Good Cause Statement. This Action arises from allegations related to an

6 insurance policy issued by Defendant to Plaintiffs. As such, this Action is likely to

7 involve confidential financial information related to Plaintiff’s policy as well as

8 internal confidential financial related to Defendant’s business for which special

9 protection from public disclosure and from use for any purpose other than prosecution

10 of this action is warranted. Such confidential and proprietary materials and

11 information involving confidential financial information related to Plaintiff’s policy

12 as well as internal confidential financial related to Defendant’s business would

13 otherwise generally be unavailable to the public, or which may be privileged or

14 otherwise protected from disclosure under state or federal statutes, court rules, case

15 decisions, or common law. Accordingly, to expedite the flow of information, to

16 facilitate the prompt resolution of disputes over confidentiality of discovery materials,

17 to adequately protect information the parties are entitled to keep confidential, to

18 ensure that the parties are permitted reasonable necessary uses of such material in

19 preparation for and in the conduct of trial, to address their handling at the end of the

20 litigation, and serve the ends of justice, a protective order for such information is

21 justified in this matter. It is the intent of the parties that information will not be

22 designated as confidential for tactical reasons and that nothing be so designated

23 without a good faith belief that it has been maintained in a confidential, non-public

24 manner, and there is good cause why it should not be part of the public record of this

25 case.

26 2. DEFINITIONS

27 2.1 Action: Connor Morgan Huff et. al. v. Homesite Insurance Company of

28 the Midwest, Case No.: 2:25-cv-08645-FLA-AYP.

1 2.2 Challenging Party: a Party or Non-Party that challenges the designation

2 of information or items under this Order.

3 2.3 “CONFIDENTIAL” Information or Items: information (regardless of

4 how it is generated, stored or maintained) or tangible things that qualify for protection

5 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good

6 Cause Statement.

7 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their

8 support staff).

9 2.5 Designating Party: a Party or Non-Party that designates information or

10 items that it produces in disclosures or in responses to discovery as

11 “CONFIDENTIAL.”

12 2.6 Disclosure or Discovery Material: all items or information, regardless

13 of the medium or manner in which it is generated, stored, or maintained (including,

14 among other things, testimony, transcripts, and tangible things), that are produced or

15 generated in disclosures or responses to discovery in this matter.

16 2.7 Expert: a person with specialized knowledge or experience in a matter

17 pertinent to the litigation who has been retained by a Party or its counsel to serve as

18 an expert witness or as a consultant in this Action.

19 2.8 House Counsel: attorneys who are employees of a party to this Action.

20 House Counsel does not include Outside Counsel of Record or any other outside

21 counsel.

22 2.9 Non-Party: any natural person, partnership, corporation, association, or

23 other legal entity not named as a Party to this action.

24 2.10 Outside Counsel of Record: attorneys who are not employees of a party

25 to this Action but are retained to represent or advise a party to this Action and have

26 appeared in this Action on behalf of that party or are affiliated with a law firm that

27 has appeared on behalf of that party, including support staff.

28 2.11 Party: any party to this Action, including all of its officers, directors,

1 employees, consultants, retained experts, and Outside Counsel of Record (and their

2 support staffs).

3 2.12 Producing Party: a Party or Non-Party that produces Disclosure or

4 Discovery Material in this Action.

5 2.13 Professional Vendors: persons or entities that provide litigation support

6 services (e.g., photocopying, videotaping, translating, preparing exhibits or

7 demonstrations, and organizing, storing, or retrieving data in any form or medium)

8 and their employees and subcontractors.

9 2.14 Protected Material: any Disclosure or Discovery Material that is

10 designated as “CONFIDENTIAL.”

11 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material

12 from a Producing Party.

13 3. SCOPE

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 extracted

16 from Protected Material; (2) all copies, excerpts, summaries, or compilations of

17 Protected Material; and (3) any testimony, conversations, or presentations by Parties

18 or their Counsel that might reveal Protected Material.

19 Any use of Protected Material at trial shall be governed by the orders of the trial judge.

20 This Order does not govern the use of Protected Material at trial.

21

22 4. DURATION

23 Once a case proceeds to trial, all of the court-filed information to be introduced

24 that was previously designated as confidential or maintained pursuant to this

25 protective order becomes public and will be presumptively available to all members

26 of the public, including the press, unless compelling reasons supported by specific

27 factual findings to proceed otherwise are made to the trial judge in advance of the

28 trial. See Kamakana v. City and Cty. of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir.

1 2006) (distinguishing “good cause” showing for sealing documents produced in

2 discovery from “compelling reasons” standard when merits-related documents are

3 part of court record). Accordingly, the terms of this protective order do not extend

4 beyond the commencement of the trial.

5 After final disposition of this litigation, the confidentiality obligations imposed

6 by this Order shall remain in effect until a Designating Party agrees otherwise in

7 writing or a court order otherwise directs. Final disposition shall be deemed to be the

8 later of (1) dismissal of all claims and defenses in this Action, with or without

9 prejudice; and (2) final judgment herein after the completion and exhaustion of all

10 appeals, rehearing’s, remands, trials, or reviews of this Action, including the time

11 limits for filing any motions or applications for extension of time pursuant to

12 applicable law.

13

14 5. DESIGNATING PROTECTED MATERIAL

15 5.1 Exercise of Restraint and Care in Designating Material for Protection.

16 Each Party or Non-Party that designates information or items for protection under this

17 Order must take care to limit any such designation to specific material that qualifies

18 under the appropriate standards. The Designating Party must designate for protection

19 only those parts of material, documents, items, or oral or written communications that

20 qualify so that other portions of the material, documents, items, or communications

21 for which protection is not warranted are not swept unjustifiably within the ambit of

22 this Order.

23 Mass, indiscriminate, or routinized designations are prohibited. Designations

24 that are shown to be clearly unjustified or that have been made for an improper

25 purpose (e.g., to unnecessarily encumber the case development process or to impose

26 unnecessary expenses and burdens on other parties) may expose the Designating Party

27 to sanctions.

28

1 If it comes to a Designating Party’s attention that information or items that it

2 designated for protection do not qualify for protection, that Designating Party must

3 promptly notify all other Parties that it is withdrawing the inapplicable designation.

4 5.2 Manner and Timing of Designations. Except as otherwise provided in

5 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise

6 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection

7 under this Order must be clearly so designated before the material is disclosed or

8 produced.

9 Designation in conformity with this Order requires:

10 (a) for information in documentary form (e.g., paper or electronic

11 documents, but excluding transcripts of depositions or other pretrial or trial

12 proceedings), that the Producing Party affix, at a minimum, the legend

13 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that

14 contains protected material. If only a portion or portions of the material on a page

15 qualifies for protection, the Producing Party also must clearly identify the protected

16 portion(s) (e.g., by making appropriate markings in the margins).

17 A Party or Non-Party that makes original documents available for inspection

18 need not designate them for protection until after the inspecting Party has indicated

19 which documents it would like copied and produced. During the inspection and

20 before the designation, all of the material made available for inspection shall be

21 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents

22 it wants copied and produced, the Producing Party must determine which documents,

23 or portions thereof, qualify for protection under this Order. Then, before producing

24 the specified documents, the Producing Party must affix the “CONFIDENTIAL

25 legend” to each page that contains Protected Material. If only a portion or portions

26 of the material on a page qualifies for protection, the Producing Party also must clearly

27 identify the protected portion(s) (e.g., by making appropriate markings in the

28 margins).

1 (b) for testimony given in depositions that the Designating Party

2 identify the Disclosure or Discovery Material on the record, before the close of the

3 deposition all protected testimony. When it is impractical to identify separately each

4 portion of testimony that is entitled to protection or it appears that substantial portions

5 of the testimony may qualify for protection, the Designating Party may invoke on the

6 record (before the deposition, hearing, or other proceeding is concluded) a right to

7 have up to 30 days from the date the transcript is received by counsel for the

8 Designating Party to identify the specific portions of the testimony as to which

9 protection is sought and to specify the level of protection being asserted. Only those

10 portions of the testimony that are appropriately designated for protection within 30

11 days from the date the transcript is received from counsel for the Designating Party

12 shall be covered by the provisions of this Stipulated Protective Order. Alternatively,

13 a Designating Party may specify, at the deposition, hearing, or other proceeding or

14 up to 30 days from the date the transcript is received by counsel for the Designating

15 Party if that period is properly invoked, that the entire transcript shall be treated as

16 “CONFIDENTIAL.”

17 Parties shall give the other parties notice if they reasonably expect a deposition

18 to include Protected Materials so that the other parties can ensure that only authorized

19 individuals who have signed the “Acknowledgement and Agreement to Be Bound”

20 (Exhibit A) are present at those proceedings. The use of a document as an exhibit at

21 a deposition shall not in any way affect its designation as “CONFIDENTIAL.”

22 (c) for information produced in some form other than documentary and

23 for any other tangible items, that the Producing Party affix in a prominent place on

24 the exterior of the container or containers in which the information is stored the legend

25 “CONFIDENTIAL.” If only a portion or portions of the information warrants

26 protection, the Producing Party, to the extent practicable, shall identify the protected

27 portion(s).

28

1 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent

2 failure to designate qualified information or items does not, standing alone, waive the

3 Designating Party’s right to secure protection under this Order for such material.

4 Upon timely correction of a designation, the Receiving Party must make reasonable

5 efforts to assure that the material is treated in accordance with the provisions of this

6 Order.

7 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

8 6.1 Timing of Challenges. Any Party or Non-Party may challenge a

9 designation of confidentiality at any time that is consistent with the Court’s

10 Scheduling Order.

11 6.2 Meet and Confer. The Challenging Party shall initiate the dispute

12 resolution process under Local Rule 37-1, et seq. Any discovery motion must strictly

13 comply with the procedures set forth in Local Rules 37-1, 37-2, and 37-3.

14 6.3 Burden. The burden of persuasion in any such challenge proceeding

15 shall be on the Designating Party. Frivolous challenges, and those made for an

16 improper purpose (e.g., to harass or impose unnecessary expenses and burdens on

17 other parties) may expose the Challenging Party to sanctions. Unless the Designating

18 Party has waived or withdrawn the confidentiality designation, all parties shall

19 continue to afford the material in question the level of protection to which it is entitled

20 under the Producing Party’s designation until the Court rules on the challenge.

21 7. ACCESS TO AND USE OF PROTECTED MATERIAL

22 7.1 Basic Principles. A Receiving Party may use Protected Material that is

23 disclosed or produced by another Party or by a Non-Party in connection with this

24 Action only for prosecuting, defending, or attempting to settle this Action. Such

25 Protected Material may be disclosed only to the categories of persons and under the

26 conditions described in this Order. When the Action has been terminated, a Receiving

27 Party must comply with the provisions of section 13 below (FINAL DISPOSITION).

28

1 Protected Material must be stored and maintained by a Receiving Party at a

2 location and in a secure manner that ensures that access is limited to the persons

3 authorized under this Order.

4 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless

5 otherwise ordered by the Court or permitted in writing by the Designating Party, a

6 Receiving Party may disclose any information or item designated

7 “CONFIDENTIAL” only to:

8 (a) the Receiving Party’s Outside Counsel of Record in this Action, as

9 well as employees of said Outside Counsel of Record to whom it is reasonably

10 necessary to disclose the information for this Action;

11 (b) the officers, directors, and employees (including House Counsel) of

12 the Receiving Party to whom disclosure is reasonably necessary for this Action;

13 (c) Experts (as defined in this Order) of the Receiving Party to whom

14 disclosure is reasonably necessary for this Action and who have signed the

15 “Acknowledgment and Agreement to Be Bound” (Exhibit A);

16 (d) the Court and its personnel;

17 (e) court reporters and their staff;

18 (f) professional jury or trial consultants, mock jurors, and Professional

19 Vendors to whom disclosure is reasonably necessary for this Action and who have

20 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);

21 (g) the author or recipient of a document containing the information or

22 a custodian or other person who otherwise possessed or knew the information;

23 (h) during their depositions, witnesses, and attorneys for witnesses, in

24 the Action to whom disclosure is reasonably necessary provided:(1) the deposing

25 party requests that the witness sign the form attached as Exhibit A hereto; and (2) they

26 will not be permitted to keep any confidential information unless they sign the

27 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise

28 agreed by the Designating Party or ordered by the Court. Pages of transcribed

1 deposition testimony or exhibits to depositions that reveal Protected Material may be

2 separately bound by the court reporter and may not be disclosed to anyone except as

3 permitted under this Stipulated Protective Order; and

4 (i) any mediator or settlement officer, and their supporting personnel,

5 mutually agreed upon by any of the parties engaged in settlement discussions.

6 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED

7 PRODUCED IN OTHER LITIGATION

8 If a Party is served with a subpoena or a court order issued in other litigation

9 that compels disclosure of any information or items designated in this Action as

10 “CONFIDENTIAL,” that Party must:

11 (a) promptly notify in writing the Designating Party. Such notification shall

12 include a copy of the subpoena or court order;

13 (b) promptly notify in writing the party who caused the subpoena or order to

14 issue in the other litigation that some or all of the material covered by the subpoena

15 or order is subject to this Protective Order. Such notification shall include a copy of

16 this Stipulated Protective Order; and

17 (c) cooperate with respect to all reasonable procedures sought to be pursued

18 by the Designating Party whose Protected Material may be affected.

19 If the Designating Party timely seeks a protective order, the Party served with

20 the subpoena or court order shall not produce any information designated in this action

21 as “CONFIDENTIAL” before a determination by the court from which the subpoena

22 or order issued, unless the Party has obtained the Designating Party’s permission. The

23 Designating Party shall bear the burden and expense of seeking protection in that court

24 of its confidential material and nothing in these provisions should be construed as

25 authorizing or encouraging a Receiving Party in this Action to disobey a lawful

26 directive from another court.

27 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

28 PRODUCED IN THIS LITIGATION

1 (a) The terms of this Order are applicable to information produced by a Non-

2 Party in this Action and designated as “CONFIDENTIAL.” Such information

3 produced by Non-Parties in connection with this litigation is protected by the

4 remedies and relief provided by this Order. Nothing in these provisions should be

5 construed as prohibiting a Non-Party from seeking additional protections.

6 (b) In the event that a Party is required, by a valid discovery request, to produce

7 a Non-Party’s confidential information in its possession, and the Party is subject to an

8 agreement with the Non-Party not to produce the Non-Party’s confidential

9 information, then the Party shall:

10 (1) promptly notify in writing the Requesting Party and the Non-Party

11 that some or all of the information requested is subject to a confidentiality agreement

12 with a Non-Party;

13 (2) promptly provide the Non-Party with a copy of the Stipulated

14 Protective Order in this Action, the relevant discovery request(s), and a reasonably

15 specific description of the information requested; and

16 (3) make the information requested available for inspection by the Non-

17 Party, if requested.

18 (c) If the Non-Party fails to seek a protective order from this Court within 14

19 days of receiving the notice and accompanying information, the Receiving Party may

20 produce the Non-Party’s confidential information responsive to the discovery request.

21 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce

22 any information in its possession or control that is subject to the confidentiality

23 agreement with the Non-Party before a determination by the Court. Absent a court

24 order to the contrary, the Non-Party shall bear the burden and expense of seeking

25 protection in this Court of its Protected Material.

26 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

27 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed

28 Protected Material to any person or in any circumstance not authorized under this

1 Stipulated Protective Order, the Receiving Party must immediately (a) notify in

2 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts

3 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or

4 persons to whom unauthorized disclosures were made of all the terms of this Order,

5 and (d) request such person or persons to execute the “Acknowledgment and

6 Agreement to Be Bound” that is attached hereto as Exhibit A.

7 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

8 PROTECTED MATERIAL

9 When a Producing Party gives notice to Receiving Parties that certain

10 inadvertently produced material is subject to a claim of privilege or other protection,

11 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil

12 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure

13 may be established in an e-discovery order that provides for production without prior

14 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the

15 parties reach an agreement on the effect of disclosure of a communication or

16 information covered by the attorney-client privilege or work product protection, the

17 parties may incorporate their agreement in the stipulated protective order submitted

18 to the Court.

19 12. MISCELLANEOUS

20 12.1 Right to Further Relief. Nothing in this Order abridges the right of any

21 person to seek its modification by the Court in the future.

22 12.2 Right to Assert Other Objections. By stipulating to the entry of this

23 Protective Order, no Party waives any right it otherwise would have to object to

24 disclosing or producing any information or item on any ground not addressed in this

25 Stipulated Protective Order. Similarly, no Party waives any right to object on any

26 ground to use in evidence of any of the material covered by this Protective Order.

27 12.3 Filing Protected Material. A Party that seeks to file under seal any

28 Protected Material must comply with Civil Local Rule 79-5. Protected Material may

1 only be filed under seal pursuant to a court order authorizing the sealing of the specific

2 Protected Material at issue; good cause must be shown in the request to file under

3 seal. If a Party’s request to file Protected Material under seal is denied by the Court,

4 then the Receiving Party may file the information in the public record unless

5 otherwise instructed by the Court.

6 13. FINAL DISPOSITION

7 After the final disposition of this Action, as defined in paragraph 4, within 60

8 days of a written request by the Designating Party, each Receiving Party must return

9 all Protected Material to the Producing Party or destroy such material. As used in this

10 subdivision, “all Protected Material” includes all copies, abstracts, compilations,

11 summaries, and any other format reproducing or capturing any of the Protected

12 Material. Whether the Protected Material is returned or destroyed, the Receiving

13 Party must submit a written certification to the Producing Party (and, if not the same

14 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies

15 (by category, where appropriate) all the Protected Material that was returned or

16 destroyed, and (2) affirms that the Receiving Party has not retained any copies,

17 abstracts, compilations, summaries or any other format reproducing or capturing any

18 of the Protected Material. Notwithstanding this provision, counsel are entitled to

19 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing

20 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert

21 reports, attorney work product, and consultant and expert work product, even if such

22 materials contain Protected Material. Any such archival copies that contain or

23 constitute Protected Material remain subject to this Protective Order as set forth in

24 Section 4 (DURATION).

25 14. VIOLATION OF ORDER

26 Any violation of this Order may be punished by any and all appropriate

27 measures including, without limitation, contempt proceedings and/or monetary

28 sanctions.

1 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

2 || DATED: 03/30/2026 CASTLE LEGAL GROUP, APC

3

4

5

JAMES CASTLE

6 PETER SINDHUPHAK1

7 for Plaintiff(s)

CONNOR MORGAN HUFF and WILLIAM

8 HUFF

9

10 || DATED: 03/30/2026 DKM LAW GROUP, LLP

11

12

13

BRIAN R. DAVIS

14 ZEDRIC M. DALISAY

15 Attorneys for Defendant

HOMESITE INSURANCE COMPANY

16 OF THE MIDWEST

17

18

19 ORDER

20

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

21

ee

23 || DATED: April 20, 2026

24 Honorable Anna Y. Park

United States Magistrate Judge

25

26

27 || 1 Pursuant to Local Rules 5-4.3.4 (a)(2)(i), filer hereby attests that all

28 signatories listed, and on whose behalf the filing is submitted, concur in the

filing’s content and have authorized this filing.

14

1 EXHIBIT A

2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3

4 I, _____________________________ [full name], of _________________

5 [full address], declare under penalty of perjury that I have read in its entirety and

6 understand the Stipulated Protective Order that was issued by the United States

7 District Court for the Central District of California on ____________ [date] in the

8 case of ___________ [insert case name and number]. I agree to comply with and

9 to be bound by all the terms of this Stipulated Protective Order and I understand and

10 acknowledge that failure to so comply could expose me to sanctions and punishment

11 in the nature of contempt. I solemnly promise that I will not disclose in any manner

12 any information or item that is subject to this Stipulated Protective Order to any

13 person or entity except in strict compliance with the provisions of this Order.

14 I further agree to submit to the jurisdiction of the United States District Court

15 for the Central District of California for the purpose of enforcing the terms of this

16 Stipulated Protective Order, even if such enforcement proceedings occur after

17 termination of this action. I hereby appoint __________________________ [full

18 name] of _______________________________________ [full address and

19 telephone number] as my California agent for service of process in connection with

20 this action or any proceedings related to enforcement of this Stipulated Protective

21 Order.

22 Date: ______________________________________

23 City and State where signed: _________________________________

24

25 Printed name: _______________________________

26

27 Signature: __________________________________

28