Opinion

Opinion

Court
District Court, C.D. California
Filed
Jun 3, 2026
Cited by
0 cases

The opinion

1 JD.yEldanw Lar.d S Kchearlfefeyr ((117553669152))

2 Nicholas J. Peterson (287902)

Kerley Schaffer LLP

3 1939 Harrison Street, Ste 900

Oakland, California 94612

4 Telephone: (510) 379-5801

5 Attorneys for Plaintiffs

KATHY MYLES and

6 WILLIE DANIELS

7

SHEPPARD, MULLIN, RICHTER & HAMPTON LLP

8 A Limited Liability Partnership

Including Professional Corporations

9 JENNIFER M. HOFFMAN, Cal. Bar No. 240600

jhoffman@sheppard.com

10 MADALYN A. MACARR, Cal Bar No. 301539

mmacarr@sheppard.com

11 CAROLYN CAREY, Cal Bar No. 356506

ccarey@sheppard.com

12 350 South Grand Avenue, 40th Floor

Los Angeles, California 90071-3460

13 Telephone: 213.620.1780

Facsimile: 213.620.1398

14

Attorneys for Defendant

15 STATE FARM GENERAL

INSURANCE COMPANY

16

17

UNITED STATES DISTRICT COURT

18

CENTRAL DISTRICT OF CALIFORNIA

19

20 KATHY MYLES, an individual, and Case No. 2:26-cv-00452-CAS (MBKx)

21 WILLIE DANIELS, an individual, District Judge: Hon. Christina A. Snyder

22 Plaintiffs, Mag. Judge: Hon. Michael B. Kaufman

23 v. [xPxRxOxxPxOxxSxExDx] PROVISIONAL

STIPULATED PROTECTIVE ORDER

24 STATE FARM GENERAL

INSURANCE COMPANY, an Illinois Hearing:

25 corporation, and DOES 1 through 10, Date: July 8, 2026

Time: 10:00 a.m.

26 Defendants.

27

28

1 1. GENERAL

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 prosecuting this litigation may be warranted. The parties hereby stipulate to and

6 petition the Court to enter the following Provisional Stipulated Protective Order,

7 (hereinafter “Stipulated Protective Order”). The parties acknowledge that this Order

8 does not confer blanket protections on all disclosures or responses to discovery and

9 that the protection it affords from public disclosure and use extends only to the

10 limited information or items that are entitled to confidential treatment under the

11 applicable legal principles. The parties further acknowledge, as set forth in Section

12 12.3, below, that this Stipulated Protective Order does not entitle them to file

13 confidential information under seal; Civil Local Rule 79-5 sets forth the procedures

14 that must be followed and the standards that will be applied when a party seeks

15 permission from the court to file material under seal.

16 1.2 Good Cause Statement. This action is likely to involve trade

17 secrets, customer and pricing lists and other valuable research, development,

18 commercial, financial, technical and/or proprietary information for which special

19 protection from public disclosure and from use for any purpose other than

20 prosecution of this action is warranted. Such confidential and proprietary materials

21 and information consist of, among other things, confidential business or financial

22 information, information regarding confidential business practices, or other

23 confidential research, development, or commercial information (including

24 information implicating privacy rights of third parties), information otherwise

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

26 protected from disclosure under state or federal statutes, court rules, case decisions,

27 or common law. State Farm General Insurance Company (“State Farm”)

28 specifically contends that its internal guidelines and procedures contain proprietary

1 intellectual property developed by State Farm for exclusive use by State Farm’s

2 claims personnel. State Farm contends that these materials are unique to State

3 Farm, and are the product of internal analyses, are not distributed outside of State

4 Farm and are considered by State Farm to be confidential, trade secret protected and

5 proprietary; the dissemination of these materials could cause competitive harm.

6 Accordingly, to expedite the flow of information, to facilitate the prompt resolution

7 of disputes over confidentiality of discovery materials, to adequately protect

8 information the parties are entitled to keep confidential, to ensure that the parties are

9 permitted reasonable necessary uses of such material in preparation for and in the

10 conduct of trial, to address their handling at the end of the litigation, and serve the

11 ends of justice, a protective order for such information is justified in this matter. It

12 is the intent of the parties that information will not be designated as confidential for

13 tactical reasons and that nothing be so designated without a good faith belief that it

14 has been maintained in a confidential, non-public manner, and there is good cause

15 why it should not be part of the public record of this case.

16 2. DEFINITIONS

17 2.1 Action: Myles, et al. v. State Farm General Insurance Company et al.,

18 Case No. 2:26-cv-00452-CAS (MBKx)

19 2.2 Challenging Party: a Party or Non-Party that challenges the

20 designation of information or items under this Order.

21 2.3 “CONFIDENTIAL” Information or Items: information (regardless of

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

23 protection under Federal Rule of Civil Procedure 26(c), and as specified above in

24 the Good Cause Statement.

25 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as

26 their support staff).

27 2.5 Designating Party: a Party or Non-Party that designates information or

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

1 “CONFIDENTIAL” or similar.

2 2.6 Disclosure or Discovery Material: all items or information, regardless

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

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

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

6 2.7 Expert: a person with specialized knowledge or experience in a matter

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

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

9 2.8 House Counsel: attorneys who are employees of a party to this Action.

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

11 counsel.

12 2.9 Non-Party: any natural person, partnership, corporation, association, or

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

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 and

16 have appeared in this Action on behalf of that party or are employees of a law firm

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

18 2.11 Party: any party to this Action, including all of its officers, directors,

19 retained experts, House Counsel and Outside Counsel of Record (and their support

20 staffs).

21 2.12 Producing Party: a Party or Non-Party that produces Disclosure or

22 Discovery Material in this Action.

23 2.13 Professional Vendors: persons or entities that provide litigation

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

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

26 and their employees and subcontractors.

27 2.14 Protected Material: any Disclosure or Discovery Material that is

28 designated as “CONFIDENTIAL” or similar.

1 2.15 Receiving Party: a Party that receives Disclosure or Discovery

2 Material from a Producing Party.

3 3. 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

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

11 4. DURATION

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

13 introduced that was previously designated as confidential or maintained pursuant to

14 this protective order becomes public and will be presumptively available to all

15 members of the public, including the press, unless compelling reasons supported by

16 specific factual findings to proceed otherwise are made to the trial judge in advance

17 of the trial. See Kamakana v. City and Cty. of Honolulu, 447 F.3d 1172, 1180-81

18 (9th Cir. 2006) (distinguishing “good cause” showing for sealing documents

19 produced in discovery from “compelling reasons” standard when merits-related

20 documents are part of court record).

21 Notwithstanding the above, even after final disposition of this litigation, the

22 confidentiality obligations imposed by this Order shall remain in effect until a

23 Designating Party agrees otherwise in writing or a court order otherwise directs.

24 Final disposition shall be deemed to be the later of (1) dismissal of all claims and

25 defenses in this Action, with or without prejudice; and (2) final judgment herein

26 after the completion and exhaustion of all appeals, rehearings, remands, trials, or

27 reviews of this Action, including the time limits for filing any motions or

28 applications for extension of time pursuant to applicable law.

1 5. DESIGNATING PROTECTED MATERIAL

2 5.1 Exercise of Restraint and Care in Designating Material for Protection.

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

4 this Order must take care to limit any such designation to specific material that

5 qualifies under the appropriate standards. The Designating Party must designate for

6 protection only those parts of material, documents, items, or oral or written

7 communications that qualify so that other portions of the material, documents,

8 items, or communications for which protection is not warranted are not swept

9 unjustifiably within the ambit of this Order.

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

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

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

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

14 Party to sanctions.

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

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

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

18 5.2 Manner and Timing of Designations. Except as otherwise provided in

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

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

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

22 produced.

23 Designation in conformity with this Order requires:

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

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

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

27 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”) or similar, to each

28 page that contains protected material (or to the file name for media formats without

1 pages). If only a portion or portions of the material on a page qualifies for

2 protection, the Producing Party also must clearly identify the protected portion(s)

3 (e.g., by making appropriate markings in the margins).

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

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

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

10 documents, or portions thereof, qualify for protection under this Order. Then,

11 before producing the specified documents, the Producing Party must affix the

12 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a

13 portion or portions of the material on a page qualifies for protection, the Producing

14 Party also must clearly identify the protected portion(s) (e.g., by making appropriate

15 markings in the margins).

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

17 either:

18 (i) identify on the record all portions of the testimony that qualify as

19 Protected Material; or

20 (ii) designate the entirety of the testimony at the deposition as

21 “CONFIDENTIAL”. Within 30 days following the receipt of the deposition

22 transcript, counsel for the Designating Party must specify all portions of the

23 testimony that qualify as Protected Material. This does not preclude counsel

24 for the Designating Party from determining that the entirety of the deposition

25 testimony qualifies as Protected Material. In circumstances where portions of

26 the deposition testimony are designated for protection, the transcript pages

27 containing Confidential Information and/or Trade Secret Information may be

28 separately bound by the court reporter, who must affix to the top of each page

1 the legend “CONFIDENTIAL,” as instructed by the Designating Party.

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

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

4 the exterior of the container or containers in which the information is stored the

5 legend “CONFIDENTIAL.” If only a portion or portions of the information

6 warrants protection, the Producing Party, to the extent practicable, shall identify the

7 protected portion(s).

8 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent

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

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

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

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

13 Order.

14 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

15 6.1 Timing of Challenges. Any Party or Non-Party may challenge a

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

17 Scheduling Order.

18 6.2 Meet and Confer. The Challenging Party shall initiate the dispute

19 resolution process under Local Rule 37-1, et seq, as modified by Judge Kaufman’s

20 Procedures. See https://www.cacd.uscourts.gov/honorable-michael-b-kaufman. Any

21 discovery motion must strictly comply with these procedures.

22 6.3 Burden. The burden of persuasion in any such challenge proceeding

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

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

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

26 Designating Party has waived or withdrawn the confidentiality designation, all

27 parties shall continue to afford the material in question the level of protection to

28 which it is entitled under the Producing Party’s designation until the Court rules on

1 the challenge.

2 7. ACCESS TO AND USE OF PROTECTED MATERIAL

3 7.1 Basic Principles. A Receiving Party may use Protected Material that is

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

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

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

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

8 Receiving Party must comply with the provisions of section 13 below (FINAL

9 DISPOSITION).

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

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

12 authorized under this Order.

13 7.1.1 Use of Artificial Intelligence. Notwithstanding any other provision of

14 this Stipulation and Protective Order, under no circumstances shall any Receiving

15 Party upload, enter, or use any Protected Material, or any information derived

16 therefrom, in any open, public, or non-secure artificial intelligence program,

17 platform, or tool, including, but not limited to, large language models, generative AI

18 platforms, or any other artificial intelligence systems (collectively, “AI Tools”)

19 unless the AI Tool provides verifiable technical and contractual assurances that such

20 Protected Material or information will remain private, secure, and inaccessible to

21 any unauthorized person, dataset, model, or other AI Tool, and will not be used for

22 model training, fine-tuning, evaluation, or any other process that may incorporate

23 such information into an AI Tool or other third-party system.

24 Protected Material, and information derived therefrom, may only be used with

25 AI Tools that (a) are operated in a private, closed environment; (b) restrict access to

26 individuals bound by confidentiality obligations equal to or greater than those set

27 forth in this Protective Order; (c) implement and maintain reasonable administrative,

28 technical, and physical safeguards to protect against unauthorized access, disclosure,

1 alteration, or destruction; and (d) prevent any incorporation of Protected Material

2 into shared or publicly accessible models, training datasets, or AI Tools (“Secure

3 AI”). For the avoidance of doubt, prohibited AI Tools include, but are not limited

4 to, open platforms such as the public versions of ChatGPT, Anthropic’s Claude, and

5 Google Gemini. In the event of any unauthorized access, disclosure, or security

6 incident involving Protected Material in connection with any AI Tool or Secure AI,

7 the affected party shall promptly notify all other parties and take reasonable steps to

8 mitigate any resulting harm. This includes compliance with the measures outlined

9 in paragraph 10 below.

10 The Receiving Party using an AI Tool bears the responsibility for any breach

11 or unauthorized disclosure of Protected Material resulting from that use, regardless

12 of whether the fault lies with the user or the platform provider.

13 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless

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

15 Receiving Party may disclose any information or item designated

16 “CONFIDENTIAL” i.e. Protected Material only for purposes of the Myles, et. al. v.

17 State Farm General Insurance Company et. al., Case No. 2:26-cv-00452-CAS

18 (MBKx) litigation and only to the following persons:

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

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

21 necessary to disclose the information for this Action;

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

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

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

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

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

27 (d) the Court and its personnel;

28 (e) court reporters and their staff;

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

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

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

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

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

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

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

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

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

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

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

12 deposition testimony or exhibits to depositions that reveal Protected Material may

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

14 as permitted under this Stipulated Protective Order. Any Non-Party present at the

15 deposition and not subject to this Stipulated Protective Order will leave the

16 proceedings when the witness is providing testimony or being questioned regarding

17 Protected Material unless they are a signatory to this Stipulated Protective Order

18 and/or Exhibit A thereto; and

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

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

21 7.3 Notice of Disclosures of “CONFIDENTIAL” Information or Items or

22 similar. With respect to disclosures pursuant to 7.2(c) and 7.2(f), within twenty

23 days of the disclosure, the Receiving Party will provide written notice to the

24 Designating Party of the disclosure and a copy of Exhibit A executed by the person

25 or entity identified in 7.2(c) or 7.2(f).

26 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED

27 PRODUCED IN OTHER LITIGATION

28 If a Party or any person subject to this Protective Order is served with a

1 subpoena or a court order issued in other litigation that compels disclosure of any

2 information or items designated in this Action as “CONFIDENTIAL” or similar

3 that Party must:

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

5 include a copy of the subpoena or court order;

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

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

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

9 this Stipulated Protective Order; and

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

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

12 If the Designating Party timely seeks a protective order or moves to quash or

13 limit the subpoena or otherwise opposes production of the Protected Material, the

14 Party or any person subject to this Protective Order served with the subpoena or

15 court order shall not produce any information designated in this action as

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

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

18 The Designating Party shall bear the burden and expense of seeking protection in

19 that court of its confidential material and nothing in these provisions should be

20 construed as authorizing or encouraging a Receiving Party in this Action to disobey

21 a lawful directive from another court.

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

23 PRODUCED IN THIS LITIGATION

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

25 Party in this Action and designated as “CONFIDENTIAL” or similar. Such

26 information produced by Non-Parties in connection with this litigation is protected

27 by the remedies and relief provided by this Order. Nothing in these provisions

28 should be construed as prohibiting a Non-Party from seeking additional protections.

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

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

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

7 agreement with a Non-Party;

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

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

10 specific description of the information requested; and

11 (3) make the information requested available for inspection by the

12 Non-Party, if requested.

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

14 days of receiving the notice and accompanying information, the Receiving Party

15 may produce the Non-Party’s confidential information responsive to the discovery

16 request. If the Non-Party timely seeks a protective order, the Receiving Party shall

17 not produce any information in its possession or control that is subject to the

18 confidentiality agreement with the Non-Party before a determination by the Court.

19 Absent a court order to the contrary, the Non-Party shall bear the burden and

20 expense of seeking protection in this Court of its Protected Material.

21 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

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

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

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

26 to retrieve all unauthorized copies of the Protected Material and, use reasonable

27 efforts to prevent further disclosure by the Party and the person(s) receiving the

28 unauthorized disclosure, (c) inform the person or persons to whom unauthorized

1 disclosures were made of all the terms of this Order, and (d) request such person or

2 persons to execute the “Acknowledgment and Agreement to Be Bound” that is

3 attached hereto as Exhibit A.

4 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

5 PROTECTED MATERIAL

6 The inadvertent or unintentional disclosure of Protected Material, regardless

7 of whether the information was so designated at the time of disclosure, shall not be

8 deemed a waiver in whole or in part of the Designating Party’s claim of

9 confidentiality either as to the specific information disclosed therein or on the same

10 or related subject matter.

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

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

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

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

15 procedure may be established in an e-discovery order that provides for production

16 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and

17 (e), insofar as the parties reach an agreement on the effect of disclosure of a

18 communication or information covered by the attorney-client privilege or work

19 product protection, the parties may incorporate their agreement in the Stipulated

20 Protective Order submitted to the Court.

21 12. MISCELLANEOUS

22 12.1 Right to Further Relief. Nothing in this Order abridges the right of any

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

24 12.2 Right to Assert Other Objections. By stipulating to the entry of this

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

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

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

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

1 12.3 Filing Protected Material. A Party that seeks to file under seal any

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

3 may only be filed under seal pursuant to a court order authorizing the sealing of the

4 specific Protected Material at issue; good cause must be shown in the request to file

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

6 Court, then the Receiving Party may file the information in the public record unless

7 otherwise instructed by the Court.

8 13. FINAL DISPOSITION

9 After the final disposition of this Action, as defined in Section 4, within 60

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

11 destroy all Protected Material. As used in this subdivision, “all Protected Material”

12 includes all copies, abstracts, compilations, summaries, and any other format

13 reproducing or capturing any of the Protected Material. This also includes any input

14 of Protected Material or information derived therefrom into any AI Tool, as well as

15 outputs generated by such AI Tool. The Receiving Party must submit a written

16 certification to the Producing Party (and, if not the same person or entity, to the

17 Designating Party) by the 60 day deadline that (1) identifies (by bates number or, if

18 none is available, category) all the Protected Material that was destroyed; (2) affirms

19 that the Receiving Party has not retained any copies, abstracts, compilations,

20 summaries or any other format reproducing or capturing any of the Protected

21 Material; and (3) affirms that the Receiving Party has obtained a certification, which

22 can be produced on demand from the Designating Party, from each of the parties

23 that signed Exhibit A to this Protective Order signifying that each Exhibit A

24 signatory has identified (by category, where appropriate) all the Protected Material

25 that was shared and has been destroyed and affirms that each Exhibit A signatory

26 has not retained any copies, abstracts, compilations, summaries or any other

27 format reproducing or capturing any of the Protected Material. Notwithstanding this

28 provision, counsel are entitled to retain an archival copy of all pleadings, motion

1 papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence,

2 deposition and trial exhibits, expert reports, attorney work product, and consultant

3 and expert work product, even if such materials contain Protected Material. Any

4 such archival copies that contain or constitute Protected Material remain subject to

5 this Protective Order as set forth in Section 4 (DURATION).

6 Nothing in this Protective Order disallows State Farm from: (a) complying

7 with any state or federal law or regulation, including reporting of information to a

8 regulator or government entity as permitted and/or required by applicable state and

9 federal law; (b) adding information discovered that is relevant to a claim to the

10 relevant electronic record in its electronic claim system; or (c) disclosing evidence

11 of a crime or fraud.

12 14. VIOLATION OF ORDER

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

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

15 sanctions.

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1 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD.

2

3 || Dated: May 29, 2026 SHEPPARD, MULLIN, RICHTER & HAMPTON IIp

By /s/ Jennifer M. Hoffman

5 JENNIFER M. HOFFMAN

6 MADALYN A. MACARR

CAROLYN CAREY

7 Attorneys for Defendant

8 STATE FARM GENERAL INSURANCE

COMPANY

9

10

11 || Dated: May 29, 2026 KERLEY SCHAFFER LLP

12 By /s/ Dylan L. Schaffer

13 J. EDWARD KERLEY

14 DYLAN L. SCHAFFER

NICHOLAS J. PETERSON

15 Attorneys for Plaintiffs

16 KATHY MYLES

WILLIE DANIELS

17 || FOR GOOD CAUSE SHOWN IT IS SO ORDERED.

18

19 || DATED: __ June 3 , 2026 LEA Hi

20 MICHAEL B. KAUFMAN

>] UNITED STATES MAGISTRATE JUDGE

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1 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

2

3

I, [print or type full name], of

4

[print or type full address], declare under penalty of perjury that I have read

5

in its entirety and understand the Stipulated Protective Order that was issued by the

6

United States District Court for the Central District of California on [DATE] in the

7

case of Myles, et. al. v. State Farm General Insurance Company et. al., Case No.

8

2:26-cv-00452-CAS (MBKx). I agree to comply with and to be bound by all the

9

terms of this Stipulated Protective Order and I understand and acknowledge that

10

failure to comply could expose me to sanctions and punishment in the nature of

11

contempt. I solemnly promise that I will not disclose in any manner any

12

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

13

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

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Stipulated Protective Order, even if such enforcement proceedings occur after

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termination of this action. [I hereby appoint [print or type

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full name] of [print or type full address and

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

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

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Order.]

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Date:

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City and State where sworn and signed:

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Printed Name:

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Signature:

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This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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