Anna Anush Khachatryan v. State Farm Mutual Automobile Insurance Company ( 2019 )

EEE EEE SE NEE am A eee Na eS wT ee . 1 | LAURIE E. SHERWOOD, State Bar No. 155312 □□ Isherwood@wfbm.com || WFBM, LLP □ 601 Montgomery Street, Ninth Floor 3 ? San Francisco, California 94111-2612 MANDATORY _ 41lTelephone: (415) 781-7072 imile: 15) 391- □□ □□□ 5 ||Facsimile: (415) 391-6258 CHAMBERS COPY 6 || SAGE R. KNAUFT, State Bar No. 194396 7 sknauft@wfbm.com REEMA ABBOUD, State Bar No. 301841 8 || rabboud@wfbm.com 9 || WFBM, LLP One City Boulevard West, Fifth Floor 10 || Orange, California 92868-3677 il Telephone: (714) 634-2522 Facsimile: (714) 634-0686 12 = 8 13 || Attorneys for Defendant, Es STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY bia 15 || A: JACOB NALBANDYAN, State Bar No. 272023 5 8 jnalbandyan@Intriallawyers.com 16 || TANGANICA J. TURNER, State Bar No. 315716 □ 17 || tturer@lntriallawyers.com vee LEVIN & NALBANDYAN, LLP 18]/811 Wilshire Boulevard, Suite 800 . 19 || Los Angeles, California 90017 _ Telephone: (213) 232-4848 . . 20|/Facsimile: (213) 232-4849 NOTE CHANGES MADE 3Y THE COURT Attorneys for Plaintiff, ANNA ANUSH KHACHATRYAN □ UNITED STATES DISTRICT COURT 23 CENTRAL DISTRICT OF CALIFORNIA 2A ANNA ANUSH KHACHATRYAN, an Case No. 2:18-cv-9084 PSG (AGR) 25 || individual, . Los Angeles County Superior Court 26 Plaintiff, es No. BC752280] 27 STIPULATED PROTECTIVE v. ORDER. 28 5 NOTE CHANGES MADE BY THE COURT IIE IIIIIE IIIS IDE BIDE NIPSEIAGONAS SEN Ow NN Be TAY LS □□ 1 STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, an Illinois 9 || Corporation, and DOES 1 through 20, Inclusive, 3 Defendants. 4 1. PURPOSES AND LIMITATIONS 5 Discovery in this action is likely to involve production of confidential, 6 || Proprietary or private information for which special protection from public 7 || disclosure and from use for any purpose other than pursuing this litigation may be g || warranted. Accordingly, the parties hereby stipulate to and petition the Court to g|jenter the following Stipulated Protective Order. The parties acknowledge that this 10 || Order does not confer blanket protections on all disclosures or responses to 11 || discovery and that the protection it affords from public disclosure and use extends 12 || only to the limited information or items that are entitled to confidential treatment ; 13 || under the applicable legal principles. ~ ; 4 2. GOODCAUSE STATEMENT 38 15 This action is likely to involve trade secrets, medical information, third party ES 16 || identification and other valuable confidential or proprietary information for which 17 || Special protection from public disclosure and from use for any purpose other than 18 ||Prosecution of this action is warranted. Such confidential and proprietary materials 19 || and information consist of, among other things, confidential business or financial 40 || information, information regarding confidential business practices, or other 21 || confidential research, development, or commercial information (including 22 || information implicating privacy rights of third parties), information otherwise 23 || generally unavailable to the public, or which may be privileged or otherwise 24 || protected from disclosure under state or federal statutes, court rules, case decisions, 25 || or common law. Accordingly, to expedite the flow of information, to facilitate the 26 || prompt resolution of disputes over confidentiality of discovery materials, to 27 || adequately protect information the parties are entitled to keep confidential, to ensure 28 || that the parties are permitted reasonable necessary uses of such material in -2- IEE OIRO EIEN. Ge NEE ils WP MM eR AY OP □□ 1 || preparation for and in the conduct of trial, to address their handling at the end of the 2 || litigation, and serve the ends of justice, a protective order for such information is 3 || justified in this matter. It is the intent of the parties that information will not be 4 || designated as confidential for tactical reasons and that nothing be so designated 5 || without a good faith belief that it has been maintained in a confidential, non-public 6 manner, and there is good cause why it should not be part of the public record of this 7 || case. 8 3. | ACKNOWLEDGMENT OF UNDER SEAL FILING PROCEDURE 9 The parties further acknowledge, as set forth in Section 14.3, below, that this 10 || Stipulated Protective Order does not entitle them to file confidential information 11 || under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed 12 || and the standards that will be applied when a party seeks permission from the court 13 || to file material under seal. |Fhere-is-a-streng_presumption that the-public has- righ 14 |Ofaccess to judicial proceedings and records in civil cases. In connection with non 8 15 ne on good cause must be shown to support a filing under‘seal. See : 5 16 ||\Kamakana City and County of Honolulu 447 F.3d 1172, 1176(9th Cir. 2006), 17 Phillips v. Gen. M otors Corp., 307 F.3d 1206, 1210-11 (9#fCir. 2002), Makar- 18||hwelbon v. Sony BleStrios, Inc., 187 FD. 576, STI(E.D. Wis. 1999) (even 19 || Stipulated protective orders require good causeShowing), and a specific showing of 20 || good cause or compelling reason3nwith pr6per evidentiary support andlegal 21 |justification, must be made with respechto Protected Material that a party seeks to 22 || file under seal. The parties’ m€ére designatiotof Disclosure or Discovery Material 5 23 || CONFIDENTIAL does fot— without the submission of competent evidence by 24 || declaration, establishing that the material sought to be fied under seal qualifies as 25 || confidential Privileged, or otherwise protectable—constitute 2aod cause. 26 || Rurther,if a party requests sealing related to a dispositive motion or tial, then || govhpelling reasons, not only good cause, for the sealing must be shown, and 16 28 EIEIO IIE OIE IN ae OTT □ □□□ □□ oe 1 lIrettefs ought shall be narrowly tailored to serve the specific interest to be proteCted. 2 Creditors Ass’n., 605 F.3d 665, 677-79 (9trCir. 2010). For 3]!each item or type of informatton,document, or thing Sought to be filed or introduced 4 under seal, the party seeking protectierr mustasticulate compelling reasons, □ |lsupported by specific faets“and legal justification, for thé 2 jested sealing order. 6 ||Again, competént evidence supporting the application to file documents.under seal 7 |Ipust be provided by declaration. 8 Any document that is not confidential, privileged, or otherwise protectable in 9 |\its entirety will not be filed under seal if the confidential portions can be redacted. 10 || If documents can be redacted, then a redacted version for public viewing, omitting § 11 || only the confidential, privileged, or otherwise protectable portions of the document, : : a 12 || shall be filed. Any application that seeks to file documents under seal in their 13 || entirety should include an explanation of why redaction is not feasible. 14 4. DEFINITIONS 15 4.1. Action: Anna Anush Khachatryan, an individual v. State Farm Mutual 5 16 || Automobile Insurance Company; et al., Case No. 2:18-cv-9084 PSG (AGR); 4.2 Challenging Party: a Party or Non-Party that challenges the `` 18 || designation of information or items under this Order. - 4.3 “CONFIDENTIAL” Information or Items: information 20 || (regardless of how it is generated, stored or maintained) or tangible things that 21 || qualify for protection under Federal Rule of Civil Procedure 26(c), and as specified 22]/above in the Good Cause Statement. 44 Counsel: Outside Counsel of Record and House Counsel (as well. 24 |! as their support staff). □ 25 4.5 Designating Party: a Party or Non-Party that designates 26 || information or items that it produces in disclosures or in responses to discovery as 27 || “CONFIDENTIAL.” 28 -4. IIE III IIE ONES OR NEE ONE NN me TE □ □□□□ □ □□ 1 4.6 Disclosure or Discovery Material: all items or information, 2 ||regardless of the medium or manner in which it is generated, stored, or maintained 3 || (including, among other things, testimony, transcripts, and tangible 4 || things), that are produced or generated in disclosures or responses to discovery. 5 4.7 Expert: a person with specialized knowledge or experience in a 6 || matter pertinent to the litigation who has been retained by a Party or its counsel 7 || to serve as an expert witness or as a consultant in this Action. 8 4.8 | House Counsel: attorneys who are employees of a party to this 9 || Action. House Counsel does not include Outside Counsel of Record or any other 10.|| outside counsel. . 11 4.9 Non-Party: any natural person, partnership, corporation, : 12 || association or other legal entity not named as a Party to this action. 13 4.10 Outside Counsel of Record: attorneys who are not employees of a party 14|\to this Action but are retained to represent a party to this Action and have appeared 15 || in this Action on behalf of that party or are affiliated with a law firm that has 16 || appeared on behalf of that party, and includes support staff. 17 4.11 Party: any party to this Action, including all of its officers, directors, 18 || employees, consultants, retained experts, and Outside Counsel of Record (and 19 || their support staffs). 20 4.12 Producing Party: a Party or Non-Party that produces Disclosure or 21 || Discovery Material in this Action. 22 4.13 Professional Vendors: persons or entities that provide litigation || support services (e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and organizing, storing, or retrieving data in any form or 25 ||medium) and their employees and subcontractors. 26 4.14 Protected Material: any Disclosure or Discovery Material that is 27 || designated as “CONFIDENTIAL.” 28 & III EIEIO IIIS ISTE IERIE RE NES 0SWNAE Ws SAE NERY OF TY 1 4.15 Receiving Party: a Party that receives Disclosure or Discovery Material 2 || from a Producing Party. 3 5. SCOPE 4 The protections conferred by this Stipulation and Order cover not only □ 5 || Protected Material (as defined above), but also (1) any information copied or 6 || extracted from Protected Material; (2) all copies, excerpts, summaries, or 7 || compilations of Protected Material; and (3) any testimony, conversations, or 8 presentations by Parties or their Counsel that might reveal Protected Material. 9 || Any use of Protected Material at trial shall be governed by the orders of the trial 10 || judge and other applicable authorities. This Order does not govern the use of 5 11 Protected Material at trial. 12 6. DURATION _ □ : 13 | Once a case proceeds to trial, information that was designated as : || CONFIDENTIAL or maintained pursuant to this protective order used or introduced 15.||as an exhibit at trial becomes public and will be presumptively available to all : 16 ||members of the public, including the press, unless compelling reasons supported by 17 || specific factual findirigs to proceed otherwise are made to the trial judge in advance 18 || of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” 19 showing for sealing documents produced in discovery from “compelling reasons” 20 || standard when merits-related documents are part of court record). Accordingly, the 21 ||terms of this protective order do not extend beyond the commencement of the trial. 221 7. | DESIGNATING PROTECTED MATERIAL 7.1 Exercise of Restraint and Care in Designating Material for Protection. /||Bach Party or Non-Party that designates information or items for protection under 25 || this Order must take care to limit any such designation to specific material that 26 || qualifies under the appropriate standards. The Designating Party must designate for 27 protection only those parts of material, documents, items or oral or written □ 28 6. EEE IEEE II III I INES ONSEN NAS AT NN Ele OP OP 1 || communications that qualify so that other portions of the material, documents, 2 || items or communications for which protection is not warranted are not swept 3 || unjustifiably within the ambit of this Order. 4 Mass, indiscriminate or routinized designations are prohibited. Designations 5 || that are shown to be clearly unjustified or that have been made for an improper 6 || purpose (e.g., to unnecessarily encumber the case development process or to impose 7 || unnecessary expenses and burdens on other parties) may expose the Designating 8 || Party to sanctions. 9 If it comes to a Designating Party’s attention that information or items that it 10 || designated for protection do not qualify for protection, that Designating Party must 11 |) promptly notify all other Parties that it is withdrawing the inapplicable designation. 12 7.2 | Manner and Timing of Designations. Except as otherwise provided g 13 || in this Order, or as otherwise stipulated or ordered, Disclosure of Discovery 3 14'|| Material that qualifies for protection under this Order must be clearly so 15 || designated. before the material is disclosed or produced. 5 16 Designation in conformity with this Order requires: 17 (a) for information in documentary form (e.g., paper or electronic 18 || documents, but excluding transcripts of depositions or other pretrial or trial 19 || proceedings), that the Producing Party affix at a minimum, the legend 20 || “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 21 contains protected material. If only a portion of the material on a page qualifies for 22 || protection, the Producing Party also must clearly identify the protected portion(s) -23'||(e.g., by making appropriate markings in the margins). == □ 241 A Party or Non-Party that makes original documents available for inspection 25 || need not designate them for protection until after the inspecting Party has indicated 26 || which documents it would like copied and produced. 27|) 28 || I IEEE IIE III EORE IIE NENG Bw Af NN NE TAY OT 1 || During the inspection and before the designation, all of the material made available for inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has 3 || identified the documents it wants copied and produced, the Producing Party must 4 || determine which documents, or portions thereof, qualify for protection under this 5 || Order. Then, before producing the specified documents, the Producing Party must 6 || affix the “CONFIDENTIAL legend” to each page that contains Protected Material. 7 || If only a portion of the material on a page qualifies for protection, the Producing 8 || Party also must clearly identify the protected portion(s) (e.g., by making appropriate 9 | markings in the margins). 10 (b) for testimony given in depositions that the Designating Party 11 || identifies the Disclosure or Discovery Material on the record, before the close of 12 || the deposition all protected testimony. 13 (c) for information produced in some form other than documentary and 14 || for any other tangible items, that the Producing Party affix in a prominent place on 8 15 || the exterior of the container or containers in which the information is stored the : 16 || legend “CONFIDENTIAL.” If only a portion or portions of the information ‘17 || warrants protection, the Producing Party, to the extent practicable, shall identify the 18 || protected portion(s). _ 19 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 20 || failure to designate qualified information or items does not, standing alone, waive 21 || the Designating Party’s right to secure protection under this Order for such 22 || material. Upon timely correction of a designation, the Receiving Party must make 23 ||reasonable efforts to assure that the material is treated in accordance with the 24 |I provisions of this Order. \/// □□ 26|{/// . 27/11 28 IIE EEE IE □□□ IIT Un IIA NANA Eom NIV Wile WO OMT RYN TT 1 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS 2 8.1. Timing of Challenges. Any Party or Non-Party may challenge a 3 || designation of confidentiality at any time that is consistent with the Court’s 4 || Scheduling Order. . □ 5 8.2 Meet and Confer. The Challenging Party shall initiate the dispute 6 || resolution process under Local Rule 37-1 et seq. 7 8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a 8 || joint stipulation pursuant to Local Rule 37-2. 9 8.4 The burden of persuasion in any such challenge proceeding shall be on 10 || the Designating Party. Frivolous challenges, and those made for an improper 11 | purpose (e.g., to harass or impose unnecessary expenses and burdens on other : a 12 || parties) may expose the Challenging Party to sanctions. Unless.the Designating 13)/Party has waived or withdrawn the confidentiality designation, all parties □□□□□□ . continue to afford the material in question the level of protection to which it is. -_ 15 || entitled under the Producing Party’s designation until the Court rulesonthe □□ ; 16 || challenge. 9, 18 9.1 Basic Principles, A Receiving Party may use Protected Material that is 19 || disclosed or produced by another Party or by a Non-Party in connection with 20 || this Action only for prosecuting, defending or attempting to settle this Action. 21 || Such Protected Material may be disclosed only to the categories of persons and □ 22 || under the conditions described in this Order. When the Action hasbeen. 23 || terminated, a Receiving Party must comply with the provisions of section 15 ||below (FINAL DISPOSITION). _ 25 Protected Material must be stored and maintained by a Receiving Party 26 || at a location and in a secure manner that ensures that access is limited to the 27 || persons authorized under this Order. : 28 EE EEE IT IIE □□□ 1 9.2 Disclosure of “CONFIDENTIAL” Information or Items. “2 Unless otherwise ordered by the court or permitted in writing by the 3 || Designating Party, a Receiving Party may disclose any information or item 4 || designated “CONFIDENTIAL” only to: 5 (a) the Receiving Party’s Outside Counsel of Record in this Action, 6 || as well as employees of said Outside Counsel of Record to whom it is 7 || reasonably necessary to disclose the information for this Action; 8 (b) the officers, directors, and employees (including House 9 || Counsel) of the Receiving Party to whom disclosure is reasonably necessary for this Action; eve Li (c) Experts (as defined in this Order) of the Receiving Party to 12 || whom disclosure is reasonably necessary for this Action and who have signed E 13 || the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 3 14 (d) the court and its personnel; 15 (e) court reporters and their staff, ; 16 (f) professional jury or trial consultants, mock jurors, and 17 || Professional Vendors to whom disclosure is reasonably necessary for this 18 | Action and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 20 (g) the author or recipient of a document containing the . 21 || information or a custodian or other person who otherwise possessed or knew 22 || the information; 23'| (h) during their depositions, witnesses, and attorneys for witnesses, in the Action to whom disclosure is reasonably necessary provided: □□□ □□□ □□□□□ 25 || deposing party requests that the witness sign the form attached as Exhibit A 26 || hereto; and (2) they will not be permitted to keep any confidential information 27 | unless they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit 28 I IIE IIIIEE IRIOE ISIE PN QR in an NAN Em ne SA TE □□ 1 || A), unless otherwise agreed by the Designating Party or ordered by the court. 2 || Pages of transcribed deposition testimony or exhibits to depositions that reveal 3 || Protected Material may be separately bound by the court reporter and may not 4 |!be disclosed to anyone except as permitted under this Stipulated Protective 5 || Order; and _ (i) any mediators or settlement officers and their supporting personnel, mutually agreed upon by any of the parties engaged in settlement 8 || discussions. 9 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED 10. PRODUCED IN OTHER LITIGATION 11 Ifa Party is served with a subpoena or a court order issued in other 12 || litigation that compels disclosure of any information or items designated in this : Action as “CONFIDENTIAL,” that Party must: 3 14]. (a) promptly notify in writing the Designating Party. Such 15 || notification shall include a copy of the subpoena or court order; . 16]| (b) promptly notify in writing the party who caused the subpoena ]/or order to issue in the other litigation that some or all of the material covered 18 by the subpoena or order is subject to this Protective Order. Such notification 19 || shall include a copy of this Stipulated Protective Order; and (c) cooperate with respect to all reasonable procedures sought to be 21 || pursued by the Designating Party whose Protected Material may be affected. If 22 || the Designating Party timely seeks a protective order, the Party served with the 23 || subpoena or court order shall not produce any information designated in this 24 || action as “CONFIDENTIAL?” before a determination by the court from which 25 || the subpoena or order issued, unless the Party. has obtained the Designating | 26 || Party’s permission. The Designating Party shall bear the burden and expense of 27 || seeking protection in that court of its confidential material and nothing in these 28 IEEE II IIIS EE IOIOIRD SOOSEIEID NEE ONAN ie me AE RK MAYS Oe TT ee 1 || provisions should be construed as authorizing or encouraging a Receiving Party 2 |lin this Action to disobey a lawful directive from another court. 3 11. ANON-PARTY'S PROTECTED MATERIAL SOUGHT TO BE 4 PRODUCED IN THIS LITIGATION 5 (a) The terms of this Order are applicable to information produced 6 a Non-Party in this Action and designated as “CONFIDENTIAL.” Such 7 || information produced by Non-Parties in connection with this litigation is 8 || protected by the remedies and relief provided by this Order. Nothing in these □ 9 || provisions should be construed as prohibiting a Non-Party from seeking . 10 || additional protections. 11. (b) In the event that a Party is required, by a valid discovery : 12 || request, to produce a Non-Party’s confidential information in its possession, 13 || and the Party is subject.to an agreement with the Non-Party not to produce the E 14]/Non-Party’s confidential information, then the Party shall: oe 15 (1) promptly notify in writing the Requesting Party and the Non- . 53 16||Party that some or all of the information requested is subjecttoa | 17 || confidentiality agreement with a Non-Party; 18 . (2) promptly provide the Non-Party with a copy of the Stipulated 19 | Protective Order in this Action, the relevant discovery request(s), and 20 || reasonably specific description of the information requested; and 21 (3) make the information requested available for inspection by the 22 || Non-Party, if requested. □ 23 (c) If the Non-Party fails to seek a protective order from this court within 14 days of receiving the notice and accompanying information, the 25 || Receiving Party may produce the Non-Party’s confidential information 26 || responsive to the discovery request. If the Non-Party timely seeks a protective 27 || order, the Receiving Party shall not produce any information in its possession or 28 -12- IEEE III IS IIIS DENI SENG IRIN ONAN NAT MY OM □□ □□ 1 | control that is subject to the confidentiality agreement with the Non-Party 2 || before a determination by the court. Absent a court order to the contrary, the 3 || Non-Party shall bear the burden and expense of seeking protection in this court 4 || of its Protected Material. 5 12. UNAUTHORIZED DISCLOSURE OF PROTECTED 6 MATERIAL 7H Ifa Receiving Party learns that, by inadvertence or otherwise, it has 8 || disclosed Protected Material to any person or in any circumstance not 9 || authorized under this Stipulated Protective Order, the Receiving Party must 10 || immediately (a) notify in writing the Designating Party of the unauthorized 5 11 || disclosures, (b) use its best efforts to retrieve all unauthorized copies of the 12 Protected Material, (c) inform the person or persons to whom unauthorized 13 |; disclosures were made of all the terms of this Order, and (d) request such 3 14/]/person or persons to execute the “Acknowledgment an Agreement to Be 15|[Bound” attached hereto as Exhibit A. 16 13. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED MATERIAL 18 || When a Producing Party gives notice to Receiving Parties that certain 19 || inadvertently produced material is subject to a claim of privilege or other 20 || protection, the obligations of the Receiving Parties are those set forth in Federal 21 || Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 22 || whatever procedure may be established in an e-discovery order that provides 23 || for production without prior privilege review. Pursuant to Federal Rule of 24 Evidence 502(d) and (e), insofar as the parties reach an agreement on the effect — 25 || of disclosure of a communication or information covered by the attorney-client 26 || privilege or work product protection, the parties may incorporate their 27 || agreement in the stipulated protective order submitted to the-court. 28 EI ENED SEOUL IGE OVE NE EEE OA ee eee 1 14. MISCELLANEOUS 2 14.1 Right to Further Relief. Nothing in this Order abridges the right of 3 || any person to seek its modification by the Court in the future. 4 14.2 Right to Assert Other Objections. By stipulating to the entry of this 5 || Protective Order, no Party waives any right it otherwise would have to object to 6 || disclosing or producing any information or item on any ground not addressed in 7 || this Stipulated Protective Order. Similarly, no Party waives any right to object 8 On any ground to use in evidence of any of the material covered by this 9 || Protective Order. 10 14.3 Filing Protected Material. A Party that seeks to file under seal any 11 || Protected Material must comply with Local Civil Rule 79-5. Protected Material 12 ||may only be filed under seal pursuant to a court order authorizing the sealing of 13 || the specific Protected Material. If a Party’s request to file Protected Material 3 |) under seal is denied by the court, then the Receiving Party may file the 8 15 || information in the public record unless otherwise instructed by the court. (16 15. FINAL DISPOSITION After the final disposition of this Action, as defined in paragraph 6, 18 |) within 60 days of a written request by the Designating Party, each Receiving _ 19 || Party must return all Protected Material to the Producing Party or destroy 20 ||such material. As used in this subdivision, “all Protected Material” includes 21 || all copies, abstracts, compilations, summaries, and any other format 22 || reproducing or capturing any of the Protected Material. Whether the 23 || Protected Material is returned or destroyed, the Receiving Party must submit 24 || written certification to the Producing Party (and, ifnot the same person 25 || entity, to the Designating Party) by the 60-day deadline that (1) identifies (by 26 || category, where appropriate) all the Protected Material that was returned or 27 || destroyed and (2) affirms that the Receiving Party has not retained any copies, EI IIS IGE! ENE NN NN Oe OTE □ □□□ □□ 1 || abstracts, compilations, summaries or any other format reproducing or. . 2 || capturing any of the Protected Material. Notwithstanding this provision, 3 || Counsel are entitled to retain an archival copy of all pleadings, motion papers, 4/||trial, deposition, and hearing transcripts, legal memoranda, correspondence, 5 || deposition and trial exhibits, expert reports, attorney work product, and 6 || consultant and expert work product, even if such materials contain Protected 7 || Material. Any such archival copies that contain or constitute Protected 8 || Material: remain subject to this Protective Order as set forth in Section 6 9 || (DURATION). . `` 16. VIOLATION § 11 Any violation of this Order may be punished by appropriate : 12 || measures including, without limitation, contempt proceedings and/ or i 13 |}monetary sanctions. . . 5 14 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 15 ||Dated: August 26,2019. LEVIN & NALBANDYAN, LLP 4 eo □ 18 By: /s/ Tanganica J. Turner . 19] JACOB NALBANDYAN □ . 20 TANGANICA J. TURNER : Attorneys for Plaintiff - 21 oo ANNA ANUSH KHACHATRYAN 22 . 25 . . 26 27 □ 28 . . oo Eo ee Ee ee ON eR NANA NATE AEE Se FOR UN Be er OL gv su Vet IY □□□ Dated: August 26, 2019 WFBM, LLP 2 . 4 By: /s/Reema Abboud 5 LAURIE E. SHERWOOD SAGE R. KNAUFT 6 REEMA ABBOUD 7 Attorneys for Defendant □ STATE FARM MUTUAL AUTOMOBILE 8 INSURANCE COMPANY 10 . 3 & eo 12 14 16 18 . . 19 . 20 : 21 22 25 26 27 28| IEE EE IEE EO a” —_—anmeiseee ee fe NE Bee eae ' gw at MI ee BRAWN PR □□ □□ 1 ATTORNEY ATTESTATION. 2 Pursuant to Central District Local Rule 5-4.3.4(a)(2), 1, Reema Abboud, attest that all other signatories listed, and on whose behalf the filling is submitted, concur 4 |j in the filing’s content and have authorized the filing. 5 Executed on August 26, 2019, in Orange, California. 7 Dated: August 26, 2019 WFBM, LLP 9 By: /s/ Reema Abboud 10 REEMA ABBOUD 11 Attorneys for Defendant STATE FARM MUTUAL AUTOMOBILE pga 2 INSURANCE COMPANY She 15 sig 18 19 201]. 21 22 . 25 □ 26 27 28 |}. -17- IEEE III IEEE MEONRE We SABB ND NM Ee AY OLY TPL FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 3 || DATED: ‘| 6|2014 (be: 2-L\. UNL 4 U.S. DISTRICT COURT TAG TRATE JUDGE 6 8 10 Ly 13 pag 14 16 at 18 19 20 21. 22 al ul 25 26 eee _ EXHIBIT "A" EXHIBIT A □ ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND I, [name], of _ [address], declare under penalty of perjury that I have read in its entirety and understand the Stipulated Protective Order that was issued by the United States District Court for the Central District of California in the case of Khachatryan v. State Farm, Case No. 2:18-cv-9084 PSG (AGR). I agree to comply with and to be bound by all the terms of this Stipulated Protective Order and I understand and acknowledge that failure to so comply could expose me to sanctions and punishment in the nature of contempt. I solemnly promise that I will not disclose in any manner any information or item that is subject to this Stipulated Protective Order to any person or entity except in strict compliance with the provisions of this Order. I further agree to submit to the jurisdiction of the United States District Court for the Central District of California for the purpose of enforcing the terms of this Stipulated Protective Order, even if such enforcement proceedings occur after termination of this action. I hereby appoint. snare] of [address and telephone number] as my California agent for service of process in connection with this action or any _ proceedings related to enforcement of this Stipulated Protective Order. Date: City and State: Printed name: Signature: 4995-3 4951