Monarch Life Insurance Company v. Robert M. Turner

Filing 26

STIPULATED PROTECTIVE ORDER by Magistrate Judge Jay C. Gandhi re Stipulation for Protective Order 24 . (kh)

1 SANDRA I. WEISHART (SBN 89792)
[e-mail]
2 CHAKAMEH GANJI (SBN 311720)
[e-mail]
3 Hinshaw & Culbertson LLP
633 West 5th Street, 47th Floor
4 Los Angeles, CA 90071-2043
Telephone: [phone]
5 Facsimile: 213-614-7399
6 Attorneys for Plaintiff and Counter-Defendant
Monarch Life Insurance Company
7
8

UNITED STATES DISTRICT COURT

9

CENTRAL DISTRICT OF CALIFORNIA

10 MONARCH LIFE INSURANCE
11 COMPANY, a corporation,
Plaintiff,
12
13

vs.

Case No. 8:17-cv-01732-JLS-JCG
(Honorable Jay C. Gandhi)
DISCOVERY MATTER

14 ROBERT M. TURNER, M.D.,
Defendant.
15

STIPULATED PROTECTIVE
ORDER

16

Courtroom:

17

Complaint Filed: October 3, 2017

10A

18
19 ROBERT M. TURNER, M.D.,
20
Defendant and CounterClaimant,
21
22

vs.

23 MONARCH LIFE INSURANCE 30,
COMPANY, and DOES 1 through
24 Inclusive,
Plaintiff and Counter25
Defendant,
26
27
28
HINSHAW & CULBERTSON LLP
633 West 5th Street, 47th Floor
Los Angeles, CA 90071-2043
213-680-2800

STIPULATED PROTECTIVE ORDER
Case No. 8:17-cv-01732-JLS-JCG
301367814v1 0987400

1

Plaintiff and Counter-Defendant Monarch Life Insurance Company

2

(“Monarch”) and Defendant and Counter-Claimant Robert M. Turner, M.D. (“Dr.

3

Turner”) hereby stipulate as follows:

4
5

1.

A.

PURPOSE AND LIMITS OF THIS ORDER

6

Discovery in this action is likely to involve production of confidential,

7

proprietary, or private information for which special protection from public

8

disclosure and from use for any purpose other than prosecuting this litigation may

9

be warranted. Accordingly, the parties hereby stipulate to and petition the Court to

10

enter the following Stipulated Protective Order. The parties acknowledge that this

11

Order does not confer blanket protections on all disclosures or responses to

12

discovery and that the protection it affords from public disclosure and use extends

13

only to the limited information or items that are entitled to confidential treatment

14

under the applicable legal principles. The parties further acknowledge, as set forth in

15

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

16

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

17

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

18

seeks permission from the Court to file material under seal.

19
20

B.

21

There is good cause for issuance of the Order pursuant to Federal Rule of

22

Civil Procedure 26(c) because discovery will include the production of confidential,

23

proprietary or trade secret documents and/or information for which special

24

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

25

prosecution of this action is warranted. Such materials include but are not limited to

26

disability income insurance policy files, bank and business records that contain

27

financial, medical, insurance-related and/or other private information belonging to

28

Dr. Turner and, in some cases to non-parties such as Dr. Turner’s current or former
1

HINSHAW & CULBERTSON LLP
633 West 5th Street, 47th Floor
Los Angeles, CA 90071-2043
213-680-2800

GOOD CAUSE STATEMENT

STIPULATED PROTECTIVE ORDER

1

business partners.

2

confidential, proprietary or private information belonging to Monarch, such as

3

materials relating to its disability income insurance business including, but not

4

limited to, information pertaining to claims handling, internal company procedures

5

and/or company financial information, the disclosure of which would give

6

Monarch’s competitors information that otherwise could not be obtained, and which

7

competitors could adopt at a substantial cost savings. The confidential, proprietary

8

or trade secret documents and information are not otherwise generally unavailable to

9

the public, and may be privileged or otherwise protected from disclosure under state

10

or federal statutes, court rules, case decisions, or common law. Without a protective

11

order, the confidentiality of the foregoing materials cannot be adequately

12

maintained.

13

handling of the aforementioned materials.

Discovery may also involve the production of certain

This Stipulation and the Order shall govern the designation and

14

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

15

resolution of disputes over confidentiality of discovery materials, to adequately

16

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

17

parties are permitted reasonable necessary uses of such material in preparation for

18

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

19

serve the ends of justice, a protective order for such information is justified in this

20

matter. It is the intent of the parties that information will not be designated as

21

confidential for tactical reasons and that nothing will be so designated without a

22

good faith belief that it has been maintained in a confidential, non-public manner,

23

and there is good cause why it should not be part of the public record of this case.

24
25

2.

DEFINITIONS

26

2.1

Action: The above-captioned lawsuit.

27

2.2

Challenging Party:

28
HINSHAW & CULBERTSON LLP
633 West 5th Street, 47th Floor
Los Angeles, CA 90071-2043
213-680-2800

a Party or Non-Party that challenges the

designation of information or items under this Order.
2
STIPULATED PROTECTIVE ORDER

1

2.3

“CONFIDENTIAL” Information or Items: information (regardless of

2

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

3

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

4

the Good Cause Statement.

5
6
7

2.4

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

their support staff).
2.5

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

8

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

9

“CONFIDENTIAL.”

10

2.6

Disclosure or Discovery Material: all items or information, regardless

11

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

12

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

13

generated in disclosures or responses to discovery in this matter.

14

2.7

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

15

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

16

an expert witness or as a consultant in this Action.

17

2.8

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

18

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

19

counsel.

20
21

2.9

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

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

22

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

23

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

24

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

25

which has appeared on behalf of that party, and includes support staff.

26

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

27

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

28

support staffs).

HINSHAW & CULBERTSON LLP
633 West 5th Street, 47th Floor
Los Angeles, CA 90071-2043
213-680-2800

3
STIPULATED PROTECTIVE ORDER

1
2

2.12 Producing Party: a Party or Non-Party that produces Disclosure or
Discovery Material in this Action.

3

2.13 Professional Vendors:

persons or entities that provide litigation

4

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

5

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

6

and their employees and subcontractors.

7

2.14 Protected Material:

8

designated as “CONFIDENTIAL.”

9
10

any Disclosure or Discovery Material that is

2.15 Receiving Party:

a Party that receives Disclosure or Discovery

Material from a Producing Party.

11
12

3.

SCOPE

13

The protections conferred by this Stipulation and Order cover not only

14

Protected Material (as defined above), but also (1) any information copied or

15

extracted from Protected Material; (2) all copies, excerpts, summaries, or

16

compilations of Protected Material; and (3) any testimony, conversations, or

17

presentations by Parties or their Counsel that might reveal Protected Material. Any

18

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

19

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

20
21

4.

DURATION

22

Even after final disposition of this litigation, the confidentiality obligations

23

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

24

otherwise in writing or a court order otherwise directs. Final disposition shall be

25

deemed to be the later of (1) dismissal of all claims and defenses in this Action, with

26

or without prejudice; and (2) final judgment herein after the completion and

27

exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action,

28
HINSHAW & CULBERTSON LLP
633 West 5th Street, 47th Floor
Los Angeles, CA 90071-2043
213-680-2800

4
STIPULATED PROTECTIVE ORDER

1

including the time limits for filing any motions or applications for extension of time

2

pursuant to applicable law.

3
4
5

5.

DESIGNATING PROTECTED MATERIAL
5.1

Exercise of Restraint and Care in Designating Material for Protection:

6

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

7

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

8

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

9

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

10

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

11

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

12

unjustifiably within the ambit of this Order.

13

Mass, indiscriminate, or routinized designations are prohibited. Designations

14

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

15

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

16

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

17

Party to sanctions.

18

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

19

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

20

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

21

5.2

Manner and Timing of Designations: Except as otherwise provided in

22

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

23

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

24

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

25

produced.

26

Designation in conformity with this Order requires:

27

(a)

28
HINSHAW & CULBERTSON LLP
633 West 5th Street, 47th Floor
Los Angeles, CA 90071-2043
213-680-2800

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

documents, but excluding transcripts of depositions or other pretrial or trial
5
STIPULATED PROTECTIVE ORDER

1

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

2

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

3

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

4

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

5

portion(s) (e.g., by making appropriate markings in the margins). A Party or Non-

6

Party that makes original documents available for inspection need not designate

7

them for protection until after the inspecting Party has indicated which documents it

8

would like copied and produced. During the inspection and before the designation,

9

all

of

the

material

made

available

for

inspection

shall

be

deemed

10

“CONFIDENTIAL.” After the inspecting Party has identified the documents it

11

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

12

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

13

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

14

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

15

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

16

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

17

margins).

18

(b)

for testimony given in depositions that the Designating Party identify

19

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

20

deposition all protected testimony.

21

(c)

for information produced in some form other than documentary and for

22

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

23

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

24

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

25

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

26

portion( s).

27
28
HINSHAW & CULBERTSON LLP
633 West 5th Street, 47th Floor
Los Angeles, CA 90071-2043
213-680-2800

5.3

Inadvertent Failures to Designate: If timely corrected, an inadvertent

failure to designate qualified information or items does not, standing alone, waive
6
STIPULATED PROTECTIVE ORDER

1

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

2

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

3

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

4

Order.

5
6

6.

7

CHALLENGING CONFIDENTIALITY DESIGNATIONS
6.1

Timing of Challenges:

Any Party or Non-Party may challenge a

8

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

9

Scheduling Order.

10
11

6.2

Meet and Confer: The Challenging Party shall initiate the dispute

resolution process under Local Rule 37.1 et seq.

12

6.3

Burden of Persuasion: The burden of persuasion in any such challenge

13

proceeding shall be on the Designating Party. Frivolous challenges, and those made

14

for an improper purpose (e.g., to harass or impose unnecessary expenses and

15

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

16

Designating Party has waived or withdrawn the confidentiality designation, all

17

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

18

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

19

the challenge.

20
21
22

7.

ACCESS TO AND USE OF PROTECTED MATERIAL
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.

27

Receiving Party must comply with the provisions of Section 13, below (FINAL

28

DISPOSITION).

HINSHAW & CULBERTSON LLP
633 West 5th Street, 47th Floor
Los Angeles, CA 90071-2043
213-680-2800

When the Action has been terminated, a

7
STIPULATED PROTECTIVE ORDER

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

7

“CONFIDENTIAL” only to:

8
9
10
11
12
13

(a)

Party

may

disclose

any

information

or

item

designated

the Receiving Party’s Outside Counsel of Record in this Action, as well

as employees of said Outside Counsel of Record to whom it is reasonably necessary
to disclose the information for this Action;
(b)

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

Receiving Party to whom disclosure is reasonably necessary for this Action;
(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
22
23

(g)

the author or recipient of a document containing the information or a

custodian or other person who otherwise possessed or knew the information;
(h)

during their depositions, witnesses ,and attorneys for witnesses, in the

24

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

25

requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will

26

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
8

HINSHAW & CULBERTSON LLP
633 West 5th Street, 47th Floor
Los Angeles, CA 90071-2043
213-680-2800

STIPULATED PROTECTIVE ORDER

1

deposition testimony or exhibits to depositions that reveal Protected Material may

2

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

3

as permitted under this Stipulated Protective Order; and

4
5

(i)

any mediator or settlement officer, and their supporting personnel,

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

6
7

8.

8

PRODUCED IN OTHER LITIGATION

PROTECTED

MATERIAL

SUBPOENAED

OR

ORDERED

9

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

10

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

11

“CONFIDENTIAL,” that Party must:

12
13
14

(a)

promptly notify in writing the Designating Party. Such notification

shall include a copy of the subpoena or court order;
(b)

promptly notify in writing the party who caused the subpoena or order

15

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

16

subpoena or order is subject to this Protective Order. Such notification shall include

17

a copy of this Stipulated Protective Order; and

18

(c)

cooperate with respect to all reasonable procedures sought to be

19

pursued by the Designating Party whose Protected Material may be affected. If the

20

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

21

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

22

as “CONFIDENTIAL” before a determination by the Court from which the

23

subpoena or order issued, unless the Party has obtained the Designating Party’s

24

permission. The Designating Party shall bear the burden and expense of seeking

25

protection in that court of its confidential material and nothing in these provisions

26

should be construed as authorizing or encouraging a Receiving Party in this Action

27

to disobey a lawful directive from another court.

28
HINSHAW & CULBERTSON LLP
633 West 5th Street, 47th Floor
Los Angeles, CA 90071-2043
213-680-2800

9
STIPULATED PROTECTIVE ORDER

1

9.

A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

2

PRODUCED IN THIS LITIGATION

3

(a)

The terms of this Order are applicable to information produced by a

4

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

5

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

6

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

7

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

8

(b)

In the event that a Party is required, by a valid discovery request, to

9

produce a Non-Party’s confidential information in its possession, and the Party is

10

subject to an agreement with the Non-Party not to produce the Non-Party’s

11

confidential information, then the Party shall:

12

(1)

promptly notify in writing the Requesting Party and the

13

Non-Party that some or all of the information requested is subject to a

14

confidentiality agreement with a Non-Party;

15

(2)

promptly provide the Non-Party with a copy of the

16

Stipulated Protective Order in this Action, the relevant discovery

17

request(s), and a reasonably specific description of the information

18

requested; and (3) make the information requested available for

19

inspection by the Non-Party, if requested.

20

(c)

If the Non-Party fails to seek a protective order from this Court within

21

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

22

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

23

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

24

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

25

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

26

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

27

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

28
HINSHAW & CULBERTSON LLP
633 West 5th Street, 47th Floor
Los Angeles, CA 90071-2043
213-680-2800

10
STIPULATED PROTECTIVE ORDER

1

10.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

2

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

3

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

4

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

5

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

6

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

7

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

8

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

9

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

10
11

11.

12

PROTECTED MATERIAL

INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

13

When a Producing Party gives notice to Receiving Parties that certain

14

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

15

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

16

Procedure 26(b)(5)(B).

17

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

18

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

19

insofar as the parties reach an agreement on the effect of disclosure of a

20

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

21

product protection, the parties may incorporate their agreement in the stipulated

22

protective order submitted to the court.

This provision is not intended to modify whatever

23
24
25
26

12.

MISCELLANEOUS
12.1 Right to Further Relief: Nothing in this Order abridges the right of any

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

27

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

28

Protective Order no Party waives any right it otherwise would have to object to
11

HINSHAW & CULBERTSON LLP
633 West 5th Street, 47th Floor
Los Angeles, CA 90071-2043
213-680-2800

STIPULATED PROTECTIVE ORDER

1

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

2

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

3

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

4

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

5

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

6

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

7

specific Protected Material at issue. If a Party’s request to file Protected Material

8

under seal is denied by the Court, then the Receiving Party may file the information

9

in the public record unless otherwise instructed by the Court.

10
11

13.

FINAL DISPOSITION

12

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

13

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

14

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

15

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

16

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

17

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

18

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

19

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

20

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

21

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

22

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

23

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

24

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

25

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

26

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

27

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

28
HINSHAW & CULBERTSON LLP
633 West 5th Street, 47th Floor
Los Angeles, CA 90071-2043
213-680-2800

12
STIPULATED PROTECTIVE ORDER

1

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

2

Section 4, above (DURATION).

3

14.

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

4

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

5

sanctions.

6

DATED: April 9, 2018

HINSHAW & CULBERTSON LLP

7
8

By: /s/ Sandra I. Weishart
SANDRA I. WEISHART
CHAKAMEH GANJI
Attorneys for Plaintiff and CounterDefendant Monarch Life Insurance
Company

9
10
11
12
13
14
15

DATED: April 9, 2018

NEWMEYER & DILLION LLP
By:

16
17
18
19

/s/ Stephen M. Hauptman
STEPHEN M. HAUPTMAN
Attorney for Defendant and CounterClaimant Robert M. Turner, M.D.

Signature Attestation

20

Pursuant to Local Rule 5-4. 3.4(a)(2)(l), I hereby certify that the content of

21

this document is acceptable to Stephen Hauptman, counsel for Defendant and

22

Counter-Claimant, and that I have obtained Mr. Hauptman’s authorization to affix

23

his electronic signature to this document.

/s/ Sandra I. Weishart
Sandra I. Weishart

24
25
26
27
28
HINSHAW & CULBERTSON LLP
633 West 5th Street, 47th Floor
Los Angeles, CA 90071-2043
213-680-2800

13
STIPULATED PROTECTIVE ORDER

1

ORDER

2
3

FOR GOOD CAUSE SHOWN,

4
5

IT IS SO ORDERED.

6
7
8

DATED:

Honorable Jay C. Gandhi
n
y
Honorable Jay C.
U it d States M i t t J d
United St t Magistrate Judge

9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
HINSHAW & CULBERTSON LLP
633 West 5th Street, 47th Floor
Los Angeles, CA 90071-2043
213-680-2800

14
STIPULATED PROTECTIVE ORDER

1

EXHIBIT A

2

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3
4

I, ____________________________________ [print or type full name], of

5

__________________________________________ [print or type full address],

6

declare under penalty of perjury that I have read in its entirety and understand the

7

Stipulated Protective Order that was issued by the United States District Court for

8

the Central District of California on [date] in the case of Monarch Life Insurance

9

Company v. Robert M. Turner, M.D., United States District Court, Central District

10

of California, Case No. 8:17-cv-01732-JLS-JCG. I agree to comply with and to be

11

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

12

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

13

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

14

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

15

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

16

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

17

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

18

Stipulated Protective Order, even if such enforcement proceedings occur after

19

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

20

full name] of ________________________ [print or type full address and telephone

21

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

22

or any proceedings related to enforcement of this Stipulated Protective Order.

23

Date: ________________________

24

City and State where sworn and signed: _________________________.

25
26
27

Printed name: ____________________

________________________

Signature: _______________________

________________________

28
HINSHAW & CULBERTSON LLP
633 West 5th Street, 47th Floor
Los Angeles, CA 90071-2043
213-680-2800

15
STIPULATED PROTECTIVE ORDER