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)

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1 SANDRA I. WEISHART (SBN 89792) 2 CHAKAMEH GANJI (SBN 311720) 3 Hinshaw & Culbertson LLP 633 West 5th Street, 47th Floor 4 Los Angeles, CA 90071-2043 Telephone: 213-680-2800 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

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