NE SLI II IPR IDOE EI ELEM AD EGS AME RM TAGE NTE □□□ 3 5 7 UNITED STATES DISTRICT COURT □ 8 CENTRAL DISTRICT OF CALIFORNIA ° CITYSCAPE RENTALS, LLC, a Case No. 2:19-cv-01886-DSF-E 10 || California limited liability company, Assigned to Hon. Dale S. Fischer 11 Plaintiffs, STIPULATED PROTECTIVE vs. ORDER 13 || TRAVELERS CASUALTY 14 AMERICA: YOUNG & OF Complaint Filed: February 6, 2019 15 ASSOCIATES: PARRY through 30, Action Removed: March 14, 2019 16 inclusive, Defendants, Trial Date: None Set 17 18 19 20

22 23 || 1. A. PURPOSES AND LIMITATIONS 24 Discovery in this action is likely to involve production of confidential, 25 || proprietary or private information for which special protection from public 26 || disclosure and from use for any purpose other than prosecuting this litigation may 27 || be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 28 || enter the following Stipulated Protective Order. The parties acknowledge that this

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1 || Order does not confer blanket protections on all disclosures or responses to 2 || discovery and that the protection it affords from public disclosure and use extends 3 || only to the limited information or items that are entitled to confidential treatment 4 || under the applicable legal principles. 5 B. GOOD CAUSE STATEMENT 6 This action is likely to involve commercial, financial, technical and/or __

7 || proprietary information for which special protection from public disclosure and 8 || from use for any purpose other than prosecution of this action is warranted. Such 9 || confidential and proprietary materials and information consist of, among other 10 || things, confidential business or financial information, information regarding 11 || confidential business practices, or other confidential commercial information 12 || (including information implicating privacy rights of third parties), information 13 || otherwise generally unavailable to the public, or which may be privileged or 14 || otherwise protected from disclosure under state or federal statutes, court rules, case 15 || decisions, or common law.. Accordingly, to expedite the flow of information, to 16 || facilitate the prompt resolution of disputes over confidentiality of discovery 17 || materials, to adequately protect information the parties are entitled to keep 18 || confidential, to ensure that the parties are permitted reasonable necessary uses of 19 || such material in preparation for and in the conduct of trial, to address their handling 20 || at the end of the litigation, and serve the ends of justice, a protective order for such 21 || information is justified in this matter. It is the intent of the parties that information 22 || will not be designated as confidential for tactical reasons and that nothing be so 23 || designated without a good faith belief that it has been maintained in a confidential, 24 || non-public manner, and there is good cause why it should not be part of the public 25 || record of this case. . 26 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 27 The parties further acknowledge, as set forth in Section 12.3, below, that this 28 || Stipulated Protective Order does not entitle them to file confidential information

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1 || under seal; Local Civil Rule 79-5 seis forth the procedures that must be followed 2 | and the standards that will be applied when a party seeks permission from the court 3 |! to file material under seal. 4 There is a strong presumption that the public has a right of access to judicial 5 || proceedings and records in civil cases. In connection with non-dispositive motions, 6 || good cause must be shown to support a filing under seal. See Kamakana vy. City and 7 || County of Honolulu,

, 1176 (9th Cir. 2006), Phillips v. Gen. Motors 8 || Corp.,

, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, 9 || Inc.,

(E.D. Wis. 1999) (even stipulated protective orders 10 || require good cause showing), and a specific showing of good cause or compelling 11 || reasons with proper evidentiary support and legal justification, must be made with 12 || respect to Protected Material that a party seeks to file under seal. The parties’ mere 13 || designation of Disclosure or Discovery Material as CONFIDENTIAL does not— 14 || without the submission of competent evidence by declaration, establishing that the 15 |} material sought to be filed under seal qualifies as confidential, privileged, or 16 |} otherwise protectable—constitute good cause. 17 Further, if a party requests sealing related to a dispositive motion or trial, then 18 || compelling reasons, not only good cause, for the sealing must be shown, and the 19 |! relief sought shall be narrowly tailored to serve the specific interest to be protected. 20 || See Pintos v, Pacific Creditors Ass'n,

(9th Cir. 2010). For 21 || each item or type of information, document, or thing sought to be filed or introduced 22 || under seal in connection with a dispositive motion or trial, the party seeking 23 || protection must articulate compelling reasons, supported by specific facts and legal 24 || justification, for the requested sealing order. Again, competent evidence supporting 25 || the application to file documents under seal must be provided by declaration. 26 Any document that is not confidential, privileged, or otherwise protectable in 27 |j its entirety will not be filed under seal if the confidential portions can be redacted. |) Ifdocuments can be redacted, then a redacted version for public viewing, omitting

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1 || only the confidential, privileged, or otherwise protectable portions of the document, 2 || shall be filed. Any application that seeks to file documents under seal in their 3 || entirety should include an explanation of why redaction is not feasible. 4 ||2. DEFINITIONS 5 2.1 Action: Cityscape Rentals, LLC v. Travelers Casualty Insurance 6 || Company of America, et al., United States District Court for the Central District of 7 || California, Case No. 2:19-cv-01886-DSE-E. . 8 2.2 Challenging Party: a Party that challenges the designation of 9 || information or items under this Order. 10 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 11 || how it is generated, stored or maintained) or tangible things that qualify for 12 || protection under Federal Rule of Civil Procedure 26(c), and as specified above in 13 || the Good Cause Statement. 14 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 15 || their support staff). 16 2.5 Designating Party: a Party or Non-Party that designates information or 17 || items that it produces in disclosures or in responses to discovery as 18 || “CONFIDENTIAL.” 19 2.6 Disclosure or Discovery Material: all items or information, regardless 20 || of the medium or manner in which it is generated, stored, or maintained (including, 21 || among other things, testimony, transcripts, and tangible things), that are produced or 22 || generated in disclosures or responses to discovery in this matter. 23 2.7 Expert: a person with specialized knowledge or experience in a matter 24 || pertinent to the litigation who has been retained by a Party or its counsel to serve as 25 || an expert witness or as a consultant in this Action. 26 2.8 House Counsel: attorneys who are employees of a party to this Action. 27 || House Counsel does not include Outside Counsel of Record or any other outside 28 |; counsel.

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1 2.9 Non-Party: any natural person, partnership, corporation, association or _ 2 || other legal entity not named as a Party to this action. 3 2.10 Outside Counsel of Record: attorneys who are not employees of a 4 || party to this Action but are retained to represent or advise a party to this Action and 5 || have appeared in this Action on behalf of that party or are affiliated with a law firm 6 || that has appeared on behalf of that party, and includes support staff. 7 2.11 Party: any party to this Action, including all of its officers, directors, 8 employees, consultants, retained experts, and Outside Counsel of Record (and their 9 || support staffs). — 10 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 11 || Discovery Material in this Action. 12 2.13 Professional Vendors: persons or entities that provide litigation 13 || support services (e.g., photocopying, videotaping, translating, preparing exhibits or 14 || demonstrations, and organizing, storing, or retrieving data in any form or medium) 15 || and their employees and subcontractors. 16 2.14 Protected Material: any Disclosure or Discovery Material that is 17 || designated as “CONFIDENTIAL.” □

18 2.15 Receiving Party: a Party that receives Disclosure or Discovery 19 || Material from a Producing Party. . 20 13. SCOPE 21 The protections conferred by this Stipulation and Order cover not only 22 || Protected Material (as defined above), but also (1) any information copied or 23 || extracted from Protected Material; (2) all copies, excerpts, summaries, or 24 compilations of Protected Material; and (3) any testimony, conversations, or 25 || presentations by Parties or their Counsel that might reveal Protected Material. 26 Any use of Protected Material at trial shall be governed by the orders of the 27 || trial judge. This Order does not govern the use of Protected Material at trial. 28 | /// . a

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1||4. DURATION =

2 Once a case proceeds to trial, information that was designated as 3. || CONFIDENTIAL or maintained pursuant to this protective order used or introduced 4 || as an exhibit at trial becomes public and will be presumptively available to all

5 |] members of the public, including the press, unless compelling reasons supported by 6 || specific factual findings to proceed otherwise are made to the trial judge in advance 7 ll of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “(good cause” 8 || showing for sealing documents produced in discovery from “compelling reasons” 9 || standard when merits-related documents are part of court record). Accordingly, the 10 || terms of this protective order do not extend beyond the commencement of the trial. 11 || 5. DESIGNATING PROTECTED MATERIAL 12 5.1 Exercise of Restraint and Care in Designating Protected Material, 13 Each Party or Non-Party that designates information or items for protection 14 |] under this Order must take care to limit any such designation to specific material 15 || that qualifies under the appropriate standards. The Designating Party must 16 || designate for protection only those parts of material, documents, items or oral or 17 {| written communications that qualify so that other portions of the material, 18 || documents, items or communications for which protection is not warranted are not 19 || swept unjustifiably within the ambit of this Order. 20 If it comes to a Designating Party’s attention that information or items that it 21 || designated for protection do not qualify for protection, that Designating Party must 22 || promptly notify all other Parties that it is withdrawing the inapplicable designation. 23 5.2. Manner and Timing of Designations. Except as otherwise provided in 24 || this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 25 || stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 26 || under this Order must be clearly so designated before the material is disclosed or 27 || produced. — 28 Designation in conformity with this Order requires:

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1 (a) for information in documentary form (e.g., paper or electronic 2 || documents, but excluding transcripts of depositions or other pretrial or trial 3 || proceedings), that the Producing Party affix at a minimum, the legend 4 || “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 5 || contains protected material. If only a portion of the material on a page qualifies for 6 || protection, the Producing Party also must clearly identify the protected portion(s) 7 || (e.g., by making appropriate markings in the margins). 8 A Party or Non-Party that makes original documents available for inspection 9 || need not designate them for protection until after the inspecting Party has indicated || which documents it would like copied and produced, During the inspection and 11 || before the designation, all of the material made available for inspection shall be 12 || deemed “CONFIDENTIAL.” After the inspecting Party has identified the

13 || documents it wants copied and produced, the Producing Party must determine which 14 || documents, or portions thereof, qualify for protection under this Order. Then, 15 || before producing the specified documents, the Producing Party must affix the 16 || “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 17 || portion of the material on a page qualifies for protection, the Producing Party also 18 || must clearly identify the protected portion(s) (e.g., by making appropriate markings 19 || in the margins). 20 (b) for testimony given in depositions that the Designating Party identifies 21 || the Disclosure or Discovery Material on the record, before the close of the 22 || deposition all protected testimony. 23 (c) for information produced in some form other than documentary and 24 || for any other tangible items, that the Producing Party affix in a prominent place on 25 || the exterior of the container or containers in which the information is stored the 26 || legend “CONFIDENTIAL.” If only a portion or portions of the information 27 || warrants protection, the Producing Party, to the extent practicable, shall identify the 28 . || protected portion(s).

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1 5.3 Inadvertent Failures to Design ate. If timely corrected, an inadvertent 2 || failure to designate qualified information or items does not, standing alone, waive 3 || the Designating Party’s right to secure protection under this Order for such material. 4 || Upon timely correction of a designation, the Receiving Party must make reasonable 5 || efforts to assure that the material is treated in accordance with the provisions of this 6 || Order. 7 □□ □□ CHALLENGING CONFIDENTIALITY DESIGNATIONS 8 6.1 Timing of Challenges, Any Party may challenge a designation of 9 || confidentiality at any time that is consistent with the Court’s Scheduling Order. 10 6.2 Meetand Confer. The Challenging Party shall initiate the dispute 11 || resolution process under Local Rule 37.1 et seq. 12 6.3. The burden of persuasion in any such challenge proceeding shall be on 13 || the Designating Party. Frivolous challenges, and those made for an improper 14 || purpose (e.g., to harass or impose unnecessary expenses and burdens on other 15 |] parties) may expose the Challenging Party to sanctions. Unless the Designating 16 || Party has waived or withdrawn the confidentiality designation, all parties shall 17 || continue to afford the material in question the level of protection to which it is 18 || entitled under the Producing Party’s designation until the Court rules on the 19 || challenge. . 20 || 7. ACCESS TO AND USE OF PROTECTED MATERIAL 21 7.1 Basic Principles. A Receiving Party may use Protected Material that is 22 || disclosed or produced by another Party or by a Non-Party in connection with this 23 |) Action only for prosecuting, defending or attempting to settle this Action. Such 24 || Protected Material may be disclosed only to the categories of persons and under the 25 || conditions described in this Order.. When the Action has been terminated, a 26 |} Receiving Party must comply. with the provisions of section 13 below (FINAL 27 || DISPOSITION). .. . 28 ‘ Protected Material must be stored and maintained by a Receiving Party at a

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1 || location and in a secure manner that ensures that access is limited to the persons 2 || authorized under this Order. 3 7.2 Disclosure of “CONFIDEN TIAL ”* Information or Items. Unless 4 || otherwise ordered by the court or permitted in writing by the Designating Party, a 5 || Receiving Party may disclose any information or item designated 6 || “CONFIDENTIAL” only to: 7 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 8 || well as employees of said Outside Counsel of Record to whom it is reasonably 9 || necessary to disclose the information for this Action; 10 (b) the officers, directors, and employees (including House Counsel) of 11 || the Receiving Party to whom disclosure is reasonably necessary for this Action; 12 (c) Experts (as defined in this Order) of the Receiving Party to whom 13 || disclosure is reasonably necessary for this Action and who have signed the 14 || “Acknowledgment and Agreement to Be Bound” (Exhibit A); 15 (d) the court and its personne]; 16 (e) court reporters and their staff; . 17 (f) professional jury or trial consultants, mock jurors, and Professional 18 || Vendors to whom disclosure is reasonably necessary for this Action and who have 19 || signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 20 (g) the author or recipient of a document containing the information or a 21 || custodian or other person who otherwise possessed or knew the information; 22 (h) during their depositions, witnesses, and attorneys for witnesses, in the 23 || Action to whom disclosure is reasonably necessary provided: (1) the deposing party 24 || requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will 25 || not be permitted to keep any confidential information unless they sign the . 26 || “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 27 |) agreed by the Designating Party or ordered by the court. Pages of transcribed 28 || deposition testimony or exhibits to depositions that reveal Protected Material may

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1 || be separately bound by the court reporter and may not be disclosed to anyone except 2 || as permitted under this Stipulated Protective Order; and 3 (i) any mediator or settlement officer, and their supporting personnel, 4 || mutually agreed upon by any of the parties engaged in settlement discussions. 5 || 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 6 IN OTHER LITIGATION. 7 If a Party is served with a subpoena or a court order issued in other litigation 8 || that compels disclosure of any information or items designated in this Action as 9 || “CONFIDENTIAL,” that Party must: 10 (a) promptly notify in writing the Designating Party. Such notification 11 || shall include a copy of the subpoena or court order; 12 (b) promptly notify in writing the party who caused the subpoena or order 13 || to issue in the other. litigation, that some or all of the material covered by the 14 || subpoena or order is subject to this Protective Order. Such notification shall include 15 || acopy of this Stipulated Protective Order; and 16 (c) cooperate with respect to all reasonable procedures sought to be 17 || pursued by the Designating Party whose Protected Material may be affected. 18 If the Designating Party timely seeks a protective order, the Party served with 19 || the subpoena or court order shall not produce any information designated in this 20 || action as “CONFIDENTIAL” before a determination by the court from which the 21 || subpoena or order issued, unless the Party has obtained the Designating Party’s 22 || permission. The Designating Party shall bear the burden and expense of seeking 23 || protection in that court of its confidential material and nothing in these provisions 24 || should be construed as authorizing or encouraging a Receiving Party in this Action 25 || to disobey a lawful directive from another court. 26 11/9. ANON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 27 PRODUCED IN THIS LITIGATION 28 (a) The terms of this Order are applicable to information produced by a 10

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1 || Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 2 || produced by Non-Parties in connection with this litigation is protected by the 3 || remedies and relief provided by this Order. Nothing in these provisions should be 4 || construed as prohibiting a Non-Party from seeking additional protections. 5 (b) In the event that a Party is required, by a valid discovery request, to 6 || produce a Non-Party’s confidential information in its possession, and the Party is 7 || subject to an agreement with the Non-Party not to produce the Non-Party’s 8 || confidential information, then the Party shall: 9 (1) promptly notify in writing the Requesting Party and the Non-Party 10 || that some or all of the information requested is subject to a confidentiality 11 || agreement with a Non-Party; 12 (2) promptly provide the Non-Party with a copy of the Stipulated 13 || Protective Order in this Action, the relevant discovery request(s), and a reasonably 14 || specific description of the information requested; and 15 (3) make the information requested available for inspection by the 16 || Non-Party, if requested. 17 (c) If the Non-Party fails to seek a protective order from this court within 18 || 14 days of receiving the notice and accompanying information, the Receiving Party 19 || may produce the Non-Party’s confidential information responsive to the discovery 20 || request. Ifthe Non-Party timely seeks a protective order, the Receiving Party shall 21 || not produce any information in its possession or control that is subject to the 22 || confidentiality agreement with the Non-Party before a determination by the court. 23 || Absent a court order to the contrary, the Non-Party shall bear the burden and 24 || expense of seeking protection in this court of its Protected Material. 25 || 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 26 . If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 27 || Protected Material to any person or in any circumstance not authorized under this 28 || Stipulated Protective Order, the Receiving Party must immediately (a) notify in 11

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1 || writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 2 || to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 3 || persons to whom unauthorized disclosures were made of all the terms of this Order, 4 || and (d) request such person or persons to execute the “Acknowledgment and □ 5 || Agreement to Be Bound” that is attached hereto as Exhibit A. 6 || 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 7 PROTECTED MATERIAL |

8 When a Producing Party gives notice to Receiving Parties that certain 9 || inadvertently produced material is subject to a claim of privilege or other protection, 10 || the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 11 || Procedure 26(b)(5)(B). 12 || 12. “MISCELLANEOUS 13 12.1 Right to Further Relief, Nothing in this Order abridges the right of any 14 || person to seek its modification by the Court in the future. 15 12.2 Right to Assert Other Objections. By stipulating to the entry of this 16 || Protective Order, no Party waives any right it otherwise would have to object to 17 || disclosing or producing any information or item on any ground not addressed in this 18 || Stipulated Protective Order. Similarly, no Party waives any right to object on any 19 || ground to use in evidence of any of the material covered by this Protective Order. 20 12.3 Filing Protected Material. A Party that seeks to file under seal any 21 || Protected Material must comply with Local Civil Rule 79-5. Protected Material 22 |) may only be filed under seal pursuant to a court order authorizing the sealing of the 23 || specific Protected Material at issue. If a Party’s request to file Protected Material 24 || under seal is denied by the court, then the Receiving Party may file the information 25 || in the public record unless otherwise instructed by the court. 26 || 13. FINAL DISPOSITION 27 After the final disposition of this Action, as defined in paragraph 4, within 60 28 || days of a written request, by the Designating Party, each Receiving Party must return 12

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1 || all Protected Material to the Producing Party or destroy such material. As used in 2 || this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 3 || summaries, and any other format reproducing or capturing any of the Protected 4 || Material. Whether the Protected Material is returned or destroyed, the Receiving 5 || Party must submit a written certification to the Producing Party (and, if not the same 6 || person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 7 || (by category, where appropriate) all the Protected Material that was returned or 8 || destroyed and (2) affirms that the Receiving Party has not retained any copies, 9 || abstracts, compilations, summaries or any other format reproducing or capturing any 10 || of the Protected Material. Notwithstanding this provision, Counsel are entitled to 11 || retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 12 || transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 13 || reports, attorney work product, and consultant and expert work product, even if such 14 || materials contain Protected Material. Any such archival copies that contain or 15 || constitute Protected Material remain subject to this Protective Order as set forth in 16 || Section 4 (DURATION). . 17 || 14. VIOLATION 18 || Any violation of this Order may be punished by appropriate measures including, 19 || without limitation, contempt proceedings and/or monetary sanctions. 20 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD. 21 . 22 || DATED October 19, 2019 23

35 Atto for Plaintiff Cityscape Rentals, LLC 26 27 28 13

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IE 1 || DATED: Gcteber 13 , 2019 3 | Dad Me“ Attorneys for Defendant Travelers Casualty 4 || Insurance Company of America 5 . FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

DATED: _/2/23//2 0 11 ON. CHARLES F. EICK United States Magistrate Judge 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 14

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1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 4 iI, [print or type full name], of 5 || [print or type full address], declare under penalty of perjury that I have read in its 6 || entirety and understand the Stipulated Protective Order that was issued by the 7 || United States District Court for the Central District of California on [date] in the 8 || case of Cityscape Rentals, LLC v. Travelers Casualty Insurance Company of 9 || America, et al., United States District Court for the Central District of California, 10 |} Case No. 2:19-cv-01886-DSF-E. I agree to comply with and to be bound by all the 11 |} terms of this Stipulated Protective Order and I understand and acknowledge that 12 || failure to so comply could expose me to sanctions and punishment in the nature of 13 || contempt. I solemnly promise that I will not disclose in any manner any 14 || information or item that is subject to this Stipulated Protective Order to any person 15 || 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 for the 17 |} Central District of California for enforcing the terms of this Stipulated Protective 18 || Order, even if such enforcement proceedings occur after termination of this action. 19 || [hereby appoint [print or type full name] of 20 [print or type full address and 21 || telephone number] as my California agent for service of process in connection with 22 || this action or any proceedings related to enforcement of this Stipulated Protective 23 |} Order. 24 || Date: . __ 25 || City and State where sworm and signed: 26 || Printed name: _ 27 28 || Signature: 15