1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10

_ | CMB DEVELOPERS INC., a California Case No. 2:19-cv-09973 SVW (RAOx) 8 corporation, 3 Plaintiff, STIPULATED PROTECTIVE v. ORDER '

225 15 | AMTRUST FINANCIAL SERVICES, INC.) Filing Date: October 21, 2019 AMTRUST NORTH AMERICA, INC., a 32 16 | Delaware corporation, and DOES | through 100, inclusive, Defendants. = 18 S19 20/1. A. PURPOSES AND LIMITATIONS 21 Discovery in this action is likely to involve production of confidential, 22 proprietary or private information for which special protection from public disclosure 23 land from use for any purpose other than prosecuting this litigation may be warranted. 24 Accordingly, the parties hereby stipulate to and petition the Court to enter the following 25 Stipulated Protective Order. The parties acknowledge that this Order does not confer 26 27 28 ' This Stipulated Protective Order is substantially based on the model protective order provided under Magistrate Judge Rozella A. Oliver’s Procedures. STIPULATED PROTECTIVE ORDER

1 | blanket protections on all disclosures or responses to discovery and that the protection 2 | it affords from public disclosure and use extends only to the limited information or items 3 | that are entitled to confidential treatment under the applicable legal principles. 4 B. GOOD CAUSE STATEMENT 5 This action involves trade secrets, information regarding confidential business 6 | practices, or other confidential research, development, or commercial information 7 | generally unavailable to the public, and which is privileged or otherwise protected from 8 | disclosure under state or federal statutes, court rules, case decisions, or common law. 9 | Specifically, Plaintiff has requested that Defendant produce documents that 10 | constitute proprietary claim handling guidelines. Accordingly, to expedite the flow 11 | of information, to facilitate the prompt resolution of disputes over confidentiality of 12 | discovery materials, to adequately protect information the parties are entitled to keep be 13 | confidential, to ensure that the parties are permitted reasonable necessary uses of such : 14 | material in preparation for and in the conduct of trial, to address their handling at the 3 13 of the litigation, and serve the ends of justice, a protective order for such ae 16 | information is justified in this matter. It is the intent of the parties that information will 17 not be designated as confidential for tactical reasons and that nothing be so designated 18 | without a good faith belief that it has been maintained in a confidential, non-public 19 manner, and there is good cause why it should not be part of the public record of this 20 | case. 21 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 22 The parties further acknowledge, as set forth in Section 12.3, below, that this 23 | Stipulated Protective Order does not entitle them to file confidential information under 24 seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the 25 | standards that will be applied when a party seeks permission from the court to file 26 | material under seal. 27 There is a strong presumption that the public has a right of access to judicial 28 STIPULATED PROTECTIVE ORDER

1 | proceedings and records in civil cases. In connection with non-dispositive motions, 2 | good cause must be shown to support a filing under seal. See Kamakana v. City and 3 | County of Honolulu,

(9th Cir. 2006); Phillips v. Gen. Motors 4 | Corp.,

, 1210-11 (9th Cir. 2002); Makar-Welbon v. Sony Electrics, Inc., 5

, 577 (E.D. Wis. 1999) (even stipulated protective orders require good 6 cause showing), and a specific showing of good cause or compelling reasons with 7 proper evidentiary support and legal justification, must be made with respect to 8 | Protected Material that a party seeks to file under seal. The parties’ mere designation 9 lof Disclosure or Discovery Material as CONFIDENTIAL does not—without the 10 | submission of competent evidence by declaration, establishing that the material sought , 1! |to be filed under seal qualifies as confidential, privileged, or otherwise protectable— 12 | constitute good cause. 13 Further, if a party requests sealing related to a dispositive motion or trial, then : 14 | compelling reasons, not only good cause, for the sealing must be shown, and the relief 13 | sought shall be narrowly tailored to serve the specific interest to be protected. See ae 16 | Pintos v. Pacific Creditors Ass’n,

(9th Cir. 2010). For each item 17 or type of information, document, or thing sought to be filed or introduced under seal 18 | in connection with a dispositive motion or trial, the party seeking protection must 19 articulate compelling reasons, supported by specific facts and legal justification, for the 20 | requested sealing order. Again, competent evidence supporting the application to file 21 | documents under seal must be provided by declaration. 22 Any document that is not confidential, privileged, or otherwise protectable in its 23 | entirety will not be filed under seal if the confidential portions can be redacted. If 24 | documents can be redacted, then a redacted version for public viewing, omitting only 25 | the confidential, privileged, or otherwise protectable portions of the document shall be 26 | filed. Any application that seeks to file documents under seal in their entirety should 27 | include an explanation of why redaction is not feasible. 28 STIPULATED PROTECTIVE ORDER

2. DEFINITIONS 2 2.1 Action: this captioned federal lawsuit; there are no related actions. 3 2.2 Challenging Party: a Party or Non-Party that challenges the designation of 4 information or items under this Order. 5 2.3. “CONFIDENTIAL” Information or Items: information (regardless of how 6 it is generated, stored or maintained) or tangible things that qualify for 7 protection under Federal Rule of Civil Procedure 26(c), and as specified 8 above in the Good Cause Statement. 9 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 10 support staff). 1] 2.5 Designating Party: a Party or Non-Party that designates information or 12 items that it produces in disclosures or in responses to discovery as as} “CONFIDENTIAL.” 14 2.6 Disclosure or Discovery Material: all items or information, regardless of 15 the medium or manner in which it is generated, stored, or maintained 16 (including, among other things, testimony, transcripts, and tangible 17 things), that are produced or generated in disclosures or responses to 18 discovery in this matter. 19 2.7. Expert: a person with specialized knowledge or experience in a matter 20 pertinent to the litigation who has been retained by a Party or its counsel 21 to serve as an expert witness or as a consultant in this Action. 2.8 House 22 Counsel: attorneys who are employees of a party to this Action. House 23 Counsel does not include Outside Counsel of Record or any other outside 24 counsel. 25 2.9 Non-Party: any natural person, partnership, corporation, association, or 26 other legal entity not named as a Party to this action. 27 2.8 House Counsel: attorneys who are employees of a party to this Action. 28 STIPULATED PROTECTIVE ORDER

| House Counsel does not include Outside Counsel of Record or any other 2 outside counsel. 3 2.9 Non-Party: any natural person, partnership, corporation, association, or 4 other legal entity not named as a Party to this action. 5 2.10 Outside Counsel of Record: attorneys who are not employees of a party to 6 this Action but are retained to represent or advise a party to this Action and 7 have appeared in this Action on behalf of that party or are affiliated with a 8 law firm which has appeared on behalf of that party, and includes support 9 staff. 10 2.11 Party: any party to this Action, including all of its officers, directors, 1 employees, consultants, retained experts, and Outside Counsel of Record 12 (and their support staffs). be 13 2.12 Producing Party: a Party or Non-Party that produces Disclosure or : 14 Discovery Material in this Action. 5 3 15 2.13 Professional Vendors: persons or entities that provide litigation support 16 services (e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and organizing, storing, or retrieving data in any form 18 or medium) and their employees and subcontractors. 19 2.14 Protected Material: any Disclosure or Discovery Material that is designated 20 as “CONFIDENTIAL.” 21 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material from 22 a Producing Party. 23,13. SCOPE 24 The protections conferred by this Stipulation and Order cover not only Protected 25 | Material (as defined above), but also (1) any information copied or extracted from 26 | Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 27 | Material; and (3) any testimony, conversations, or presentations by Parties or their 28 STIPULATED PROTECTIVE ORDER

1 | Counsel that might reveal Protected Material. 2 Any use of Protected Material at trial shall be governed by the orders of the trial 3 | judge. This Order does not govern the use of Protected Material at trial. 4 DURATION 6 Even after final disposition of this litigation, the confidentiality obligations 7 |imposed by this Order shall remain in effect until a Designating Party agrees otherwise 8 | in writing or a court order otherwise directs. Final disposition shall be deemed to be the 9 | later of (1) dismissal of all claims and defenses in this Action, with or without prejudice; 10 and (2) final judgment herein after the completion and exhaustion of all appeals, 11 | rehearings, remands, trials, or reviews of this Action, including the time limits for filing 12 | any motions or applications for extension of time pursuant to applicable law.

S<8 14 15. DESIGNATING PROTECTED MATERIAL 256 15 5.1 Exercise of Restraint Care in Designating Material for Protection. ae 16 | Each Party or Non-Party that designates information or items for protection under this a 17 | Order must take care to limit any such designation to specific material that qualifies 18 | under the appropriate standards. The Designating Party must designate for protection only those parts of material, documents, items, or oral or written communications that 20 | qualify so that other portions of the material, documents, items, or communications for 21 | which protection is not warranted are not swept unjustifiably within the ambit of this 22 | Order. 23 Mass, indiscriminate, or routinized designations are prohibited. Designations that 24 are shown to be clearly unjustified or that have been made for an improper purpose 25 I(e.g., to unnecessarily encumber the case development process or to impose 26 | unnecessary expenses and burdens on other parties) may expose the Designating Party 27 | to sanctions. 28 STIPULATED PROTECTIVE ORDER

| If it comes to a Designating Party’s attention that information or items that it 2 | designated for protection do not qualify for protection, that Designating Party must 3 | promptly notify all other Parties that it is withdrawing the inapplicable designation. 4 5.2 Manner and Timing of Designations. Except as otherwise provided in this 5 | Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated 6 lor ordered, Disclosure or Discovery Material that qualifies for protection under this 7 | Order must be clearly so designated before the material is disclosed or produced. 8 Designation in conformity with this Order requires: 9 (a) for information in documentary form (e.g., paper or electronic documents, 10 but excluding transcripts of depositions or other pretrial or trial , i proceedings), that the Producing Party affix at a minimum, the legend 12 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend’), to each 13 page that contains protected material. If only a portion or portions of the : 14 material on a page qualifies for protection, the Producing Party also must 3 15 clearly identify the protected portion(s) (e.g., by making appropriate ae 16 markings in the margins). a 17 A Party or Non-Party that makes original documents available for inspection 18 need not designate them for protection until after the inspecting Party has indicated 19 which documents it would like copied and produced. During the inspection and before 20 | the designation, all of the material made available for inspection shall be deemed 21 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 22 | copied and produced, the Producing Party must determine which documents, or portions 23 | thereof, qualify for protection under this Order. Then, before producing the specified 24 | documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page 25 | that contains Protected Material. If only a portion or portions of the material on a page 26 | qualifies for protection, the Producing Party also must clearly identify the protected 27 | portion(s) (e.g., by making appropriate markings in the margins). 28 STIPULATED PROTECTIVE ORDER

| (b) for testimony given in depositions that the Designating Party identify the 2 Disclosure or Discovery Material on the record, before the close of the 3 deposition all protected testimony. 4 (c) for information produced in some form other than documentary and for 5 any other tangible items, that the Producing Party affix in a prominent 6 place on the exterior of the container or containers in which the 7 information is stored the legend “CONFIDENTIAL.” If only a portion or 8 portions of the information warrants protection, the Producing Party, to the 9 extent practicable, shall identify the protected portion(s). 10 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 11 | failure to designate qualified information or items does not, standing alone, waive the 12 | Designating Party’s right to secure protection under this Order for such material. Upon be 13 | timely correction of a designation, the Receiving Party must make reasonable efforts to : 14 | assure that the material is treated in accordance with the provisions of this Order. 5 3 ID 16. CHALLENGING CONFIDENTIALITY DESIGNATIONS ae 16 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation of confidentiality at any time that is consistent with the Court’s Scheduling 18 | Order. 19 6.2 Meet _and Confer. The Challenging Party shall initiate the dispute 20 | resolution process under Local Rule 37.1 et seq. 21 6.3. The burden of persuasion in any such challenge proceeding shall be on the 22 | Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., 23 | to harass or impose unnecessary expenses and burdens on other parties) may expose the 24 | Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn 25 |the confidentiality designation, all parties shall continue to afford the material in 26 | question the level of protection to which it is entitled under the Producing Party’s 27 | designation until the Court rules on the challenge. 28 STIPULATED PROTECTIVE ORDER

117. ACCESS TO AND USE OF PROTECTED MATERIAL 2 7.1 Basic Principles. A Receiving Party may use Protected Material that is 3 | disclosed or produced by another Party or by a Non-Party in connection with this Action 4 lonly for prosecuting, defending, or attempting to settle this Action. Such Protected 5 | Material may be disclosed only to the categories of persons and under the conditions 6 | described in this Order. When the Action has been terminated, a Receiving Party must 7 | comply with the provisions of section 13 below (FINAL DISPOSITION). 8 Protected Material must be stored and maintained by a Receiving Party at a 9 location and in a secure manner that ensures that access is limited to the persons 10 | authorized under this Order. , i 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise 12 | ordered by the court or permitted in writing by the Designating Party, a Receiving Party 13 | may disclose any information or item designated “CONFIDENTIAL” only to: 14 (a) 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 16 | disclose the information for this Action; (b) the officers, directors, and employees (including House Counsel) of the 18 | Receiving Party to whom disclosure is reasonably necessary for this Action; 19 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure 20 | is reasonably necessary for this Action and who have signed the “Acknowledgment and 21 | Agreement to Be Bound” (Exhibit A); 22 (d) the court and its personnel; 23 (e) court reporters and their staff; 24 (f) professional jury or trial consultants, mock jurors, and Professional Vendors 25 |to whom disclosure is reasonably necessary for this Action and who have signed the 26 |“Acknowledgment and Agreement to Be Bound” (Exhibit A); 27 (g) the author or recipient of a document containing the information or a 28 STIPULATED PROTECTIVE ORDER

1 | custodian or other person who otherwise possessed or knew the information; 2 (h) during their depositions, witnesses, and attorneys for witnesses, in the Action 3 |to whom disclosure is reasonably necessary provided: (1) the deposing party requests 4 | that the witness sign the form attached as Exhibit A hereto; and (2) they will not be 5 | permitted to keep any confidential information unless they sign the “Acknowledgment 6 | and Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating 7 | Party or ordered by the court. Pages of transcribed deposition testimony or exhibits to 8 | depositions that reveal Protected Material may be separately bound by the court reporter 9 | and may not be disclosed to anyone except as permitted under this Stipulated Protective 10 | Order; and , i (1) any mediator or settlement officer, and their supporting personnel, mutually 12 | agreed upon by any of the parties engaged in settlement discussions.

13/8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN : 14 | OTHER LITIGATION 5 3 15 If a Party is served with a subpoena or a court order issued in other litigation that ae 16 compels disclosure of any information or items designated in this Action as 17 “CONFIDENTIAL,” that Party must: 18 (a) promptly notify in writing the Designating Party. Such notification shall 19 include a copy of the subpoena or court order; 20 (b) promptly notify in writing the party who caused the subpoena or order to issue 21 | in the other litigation that some or all of the material covered by the subpoena or order 22 lis subject to this Protective Order. Such notification shall include a copy of this 23 | Stipulated Protective Order; and 24 (c) cooperate with respect to all reasonable procedures sought to be pursued by 25 | the Designating Party whose Protected Material may be affected. 26 If the Designating Party timely seeks a protective order, the Party served with the 27 | subpoena or court order shall not produce any information designated in this action as 28 10 STIPULATED PROTECTIVE ORDER

1 | “CONFIDENTIAL” before a determination by the court from which the subpoena or 2 | order issued, unless the Party has obtained the Designating Party’s permission. The 3 | Designating Party shall bear the burden and expense of secking protection in that court 4 | of its confidential material and nothing in these provisions should be construed as 5 | authorizing or encouraging a Receiving Party in this Action to disobey a lawful directive 6 | from another court. 7 8 19. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED 9 TIN THIS LITIGATION 10 (a) The terms of this Order are applicable to information produced by a NonParty , Jin this Action and designated as “CONFIDENTIAL.” Such information produced by 12 | Non-Parties in connection with this litigation is protected by the remedies and relief

13 | provided by this Order. Nothing in these provisions should be construed as prohibiting : 14 | a Non-Party from seeking additional protections. 5 3 15 (b) In the event that a Party is required, by a valid discovery request, to produce ae 16 | a Non-Party’s confidential information in its possession, and the Party is subject to an agreement with the Non-Party not to produce the Non-Party’s confidential information, 18 | then the Party shall: 19 (1) promptly notify in writing the Requesting Party and the Non-Party that 20 | some or all of the information requested is subject to a confidentiality agreement with 21 | a Non-Party; 22 (2) promptly provide the Non-Party with a copy of the Stipulated 23 | Protective Order in this Action, the relevant discovery request(s), and a reasonably 24 | specific description of the information requested; and 25 (3) make the information requested available for inspection by the Non- 26 | Party, if requested. 27 (c) If the Non-Party fails to seek a protective order from this court within 14 days 28 11 STIPULATED PROTECTIVE ORDER

1 | of receiving the notice and accompanying information, the Receiving Party may 2 | produce the Non-Party’s confidential information responsive to the discovery request. 3 | If the Non-Party timely secks a protective order, the Receiving Party shall not produce 4 any information in its possession or control that is subject to the confidentiality 5 | agreement with the Non-Party before a determination by the court. Absent a court order 6 | to the contrary, the Non-Party shall bear the burden and expense of secking protection 7 lin this court of its Protected Material. 8 9110. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 10 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed , Protected Material to any person or in any circumstance not authorized under this 12 | Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 13 | the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve : 14 | all unauthorized copies of the Protected Material, (c) inform the person or persons to 5 3 15 | whom unauthorized disclosures were made of all the terms of this Order, and (d) request ae 16 | such person or persons to execute the “Acknowledgment and Agreement to Be Bound” 17 that is attached hereto as Exhibit A.

19 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 20 | PROTECTED MATERIAL 21 When a Producing Party gives notice to Receiving Parties that certain 22 | inadvertently produced material is subject to a claim of privilege or other protection, 23 | the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 24 | Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 25 | may be established in an e-discovery order that provides for production without prior 26 | privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 27 parties reach an agreement on the effect of disclosure of a communication or 28 12 STIPULATED PROTECTIVE ORDER

1 | information covered by the attorney-client privilege or work product protection, the 2 | parties may incorporate their agreement in the stipulated protective order submitted to 3 | the court. 4 5112. MISCELLANEOUS 6 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 7 | person to seek its modification by the Court in the future. 8 12.2 Right to Assert Other Objections. By stipulating to the entry of this 9 Protective Order no Party waives any right it otherwise would have to object to 10 | disclosing or producing any information or item on any ground not addressed in this 11 | Stipulated Protective Order. Similarly, no Party waives any right to object on any 12 | ground to use in evidence of any of the material covered by this Protective Order.

13 12.3 Filing Protected Material. A Party that seeks to file under seal any Protected : 14 | Material must comply with Civil Local Rule 79-5. Protected Material may only be filed 13 | under seal pursuant to a court order authorizing the sealing of the specific Protected ae 16 | Material at issue. If a Party's request to file Protected Material under seal is denied by the court, then the Receiving Party may file the information in the public record unless 18 | otherwise instructed by the court. S19 20 113. FINAL DISPOSITION 21 After the final disposition of this Action, as defined in paragraph 4, within 60 22 | days of a written request by the Designating Party, each Receiving Party must return all 23 | Protected Material to the Producing Party or destroy such material. As used in this 24 | subdivision, “all Protected Material” includes all copies, abstracts, compilations, 25 |summaries, and any other format reproducing or capturing any of the Protected 26 | Material. Whether the Protected Material is returned or destroyed, the Receiving Party 27 | must submit a written certification to the Producing Party (and, if not the same person 28 13 STIPULATED PROTECTIVE ORDER

1 | or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by 2 | category, where appropriate) all the Protected Material that was returned or destroyed 3 land (2)affirms that the Receiving Party has not retained any copies, abstracts, 4 | compilations, summaries or any other format reproducing or capturing any of the 5 | Protected Material. Notwithstanding this provision, Counsel are entitled to retain an 6 | archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, 7 | legal memoranda, correspondence, deposition and trial exhibits, expert reports, attorney 8 | work product, and consultant and expert work product, even if such materials contain 9 |Protected Material. Any such archival copies that contain or constitute Protected 10 | Material remain subject to this Protective Order as set forth in Section 4 (DURATION). uly 12 | // 3 |/ 14 | // gee IS | //

18 | S19 20 21 | // 22 | // 23 | // 24 | // 25 | // 26 | // 27 28 14 STIPULATED PROTECTIVE ORDER

| 14. Any violation of this Order may be punished by any and all appropriate 2 |measures including, without limitation, contempt proceedings and/or monetary 3 | sanctions. 4 5 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 6 7 |DATED _ 5/11/21 8 9 /s/ Sohaila Sagheb 10 | Attorneys for Plaintiff

|DATED: 5/11/21 2 13

l4]__/s/ Katy A. Nelson 8 15 | Attorneys for Defendant £23 16

@~ 17 | FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 2 18 ~ 19 | DATED: May 14, 2021 20 . Rapella Ga. QOC— 21 22 | HON. ROZELLA A. OLIVER 53 United States Magistrate Judge 24 25 26 27 28 15 STIPULATED PROTECTIVE ORDER

EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, [print or type full name], of 4 [print or type full address], declare under penalty of perjury that I 5 | have read in its entirety and understand the Stipulated Protective Order that was issued 6 |by the United States District Court for the Central District of California on 7 in the case of CMB Developers, Inc. v. United Specialty Insurance 8 | Company, Case No. 2:19-cv-09973 SVW (RAOx), I agree to comply with and to be 9 |bound by all the terms of this Stipulated Protective Order and I understand and 10 | 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 12 | information or item that is subject to this Stipulated Protective Order to any person or 13 | entity except in strict compliance with the provisions of this Order. I further agree to : 14 | submit to the jurisdiction of the United States District Court for the Central District of 13 | California for the purpose of enforcing the terms of this Stipulated Protective Order, 16 | even if such enforcement proceedings occur after termination of this action. I hereby appoint [print or type full name] of 18 [print or type full address and 19 telephone number] as my California agent for service of process in connection with this 20 | action or any proceedings related to enforcement of this Stipulated Protective Order. 21 | Date: 22 |City and State where sworn and signed: 23 | Printed name: 24 25 | Signature: 26 27 28 16 STIPULATED PROTECTIVE ORDER