Case 2:21-cv-00914-AB-AFM Document 48 Filed 06/10/22 Page 1 of 17 Page ID #:538

1 Ophir Johna (SBN CA 228193) [email protected] 2 Vivian I. Orlando (SBN CA 213833) [email protected] 3 MAYNARD COOPER & GALE 10100 Santa Monica Boulevard, Suite 550 4 Los Angeles, CA 90067 Telephone: (310) 596-4500 5 Attorneys for Defendant 6 Primerica Life Insurance Company

7 8 UNITED STATES DISTRICT COURT

9 CENTRAL DISTRICT OF CALIFORNIA 10

11 JAYSON D. PALMER, JUDITH Case No. 2:21-cv-00914-AB PALMER, AND JENNIFER (AFMx) 12 WITHERSPOON, 13 Plaintiff,

STIPULATED PROTECTIVE 14 vs. ORDER REGARDING NON- DISCLOSURE OF 15 PRIMERICA LIFE INSURANCE CONFIDENTIAL 16 COMPANY, I NFORMATION1

17 Defendant. Complaint Filed: February 1, 2021 18 19 1. A. PURPOSES AND LIMITATIONS 20 Discovery and disclosures in this action are likely to involve production of 21 confidential, proprietary and/or private information for which special protection from 22 public disclosure and from use for any purpose other than prosecuting this litigation 23 may be warranted. Accordingly, the parties hereby stipulate to and petition the Court 24 to enter the following Stipulated Protective Order. The parties acknowledge that this 25 Order does not confer blanket protections on all disclosures or responses to discovery 26 27 1 This Stipulated Protective Order is based substantially on the model protective order provided under Magistrate Judge Alexander F. MacKinnon’s Procedures. 28 1 Case 2:21-cv-00914-AB-AFM Document 48 Filed 06/10/22 Page 2 of 17 Page ID #:539

1 and that the protection it affords from public disclosure and use extends only to the 2 limited information or items that are entitled to confidential treatment under the 3 applicable legal principles. 4 5 B. GOOD CAUSE STATEMENT This action is likely to involve trade secrets and/or other confidential and 6 proprietary materials, such as records reflecting operational policies and procedures, 7 underwriting guidelines, claims manuals and procedures, other company manuals, 8 private information pertaining to individuals, etc., for which special protection from 9 public disclosure and from use for any purpose other than prosecution of this action 10 is warranted. Such confidential and proprietary materials and information consist of, 11 among other things, confidential business or financial information, information 12 regarding confidential business practices and procedures, or other confidential 13 research, development, or commercial information (including information 14 implicating privacy rights of third parties), information otherwise generally 15 unavailable to the public, or which may be privileged or otherwise protected from 16 disclosure under state or federal statutes, court rules, case decisions, or common law. 17 Accordingly, to expedite the flow of information, to facilitate the prompt resolution 18 of disputes over confidentiality of discovery materials, to adequately protect 19 information the parties are entitled to keep confidential, to ensure that the parties are 20 permitted reasonable necessary uses of such material in preparation for and in the 21 conduct of trial, to address their handling at the end of the litigation, and serve the 22 ends of justice, a protective order for such information is justified in this matter. It is 23 the intent of the parties that information will not be designated as confidential for 24 tactical reasons and that nothing be so designated without a good faith belief that it 25 has been maintained in a confidential, non-public manner, and there is good cause 26 why it should not be part of the public record of this case. 27 28 2 Case 2:21-cv-00914-AB-AFM Document 48 Filed 06/10/22 Page 3 of 17 Page ID #:540

1 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 2 The parties further acknowledge, as set forth in Section 12.3, below, that this 3 Stipulated Protective Order does not entitle them to file confidential information 4 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and 5 the standards that will be applied when a party seeks permission from the court to file material under seal. 6 There is a strong presumption that the public has a right of access to judicial 7 proceedings and records in civil cases. In connection with non-dispositive motions, 8 good cause must be shown to support a filing under seal. See Kamakana v. City and 9 County of Honolulu,

(9th Cir. 2006), Phillips v. Gen. Motors 10 Corp.,

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

(E.D. Wis. 1999) (even stipulated protective orders require good 12 cause showing), and a specific showing of good cause or compelling reasons with 13 proper evidentiary support and legal justification, must be made with respect to 14 Protected Material that a party seeks to file under seal. The parties’ mere designation 15 of Disclosure or Discovery Material as CONFIDENTIAL does not— without the 16 submission of competent evidence by declaration, establishing that the material 17 sought to be filed under seal qualifies as confidential, privileged, or otherwise 18 protectable—constitute good cause. 19 Further, if a party requests sealing related to a dispositive motion or trial, then 20 compelling reasons, not only good cause, for the sealing must be shown, and the relief 21 sought shall be narrowly tailored to serve the specific interest to be protected. See 22 Pintos v. Pacific Creditors Ass’n,

(9th Cir. 2010). For each item 23 or type of information, document, or thing sought to be filed or introduced under seal 24 in connection with a dispositive motion or trial, the party seeking protection must 25 articulate compelling reasons, supported by specific facts and legal justification, for 26 the requested sealing order. Again, competent evidence supporting the application to 27 file documents under seal must be provided by declaration. 28 3 Case 2:21-cv-00914-AB-AFM Document 48 Filed 06/10/22 Page 4 of 17 Page ID #:541

1 Any document that is not confidential, privileged, or otherwise protectable in 2 its entirety will not be filed under seal if the confidential portions can be redacted. If 3 documents can be redacted, then a redacted version for public viewing, omitting only 4 the confidential, privileged, or otherwise protectable portions of the document, shall 5 be filed. Any application that seeks to file documents under seal in their entirety should include an explanation of why redaction is not feasible. 6

7 2. DEFINITIONS 8 2.1 Action: this pending federal lawsuit. 9 2.2 Challenging Party: a Party or Non-Party that challenges the designation 10 of information or items under this Order. 11 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 12 how it is generated, stored or maintained) or tangible things that qualify for protection 13 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 14 Cause Statement. 15 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 16 support staff). 17 2.5 Designating Party: a Party or Non-Party that designates information or 18 items that it produces in disclosures or in responses to discovery as 19 “CONFIDENTIAL.” 20 2.6 Disclosure or Discovery Material: all items or information, regardless 21 of the medium or manner in which it is generated, stored, or maintained (including, 22 among other things, testimony, transcripts, and tangible things), that are produced or 23 generated in disclosures or responses to discovery in this matter. 24 2.7 Expert: a person with specialized knowledge or experience in a matter 25 pertinent to the litigation who has been retained by a Party or its counsel to serve as 26 an expert witness or as a consultant in this Action. 27 28 4 Case 2:21-cv-00914-AB-AFM Document 48 Filed 06/10/22 Page 5 of 17 Page ID #:542

1 2.8 House Counsel: attorneys who are employees of a party to this Action. 2 House Counsel does not include Outside Counsel of Record or any other outside 3 counsel. 4 2.9 Non-Party: any natural person, partnership, corporation, association or 5 other legal entity not named as a Party to this action. 2.10 Outside Counsel of Record: attorneys who are not employees of a party 6 to this Action but are retained to represent or advise a party to this Action and have 7 appeared in this Action on behalf of that party or are affiliated with a law firm that 8 has appeared on behalf of that party, and includes support staff. 9 2.11 Party: any party to this Action, including all of its officers, directors, 10 employees, consultants, retained experts, and Outside Counsel of Record (and their 11 support staffs). 12 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 13 Discovery Material in this Action. 14 2.13 Professional Vendors: persons or entities that provide litigation support 15 services (e.g., photocopying, videotaping, translating, preparing exhibits or 16 demonstrations, and organizing, storing, or retrieving data in any form or medium) 17 and their employees and subcontractors. 18 2.14 Protected Material: any Disclosure or Discovery Material that is 19 designated as “CONFIDENTIAL.” 20 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 21 from a Producing Party. 22

23 3. SCOPE 24 The protections conferred by this Stipulation and Order cover not only 25 Protected Material (as defined above), but also (1) any information copied or extracted 26 from Protected Material; (2) all copies, excerpts, summaries, or compilations of 27 Protected Material; and (3) any testimony, conversations, or presentations by Parties 28 5 Case 2:21-cv-00914-AB-AFM Document 48 Filed 06/10/22 Page 6 of 17 Page ID #:543

1 or their Counsel that might reveal Protected Material. Nothing in this order shall 2 prevent the parties from negotiating additional protections for specific categories of 3 documents or information. 4 Any use of Protected Material at trial shall be governed by the orders of the 5 trial judge. This Order does not govern the use of Protected Material at trial.

6 4. DURATION 7 Once a case proceeds to trial, information that was designated as 8 CONFIDENTIAL or maintained pursuant to this protective order used or introduced 9 as an exhibit at trial becomes public and will be presumptively available to all 10 members of the public, including the press, unless compelling reasons supported by 11 specific factual findings to proceed otherwise are made to the trial judge in advance 12 of the trial. See Kamakana,

(distinguishing “good cause” 13 showing for sealing documents produced in discovery from “compelling reasons” 14 standard when merits-related documents are part of court record). Accordingly, the 15 terms of this protective order do not extend beyond the commencement of the trial. 16

17 5. DESIGNATING PROTECTED MATERIAL 18 5.1 Exercise of Restraint and Care in Designating Material for Protection. 19 Each Party or Non-Party that designates information or items for protection under this 20 Order must take care to limit any such designation to specific material that qualifies 21 under the appropriate standards. The Designating Party must designate for protection 22 only those parts of material, documents, items or oral or written communications that 23 qualify so that other portions of the material, documents, items, or communications 24 for which protection is not warranted are not swept unjustifiably within the ambit of 25 this Order. 26 Mass, indiscriminate or routinized designations are prohibited. Designations 27 that are shown to be clearly unjustified or that have been made for an improper 28 6 Case 2:21-cv-00914-AB-AFM Document 48 Filed 06/10/22 Page 7 of 17 Page ID #:544

1 purpose (e.g., to unnecessarily encumber the case development process or to impose 2 unnecessary expenses and burdens on other parties) may expose the Designating Party 3 to sanctions. 4 If it comes to a Designating Party’s attention that information or items that it 5 designated for protection do not qualify for protection, that Designating Party must promptly notify all other Parties that it is withdrawing the inapplicable designation. 6 5.2 Manner and Timing of Designations. Except as otherwise provided in 7 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 8 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 9 under this Order must be clearly so designated before the material is disclosed or 10 produced. 11 Designation in conformity with this Order requires: 12 (a) for information in documentary form (e.g., paper or electronic documents, 13 but excluding transcripts of depositions or other pretrial or trial proceedings), that the 14 Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 15 “CONFIDENTIAL legend”), to each page that contains protected material. If only a 16 portion of the material on a page qualifies for protection, the Producing Party also 17 must clearly identify the protected portion(s) (e.g., by making appropriate markings 18 in the margins). 19 A Party or Non-Party that makes original documents available for inspection 20 need not designate them for protection until after the inspecting Party has indicated 21 which documents it would like copied and produced. During the inspection and 22 before the designation, all of the material made available for inspection shall be 23 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents 24 it wants copied and produced, the Producing Party must determine which documents, 25 or portions thereof, qualify for protection under this Order. Then, before producing 26 the specified documents, the Producing Party must affix the “CONFIDENTIAL 27 legend” to each page that contains Protected Material. If only a portion or portions 28 7 Case 2:21-cv-00914-AB-AFM Document 48 Filed 06/10/22 Page 8 of 17 Page ID #:545

1 of the material on a page qualifies for protection, the Producing Party also must clearly 2 identify the protected portion(s) (e.g., by making appropriate markings in the 3 margins). 4 (b) for testimony given in depositions, that the Designating Party either (i) 5 identify the Disclosure or Discovery Material on the record or (ii) provisionally designate the entire transcript as Confidential and provide narrowed designations 6 within thirty (30) days after delivery of the deposition transcript by the court reporter. 7 This deadline may be extended by mutual agreement of the parties. During the 8 pendency of the thirty-day period, the entire transcript shall be treated as confidential 9 absent agreement by the parties. 10 (c) for information produced in some form other than documentary and for any 11 other tangible items, that the Producing Party affix in a prominent place on the exterior 12 of the container or containers in which the information is stored the legend 13 “CONFIDENTIAL.” If only a portion or portions of the information warrants 14 protection, the Producing Party, to the extent practicable, shall identify the protected 15 portion(s). 16 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 17 failure to designate qualified information or items does not, standing alone, waive the 18 Designating Party’s right to secure protection under this Order for such material. 19 Upon timely correction of a designation, the Receiving Party must make reasonable 20 efforts to assure that the material is treated in accordance with the provisions of this 21 Order. 22

23 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 24 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 25 designation of confidentiality at any time that is consistent with the Court’s 26 Scheduling Order. 27 28 8 Case 2:21-cv-00914-AB-AFM Document 48 Filed 06/10/22 Page 9 of 17 Page ID #:546

1 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 2 resolution process under Local Rule 37-1 et seq. 3 6.3 Joint Stipulation. Any challenge submitted to the Court shall be via a 4 joint stipulation pursuant to Local Rule 37-2. 5 6.4 The burden of persuasion in any such challenge proceeding shall be on the Designating Party. Frivolous challenges, and those made for an improper purpose 6 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 7 expose the Challenging Party to sanctions. Unless the Designating Party has waived 8 or withdrawn the confidentiality designation, all parties shall continue to afford the 9 material in question the level of protection to which it is entitled under the Producing 10 Party’s designation until the Court rules on the challenge. 11

12 7. ACCESS TO AND USE OF PROTECTED MATERIAL 13 7.1 Basic Principles. A Receiving Party may use Protected Material that is 14 disclosed or produced by another Party or by a Non-Party in connection with this 15 Action only for prosecuting, defending or attempting to settle this Action. Such 16 Protected Material may be disclosed only to the categories of persons and under the 17 conditions described in this Order. When the Action has been terminated, a Receiving 18 Party must comply with the provisions of section 13 below (FINAL DISPOSITION). 19 Protected Material must be stored and maintained by a Receiving Party at a 20 location and in a secure manner that ensures that access is limited to the persons 21 authorized under this Order. 22 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 23 otherwise ordered by the court or permitted in writing by the Designating Party, a 24 Receiving Party may disclose any information or item designated 25 “CONFIDENTIAL” only to: 26 27 28 9 Case 2:21-cv-00914-AB-AFM Document 48 Filed 06/10/22 Page 10 of 17 Page ID #:547

1 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as 2 employees of said Outside Counsel of Record to whom it is reasonably necessary to 3 disclose the information for this Action; 4 (b) the officers, directors, and employees (including House Counsel), if any, 5 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 6 disclosure is reasonably necessary for this Action and who have signed the 7 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 8 (d) the court and its personnel; 9 (e) court reporters and their staff; 10 (f) professional jury or trial consultants, mock jurors, and Professional Vendors 11 to whom disclosure is reasonably necessary for this Action and who have signed the 12 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 13 (g) the author or recipient of a document containing the information or a 14 custodian or other person who otherwise possessed or knew the information; 15 (h) during their depositions, witnesses, and attorneys for witnesses, in the 16 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 17 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will 18 not be permitted to keep any confidential information unless they sign the 19 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 20 agreed by the Designating Party or ordered by the court. Pages of transcribed 21 deposition testimony or exhibits to depositions that reveal Protected Material may be 22 separately bound by the court reporter and may not be disclosed to anyone except as 23 permitted under this Stipulated Protective Order; and 24 (i) any mediator or settlement officer, and their supporting personnel, mutually 25 agreed upon by any of the parties engaged in settlement discussions. 26

27 28 10 Case 2:21-cv-00914-AB-AFM Document 48 Filed 06/10/22 Page 11 of 17 Page ID #:548

1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 2 OTHER LITIGATION 3 If a Party is served with a subpoena or a court order issued in other litigation 4 that compels disclosure of any information or items designated in this Action as 5 “CONFIDENTIAL,” that Party must: (a) promptly notify in writing the Designating Party. Such notification shall 6 include a copy of the subpoena or court order; 7 (b) promptly notify in writing the party who caused the subpoena or order to 8 issue in the other litigation that some or all of the material covered by the subpoena 9 or order is subject to this Protective Order. Such notification shall include a copy of 10 this Stipulated Protective Order; and 11 (c) cooperate with respect to all reasonable procedures sought to be pursued 12 by the Designating Party whose Protected Material may be affected. 13 If the Designating Party timely seeks a protective order, the Party served with 14 the subpoena or court order shall not produce any information designated in this action 15 as “CONFIDENTIAL” before a determination by the court from which the subpoena 16 or order issued, unless the Party has obtained the Designating Party’s permission. The 17 Designating Party shall bear the burden and expense of seeking protection in that court 18 of its confidential material and nothing in these provisions should be construed as 19 authorizing or encouraging a Receiving Party in this Action to disobey a lawful 20 directive from another court. 21

22 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 23 PRODUCED IN THIS LITIGATION 24 (a) The terms of this Order are applicable to information produced by a Non- 25 Party in this Action and designated as “CONFIDENTIAL.” Such information 26 produced by Non-Parties in connection with this litigation is protected by the 27 28 11 Case 2:21-cv-00914-AB-AFM Document 48 Filed 06/10/22 Page 12 of 17 Page ID #:549

1 remedies and relief provided by this Order. Nothing in these provisions should be 2 construed as prohibiting a Non-Party from seeking additional protections. 3 (b) In the event that a Party is required, by a valid discovery request, to produce 4 a Non-Party’s confidential information in its possession, and the Party is subject to an 5 agreement with the Non-Party not to produce the Non-Party’s confidential information, then the Party shall: 6 (1) promptly notify in writing the Requesting Party and the Non-Party that 7 some or all of the information requested is subject to a confidentiality agreement with 8 a Non-Party; 9 (2) promptly provide the Non-Party with a copy of the Stipulated Protective 10 Order in this Action, the relevant discovery request(s), and a reasonably specific 11 description of the information requested; and 12 (3) make the information requested available for inspection by the Non-Party, 13 if requested. 14 (c) If the Non-Party fails to seek a protective order from this court within 14 15 days of receiving the notice and accompanying information, the Receiving Party may 16 produce the Non-Party’s confidential information responsive to the discovery request. 17 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce 18 any information in its possession or control that is subject to the confidentiality 19 agreement with the Non-Party before a determination by the court. Absent a court 20 order to the contrary, the Non-Party shall bear the burden and expense of seeking 21 protection in this court of its Protected Material. 22

23 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 24 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 25 Protected Material to any person or in any circumstance not authorized under this 26 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 27 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 28 12 Case 2:21-cv-00914-AB-AFM Document 48 Filed 06/10/22 Page 13 of 17 Page ID #:550

1 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 2 persons to whom unauthorized disclosures were made of all the terms of this Order, 3 and (d) request such person or persons to execute the “Acknowledgment and 4 Agreement to Be Bound” that is attached hereto as Exhibit A. 5 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 6 PROTECTED MATERIAL 7 When a Producing Party gives notice to Receiving Parties that certain 8 inadvertently produced material is subject to a claim of privilege or other protection, 9 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 10 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 11 may be established in an e-discovery order that provides for production without prior 12 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 13 parties reach an agreement on the effect of disclosure of a communication or 14 information covered by the attorney-client privilege or work product protection, the 15 parties may incorporate their agreement in the stipulated protective order submitted 16 to the court. 17

18 12. MISCELLANEOUS 19 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 20 person to seek its modification by the Court in the future. 21 12.2 Right to Assert Other Objections. By stipulating to the entry of this 22 Protective Order, no Party waives any right it otherwise would have to object to 23 disclosing or producing any information or item on any ground not addressed in this 24 Stipulated Protective Order. Similarly, no Party waives any right to object on any 25 ground to use in evidence of any of the material covered by this Protective Order. 26 12.3 Filing Protected Material. A Party that seeks to file under seal any 27 Protected Material must comply with Local Civil Rule 79-5. Protected Material may 28 13 Case 2:21-cv-00914-AB-AFM Document 48 Filed 06/10/22 Page 14 of 17 Page ID #:551

1 only be filed under seal pursuant to a court order authorizing the sealing of the specific 2 Protected Material at issue. If a Party’s request to file Protected Material under seal 3 is denied by the court, then the Receiving Party may file the information in the public 4 record unless otherwise instructed by the court. 5 13. FINAL DISPOSITION 6 After the final disposition of this Action, as defined in paragraph 4, within 60 7 days of a written request by the Designating Party, each Receiving Party must return 8 all Protected Material to the Producing Party or destroy such material. As used in this 9 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 10 summaries, and any other format reproducing or capturing any of the Protected 11 Material. Whether the Protected Material is returned or destroyed, the Receiving 12 Party must submit a written certification to the Producing Party (and, if not the same 13 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 14 (by category, where appropriate) all the Protected Material that was returned or 15 destroyed and (2) affirms that the Receiving Party has not retained any copies, 16 abstracts, compilations, summaries or any other format reproducing or capturing any 17 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 18 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 19 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 20 reports, attorney work product, and consultant and expert work product, even if such 21 materials contain Protected Material. Any such archival copies that contain or 22 constitute Protected Material remain subject to this Protective Order as set forth in 23 Section 4 (DURATION). 24

25 14. VIOLATION 26 Any violation of this Order may be punished by appropriate measures 27 including, without limitation, contempt proceedings and/or monetary sanctions. 28 14 Case 2:21-cv-00914-AB-AFM Document 48 Filed 06/10/22 Page 15 of 17 Page ID #:552

1 2 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 3 DATED: June 9, 2022 KLEVATT & ASSOCIATES, LLC 4

5 By: /s/ David S. Klevatt DAVID S. KLEVATT 6 TIMOTHY M. HOWE Attorneys for Plaintiffs Jayson D. 7 Palmer, Judith Palmer, and Jennifer Witherspoon, individually and on 8 behalf of all others similarly situated

9

10 DATED: June 9, 2022 MAYNARD, COOPER & GALE LLP

11

By: /s/ Ophir Johna 12 Ophir Johna Vivian I. Orlando 13 Attorneys for Defendant Primerica Life Insurance Company 14 15 16 Filer’s Attestation: Pursuant to Local Rule 5-4.3.4(a)(2)(i) regarding 17 signatures, I hereby attest that concurrence in the filing of this document and its 18 content has been obtained by all signatories listed. 19

20 DATED: June 9, 2022 MAYNARD, COOPER & GALE LLP

21 By: /s/ Ophir Johna 22 Ophir Johna Vivian I. Orlando 23 Attorneys for Defendant Primerica Life Insurance Company 24 25 26

27 28 15 Case 2}21-cv-00914-AB-AFM Document 48 Filed 06/10/22 Page 16o0f17 Page ID #:553

1 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 3 || DATED: 6/10/2022 | Qty Mock ‘ —— 7 || HON, ALEXANDER F. MacKINNON g || United States Magistrate Judge 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 □ 16

Case 2:21-cv-00914-AB-AFM Document 48 Filed 06/10/22 Page 17 of 17 Page ID #:554

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], declare under penalty of perjury that I have read in its 6 entirety and understand the Stipulated Protective Order that was issued by the United 7 States District Court for the Central District of California on ____________ [date] in 8 the case of Jayson D. Palmer, et al. v. Primerica Life Insurance Company, Case No. 9 2:21-cv-00914-AB (AFMx). I agree to comply with and to be bound by all the terms 10 of this Stipulated Protective Order and I understand and acknowledge that failure to 11 so comply could expose me to sanctions and punishment in the nature of contempt. I 12 solemnly promise that I will not disclose in any manner any information or item that 13 is subject to this Stipulated Protective Order to any person or entity except in strict 14 compliance with the provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District Court 16 for the Central District of California for the purpose of enforcing the terms of this 17 Stipulated Protective Order, even if such enforcement proceedings occur after 18 termination of this action. I hereby appoint __________________________ [print or 19 type full name] of ________________________________________ [print or type 20 full address and telephone number] as my California agent for service of process in 21 connection with this action or any proceedings related to enforcement of this 22 Stipulated Protective Order. 23 Date: ______________________________________ 24 City and State where sworn and signed: ___________________________________ 25 Printed name: _______________________________ 26

27 Signature: __________________________________ 28 17