Case 2:22-cv-06152-SB-AS Document 43 Filed 10/21/22 Page 1 of 15 Page ID #:1714

1 Thomas C. Cronin (SBN 200754) CRONIN & CO., LTD. 2 120 North LaSalle Street, 20th Floor Chicago, Illinois 60602 3 Tel: 312-500-2100 [email protected] 4 Robert R. Duncan 5 James Podolny DUNCAN LAW GROUP, LLC 6 161 North Clark Street, Suite 2550 Chicago, Illinois 60601 7 Tel: 312-202-3283 [email protected] 8 [email protected] 9 Attorneys for Plaintiffs BARBARA McHUGH et al. 10 DENTONS US LLP 11 MICHAEL J. DUVALL (SBN 276994) [email protected] 12 SANDRA D. HAUSER (admitted Pro Hac Vice) [email protected] 13 DREW W. MARROCCO (admitted Pro Hac Vice) [email protected] 14 MARILYN B. ROSEN (admitted Pro Hac Vice) [email protected] 15 601 South Figueroa Street, Suite 2500 Los Angeles, California 90017-5704 16 Tel: 213-623-9300 / Fax: 213-623-9924 17 Attorneys for Defendant METROPOLITAN LIFE INSURANCE COMPANY 18 19 UNITED STATES DISTRICT COURT 20 CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION 21 BARBARA MCHUGH, CHARLES Case No. 2:22-cv-06152-SB (ASx) PATRICK MCHUGH, JOHN 22 ELLSWORTH, and all others similarly Honorable Stanley Blumenfeld, Jr. 23 situated, AMENDED PROTECTIVE ORDER 24 Plaintiffs, 25 v. 26 METROPOLITAN LIFE INSURANCE COMPANY, a New York Corporation; 27 Defendant. 28 Case 2:22-cv-06152-SB-AS Document 43 Filed 10/21/22 Page 2 of 15 Page ID #:1715

1 2 1. A. PURPOSES AND LIMITATIONS 3 Discovery in this action is likely to involve production of confidential, 4 proprietary or private information for which special protection from public disclosure 5 and from use for any purpose other than prosecuting this litigation may be warranted. 6 Accordingly, the parties hereby stipulate to and petition the Court to enter the 7 following Stipulated Protective Order. The parties acknowledge that this Order does 8 not confer blanket protections on all disclosures or responses to discovery and that 9 the protection it affords from public disclosure and use extends only to the limited 10 information or items that are entitled to confidential treatment under the applicable 11 legal principles. The parties further acknowledge, as set forth in Section 12.3 below, 12 that this Stipulated Protective Order does not entitle them to file confidential 13 information under seal; Civil Local Rule 79-5 sets forth the procedures that must be 14 followed and the standards that will be applied when a party seeks permission from 15 the court to file material under seal. 16 B. GOOD CAUSE STATEMENT 17 This action is likely to involve trade secrets, customer and pricing lists and 18 other valuable research, actuarial methodologies, processes, and assumptions, 19 development, commercial, financial, technical and/or proprietary information for 20 which special protection from public disclosure and from use for any purpose other 21 than prosecution of this action is warranted. Such confidential and proprietary 22 materials and information consist of, among other things, confidential business or 23 financial information, information regarding confidential business practices, or other 24 confidential research, development, or commercial information (including 25 information implicating privacy rights of third parties), information otherwise 26 generally unavailable to the public, or which may be privileged or otherwise 27 protected from disclosure under state or federal statutes, court rules, case decisions, 28 or common law. Accordingly, to expedite the flow of information, to facilitate the - 2 - Case 2:22-cv-06152-SB-AS Document 43 Filed 10/21/22 Page 3 of 15 Page ID #:1716

1 prompt resolution of disputes over confidentiality of discovery materials, to 2 adequately protect information the parties are entitled to keep confidential, to ensure 3 that the parties are permitted reasonable necessary uses of such material in 4 preparation for and in the conduct of trial, to address their handling at the end of the 5 litigation, and serve the ends of justice, a protective order for such information is 6 justified in this matter. It is the intent of the parties that information will not be 7 designated as confidential for tactical reasons and that nothing be so designated 8 without a good faith belief that it has been maintained in a confidential, non-public 9 manner, and there is good cause why it should not be part of the public record of this 10 case. 11 2. DEFINITIONS 12 2.1 Action: McHugh, et al. v. Metropolitan Life Insurance Company, Case 13 Number 2:22-cv-06152-SB (ASx), pending in the United States District Court for the 14 Central District of California. 15 2.2 Challenging Party: a Party or Non-Party that challenges the designation 16 of information or items under this Order. 17 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 18 how it is generated, stored or maintained) or tangible things that qualify for protection 19 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 20 Cause Statement. 21 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 22 their support staff). 23 2.5 Designating Party: a Party or Non-Party that designates information or 24 items that it produces in disclosures or in responses to discovery as 25 “CONFIDENTIAL.” 26 2.6 Disclosure or Discovery Material: all items or information, regardless 27 of the medium or manner in which it is generated, stored, or maintained (including, 28 among other things, testimony, transcripts, and tangible things), that are produced or

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1 generated in disclosures or responses to discovery in this matter. 2 2.7 Expert: a person with specialized knowledge or experience in a matter 3 pertinent to the litigation who has been retained by a Party or its counsel to serve as 4 an expert witness or as a consultant in this Action. 5 2.8 House Counsel: attorneys who are employees of a party to this Action. 6 House Counsel does not include Outside Counsel of Record or any other outside 7 counsel. 8 2.9 Non-Party: any natural person, partnership, corporation, association or 9 other legal entity not named as a Party to this action. 10 2.10 Outside Counsel of Record: attorneys who are not employees of a party 11 to this Action but are retained to represent or advise a party to this Action and have 12 appeared in this Action on behalf of that party or are affiliated with a law firm that 13 has appeared on behalf of that party, and includes support staff. 14 2.11 Party: any party to this Action, including all of its officers, directors, 15 employees, consultants, retained experts, and Outside Counsel of Record (and their 16 support staffs). 17 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 18 Discovery Material in this Action. 19 2.13 Professional Vendors: persons or entities that provide litigation support 20 services (e.g., photocopying, videotaping, translating, preparing exhibits or 21 demonstrations, and organizing, storing, or retrieving data in any form or medium) 22 and their employees and subcontractors. 23 2.14 Protected Material: any Disclosure or Discovery Material that is 24 designated as “CONFIDENTIAL.” 25 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 26 from a Producing Party. 27 28 - 4 - Case 2:22-cv-06152-SB-AS Document 43 Filed 10/21/22 Page 5 of 15 Page ID #:1718

1 3. SCOPE 2 The protections conferred by this Stipulation and Order cover not only 3 Protected Material (as defined above), but also (1) any information copied or 4 extracted from Protected Material; (2) all copies, excerpts, summaries, or 5 compilations of Protected Material; and (3) any testimony, conversations, or 6 presentations by Parties or their Counsel that might reveal Protected Material. 7 Any use of Protected Material at trial shall be governed by the orders of the 8 trial judge. This Order does not govern the use of Protected Material at trial. 9 4. DURATION 10 Once a case proceeds to trial, information that was designated as 11 CONFIDENTIAL or maintained pursuant to this protective order used or introduced 12 as an exhibit at trial becomes public and will be presumptively available to all 13 members of the public, including the press, unless compelling reasons supported by 14 specific factual findings to proceed otherwise are made to the trial judge in advance 15 of the trial. See Kamakana v. City and County of Honolulu,

, 1180-81 16 (9th Cir. 2006) (distinguishing “good cause” showing for sealing documents produced 17 in discovery from “compelling reasons” standard when merits-related documents are 18 part of court record). Accordingly, the terms of this protective order do not extend 19 beyond the commencement of the trial. 20 5. DESIGNATING PROTECTED MATERIAL 21 5.1 Exercise of Restraint and Care in Designating Material for Protection. 22 Each Party or Non-Party that designates information or items for protection under 23 this Order must take care to limit any such designation to specific material that 24 qualifies under the appropriate standards. The Designating Party must designate for 25 protection only those parts of material, documents, items, or oral or written 26 communications that qualify so that other portions of the material, documents, items, 27 or communications for which protection is not warranted are not swept unjustifiably 28 within the ambit of this Order.

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

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1 the specified documents, the Producing Party must affix the “CONFIDENTIAL 2 legend” to each page that contains Protected Material. If only a portion or portions 3 of the material on a page qualifies for protection, the Producing Party must clearly 4 identify the protected portion(s) (e.g. by making appropriate markings in the 5 margins). 6 (b) for testimony given in depositions, the entire transcript is treated as 7 confidential for 30 days during which time the parties may designate portions of the 8 record as CONFIDENTIAL. 9 (c) for information produced in some form other than documentary and for 10 any other tangible items, that the Producing Party affix in a prominent place on the 11 exterior of the container or containers in which the information is stored the legend 12 “CONFIDENTIAL.” 13 5.3 Inadvertent Failures to Designate. If timely corrected after discovery an 14 inadvertent failure to designate qualified information or items does not, standing 15 alone, waive the Designating Party’s right to secure protection under this Order for 16 such material. Upon timely correction of a designation, the Receiving Party must 17 make reasonable efforts to assure that the material is treated in accordance with the 18 provisions of this Order. 19 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 20 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 21 designation of confidentiality at any time that is consistent with the Court’s 22 Scheduling Order. 23 6.2 Meet and Confer. The Challenging Party shall initiate the informal 24 dispute resolution process set forth in the Court's Procedures and Schedules. See 25 http://www.cacd.uscourts.gov/honorable-alka-sagar 26 6.3 Joint Stipulation. Any challenge submitted to the Court shall be via a 27 joint stipulation pursuant to Local Rule 37-2. 28 6.4 The burden of persuasion in any such challenge proceeding shall be on

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1 the Designating Party. Frivolous challenges, and those made for an improper purpose 2 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 3 expose the Challenging Party to sanctions. Unless the Designating Party has waived 4 or withdrawn the confidentiality designation, all parties shall continue to afford the 5 material in question the level of protection to which it is entitled under the Producing 6 Party’s designation until the Court rules on the challenge. 7 7. ACCESS TO AND USE OF PROTECTED MATERIAL 8 7.1 Basic Principles. A Receiving Party may use Protected Material that is 9 disclosed or produced by another Party or by a Non-Party in connection with this 10 Action only for prosecuting, defending or attempting to settle this Action. Such 11 Protected Material may be disclosed only to the categories of persons and under the 12 conditions described in this Order. When the Action has been terminated, a Receiving 13 Party must comply with the provisions of section 13 below (FINAL DISPOSITION). 14 Protected Material must be stored and maintained by a Receiving Party at a 15 location and in a secure manner that ensures that access is limited to the persons 16 authorized under this Order. 17 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 18 otherwise ordered by the court or permitted in writing by the Designating Party, a 19 Receiving Party may disclose any information or item designated 20 “CONFIDENTIAL” only to: 21 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 22 as employees of said Outside Counsel of Record to whom it is reasonably necessary 23 to disclose the information for this Action; 24 (b) the officers, directors, and employees (including House Counsel) of the 25 Receiving Party to whom disclosure is reasonably necessary for this Action; 26 (c) Experts (as defined in this Order) of the Receiving Party to whom 27 disclosure is reasonably necessary for this Action and who have signed the 28 “Acknowledgment and Agreement to Be Bound” (Exhibit A);

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1 (d) the court and its personnel; 2 (e) court reporters and their staff; 3 (f) professional jury or trial consultants, mock jurors, and Professional 4 Vendors to whom disclosure is reasonably necessary for this Action and who have 5 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 6 (g) the author or recipient of a document containing the information or a 7 custodian or other person who otherwise possessed or knew the information; 8 (h) during their depositions, witnesses, and attorneys for witnesses, in the 9 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 10 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will 11 not be permitted to keep any confidential information unless they sign the 12 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 13 agreed by the Designating Party or ordered by the court. Pages of transcribed 14 deposition testimony or exhibits to depositions that reveal Protected Material may be 15 separately bound by the court reporter and may not be disclosed to anyone except as 16 permitted under this Stipulated Protective Order; and 17 (i) any mediator or settlement officer, and their supporting personnel, 18 mutually agreed upon by any of the parties engaged in settlement discussions. 19 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 20 IN OTHER LITIGATION 21 If a Party is served with a subpoena or a court order issued in other litigation 22 that compels disclosure of any information or items designated in this Action as 23 “CONFIDENTIAL,” that Party must: 24 (a) promptly notify in writing the Designating Party. Such notification shall 25 include a copy of the subpoena or court order; 26 (b) promptly notify in writing the party who caused the subpoena or order 27 to issue in the other litigation that some or all of the material covered by the subpoena 28 or order is subject to this Protective Order. Such notification shall include a copy of

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1 this Stipulated Protective Order; and 2 (c) cooperate with respect to all reasonable procedures sought to be pursued 3 by the Designating Party whose Protected Material may be affected. 4 If the Designating Party timely seeks a protective order, the Party served with 5 the subpoena or court order shall not produce any information designated in this 6 action as “CONFIDENTIAL” before a determination by the court from which the 7 subpoena or order issued, unless the Party has obtained the Designating Party’s 8 permission. The Designating Party shall bear the burden and expense of seeking 9 protection in that court of its confidential material and nothing in these provisions 10 should be construed as authorizing or encouraging a Receiving Party in this Action 11 to disobey a lawful directive from another court. 12 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 13 PRODUCED IN THIS LITIGATION 14 (a) The terms of this Order are applicable to information produced by a 15 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 16 produced by Non-Parties in connection with this litigation is protected by the 17 remedies and relief provided by this Order. Nothing in these provisions should be 18 construed as prohibiting a Non-Party from seeking additional protections. 19 (b) In the event that a Party is required, by a valid discovery request, to 20 produce a Non-Party’s confidential information in its possession, and the Party is 21 subject to an agreement with the Non-Party not to produce the Non-Party’s 22 confidential information, then the Party shall: 23 (1) promptly notify in writing the Requesting Party and the Non- 24 Party that some or all of the information requested is subject to a confidentiality 25 agreement with a Non-Party; 26 (2) promptly provide the Non-Party with a copy of the Stipulated 27 Protective Order in this Action, the relevant discovery request(s), and a reasonably 28 specific description of the information requested; and

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1 (3) make the information requested available for inspection by the 2 Non-Party, if requested. 3 (c) If the Non-Party fails to seek a protective order from this court within 4 14 days of receiving the notice and accompanying information, the Receiving Party 5 may produce the Non-Party’s confidential information responsive to the discovery 6 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 7 not produce any information in its possession or control that is subject to the 8 confidentiality agreement with the Non-Party before a determination by the court. 9 Absent a court order to the contrary, the Non-Party shall bear the burden and expense 10 of seeking protection in this court of its Protected Material. 11 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 12 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 13 Protected Material to any person or in any circumstance not authorized under this 14 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 15 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 16 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 17 persons to whom unauthorized disclosures were made of all the terms of this Order, 18 and (d) request such person or persons to execute the “Acknowledgment and 19 Agreement to Be Bound” that is attached hereto as Exhibit A. 20 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 21 PROTECTED MATERIAL 22 When a Producing Party gives notice to Receiving Parties that certain 23 inadvertently produced material is subject to a claim of privilege or other protection, 24 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 25 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 26 may be established in an e-discovery order that provides for production without prior 27 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 28 parties reach an agreement on the effect of disclosure of a communication or

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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 3 to the court. 4 12. MISCELLANEOUS 5 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 6 person to seek its modification by the Court in the future. 7 12.2 Right to Assert Other Objections. By stipulating to the entry of this 8 Protective Order, no Party waives any right it otherwise would have to object to 9 disclosing or producing any information or item on any ground not addressed in 10 this Stipulated Protective Order. Similarly, no Party waives any right to object on 11 any ground to use in evidence of any of the material covered by this Protective 12 Order. 13 12.3 Filing Protected Material. A Party that seeks to file under seal any 14 Protected Material must comply with Civil Local Rule 79-5. Protected Material 15 may only be filed under seal pursuant to a court order authorizing the sealing of the 16 specific Protected Material at issue. If a Party’s request to file Protected Material 17 under seal is denied by the court, then the Receiving Party may file the information 18 in the public record unless otherwise instructed by the court. 19 13. FINAL DISPOSITION 20 After the final disposition of this Action, as defined in paragraph 4, within 60 21 days of a written request by the Designating Party, each Receiving Party must return 22 all Protected Material to the Producing Party or destroy such material. As used in this 23 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 24 summaries, and any other format reproducing or capturing any of the Protected 25 Material. Whether the Protected Material is returned or destroyed, the Receiving 26 Party must submit a written certification to the Producing Party (and, if not the same 27 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 28 (by category, where appropriate) all the Protected Material that was returned or

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1 destroyed and (2) affirms that the Receiving Party has made best efforts to confirm 2 that it has not retained any copies, abstracts, compilations, summaries or any other 3 format reproducing or capturing any of the Protected Material. Notwithstanding this 4 provision, Counsel are entitled to retain an archival copy of all pleadings, motion 5 papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence, 6 deposition and trial exhibits, expert reports, attorney work product, and consultant 7 and expert work product, even if such materials contain Protected Material. Any such 8 archival copies that contain or constitute Protected Material remain subject to this 9 Protective Order as set forth in Section 4 (DURATION). In addition, 10 notwithstanding this provision, (i) the Parties shall have the right to retain all 11 Protected Material in their respective possessions that they are required to maintain 12 to fulfill their potential obligations to their reinsurers, insurers, regulators and/or 13 auditors, or as otherwise required by law or regulation, or (ii) that are retained as part 14 of an electronic backup, recovery or archival system, so long as such Information is 15 not accessible in the ordinary course of business and is not accessed except as 16 required by law, regulation or legal process or for backup, recovery, contingency 17 planning or business continuity planning purposes. Any such archival copies that 18 contain or constitute Protected Material remain subject to this Protective Order. 19 14. VIOLATION 20 Any violation of this Order may be punished by appropriate measures 21 including, without limitation, contempt proceedings and/or monetary sanctions. 22 23 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 24 // 25 // 26 // 27 // 28 // - 13 - Case 2:22-cv-06152-SB-AS Document 43 Filed 10/21/22 Page 14 of 15 Page ID #:1727

1 2 DATED: October 21, 2022 3 /s/ Thomas C. Cronin 4 Attorneys for Plaintiffs 5 /s/ Michael J. Duvall Attorneys for Defendant 6 7 8 I, Michael J. Duvall, am the CM/ECF user whose ID and password are being 9 used to file this Amended Joint Stipulated Protective Order. Pursuant to Local Civil 10 Rule 5-4.3.4(a)(2)(i), I hereby attest that Thomas C. Cronin, on whose behalf this 11 filing is jointly submitted, has concurred in this filing. 12 13 /s/ Michael J. Duvall Attorneys for Defendant 14 15 16 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 17 18 DATED: October 21, 2022 19 / s / Sagar Honorable Alka Sagar 20 21 United States Magistrate Judge 22 23 24 25 26 27 28 - 14 - Case 2:22-cv-06152-SB-AS Document 43 Filed 10/21/22 Page 15 of 15 Page ID #:1728

1 EXHIBIT A 2 ACKNOWLEDGEMENT AND AGREEMENT TO BE BOUND 3 I, [print or type full name], of 4 [print or type full address], 5 declare under penalty of perjury that I have read in its entirety and understand the 6 Amended Joint Stipulated Protective Order that was issued by the United States 7 District Court for the Central District of California on [date] 8 in the case of Barbara McHugh, Charles Patrick McHugh, John Ellsworth, and all 9 others similarly situated, v. Metropolitan Life Insurance Company, Case No. 2:22- 10 cv-06152-SB (ASx). I agree to comply with and to be bound by all terms of this 11 Amended Joint 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 Amended Joint Stipulated Protective Order 15 to any 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 for 17 the Central District of California for enforcing the terms of this Amended Joint 18 Stipulated Protective Order, even if such enforcement proceedings occur after 19 termination of this action. I hereby appoint [print 20 or type full name] of [print 21 or type full address and telephone number] as my California agent for service of 22 process in connection with this action or any proceedings related to enforcement of 23 this Amended Joint Stipulated Protective Order. 24 Date: 25 City and State where sworn and signed: 26 Printed name: 27 28 Signature: EXHIBIT A