Case 2:22-cv-08371-SVW-PD Document 24 Filed 02/09/23 Page 1 of 17 Page ID #:172

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7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA

10 TRANSAMERICA LIFE INSURANCE COMPANY, a Case No. 2:22-cv-08371-SVW-PD 11 corporation (Hon. Patricia Donahue) 12 Plaintiff-in-Interpleader STIPULATED PROTECTIVE 13 v. ORDER1

14 ELIZABETH AVILA, an individual, CARMEN CHAVEZ, an individual, Complaint Filed: November 16, 2022 15 and DOES 1-20, inclusive 16 Defendants-in Interpleader.

17 1. A. PURPOSES AND LIMITATIONS 18 Discovery in this action is likely to involve production of confidential, 19 proprietary, or private information for which special protection from public 20 disclosure and from use for any purpose other than prosecuting this litigation may be 21 warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter 22 the following Stipulated Protective Order. The parties acknowledge that this Order 23 does not confer blanket protections on all disclosures or responses to discovery and 24 that the protection it affords from public disclosure and use extends only to the 25 26 27 1 This Stipulated Protective Order is substantially based on the model protective 28 order provided under Magistrate Judge Patricia Donahue’s Procedures. Case 2:22-cv-08371-SVW-PD Document 24 Filed 02/09/23 Page 2 of 17 Page ID #:173

1 limited information or items that are entitled to confidential treatment under the 2 applicable legal principles. 3 B. GOOD CAUSE STATEMENT 4 This action is likely to involve private and confidential non-party and party 5 information and confidential commercial and corporate information, including but 6 not limited to trade secrets, commercial, financial and/or proprietary information of 7 Plaintiff for which special protection from public disclosure and from use for any 8 purpose other than prosecution of this action is warranted. Such confidential and 9 proprietary materials and information consist of, among other things, confidential 10 business or financial information, information regarding confidential business 11 practices, or other confidential research, development, or 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 materials, 17 to adequately protect information the parties are entitled to keep confidential, to 18 ensure that the parties are permitted reasonable necessary uses of such material in 19 preparation for and in the conduct of trial, to address their handling at the end of the 20 litigation, and to serve the ends of justice, a protective order for such information is 21 justified in this matter. It is the intent of the parties that information will not be 22 designated as confidential for tactical reasons and that nothing be so designated 23 without a good faith belief that it has been maintained in a confidential, non-public 24 manner, and there is good cause why it should not be part of the public record of this 25 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 2 Case 2:22-cv-08371-SVW-PD Document 24 Filed 02/09/23 Page 3 of 17 Page ID #:174

1 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and 2 the standards that will be applied when a party seeks permission from the court to 3 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 v. City and 7 County of Honolulu,

(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 require 10 good cause showing), and a specific showing of good cause or compelling reasons 11 with proper evidentiary support and legal justification, must be made with respect to 12 Protected Material that a party seeks to file under seal. The parties’ mere designation 13 of Disclosure or Discovery Material as CONFIDENTIAL does not—without the 14 submission of competent evidence by declaration, establishing that the material 15 sought to be filed under seal qualifies as confidential, privileged, or otherwise 16 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 each 21 item or type of information, document, or thing sought to be filed or introduced under 22 seal in connection with a dispositive motion or trial, the party seeking protection 23 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 its entirety will not be filed under seal if the confidential portions can be redacted. If 28 documents can be redacted, then a redacted version for public viewing, omitting only 3 Case 2:22-cv-08371-SVW-PD Document 24 Filed 02/09/23 Page 4 of 17 Page ID #:175

1 the confidential, privileged, or otherwise protectable portions of the document, shall 2 be filed. Any application that seeks to file documents under seal in their entirety 3 should include an explanation of why redaction is not feasible. 4 5 2. DEFINITIONS 6 2.1 Action: Transamerica Life Insurance Company v. Elizabeth 7 Avila, et al., Case No. 2:22-cv-08371-SVW-PD. 8 2.2 Challenging Party: a Party or Non-Party that challenges 9 the designation of 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 the 13 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. 4 Case 2:22-cv-08371-SVW-PD Document 24 Filed 02/09/23 Page 5 of 17 Page ID #:176

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 party 4 to this Action but are retained to represent or advise a party to this Action and have 5 appeared in this Action on behalf of that party or are affiliated with a law firm which 6 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, applicable third-party administrators, and 9 Outside Counsel of Record (and their 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 Material 19 from a Producing Party. 20 21 3. SCOPE 22 The protections conferred by this Stipulation and Order cover not only 23 Protected Material (as defined above), but also (1) any information copied or 24 extracted from Protected Material; (2) all copies, excerpts, summaries, or 25 compilations of Protected Material; and (3) any testimony, conversations, or 26 presentations by Parties or their Counsel that might reveal Protected Material. 27 Any use of Protected Material at trial shall be governed by the orders of the 28 trial judge. This Order does not govern the use of Protected Material at trial. 5 Case 2:22-cv-08371-SVW-PD Document 24 Filed 02/09/23 Page 6 of 17 Page ID #:177

1 4. DURATION 2 Even after final disposition of this litigation, the confidentiality obligations 3 imposed by this Order will remain in effect until a Designating Party agrees otherwise 4 in writing or a court order otherwise directs. Final disposition will be deemed to be 5 the later of (1) dismissal of all claims and defenses in this Action, with or without 6 prejudice; and (2) final judgment herein after the completion and exhaustion of all 7 appeals, rehearings, remands, trials, or reviews of this Action, including the time 8 limits for filing any motions or applications for extension of time pursuant to 9 applicable law. 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,

(distinguishing “good cause” 16 showing for sealing documents produced in discovery from “compelling reasons” 17 standard when merits-related documents are part of court record). Accordingly, for 18 materials used at trial, compelling reasons supported by specific factual findings to 19 proceed otherwise are made to the trial judge in advance of the trial. 20 21 5. DESIGNATING PROTECTED MATERIAL 22 5.1 Exercise of Restraint and Care in Designating Material for Protection. 23 Each Party or Non-Party that designates information or items for protection under 24 this Order must take care to limit any such designation to specific material that 25 qualifies under the appropriate standards. The Designating Party must designate for 26 protection only those parts of material, documents, items, or oral or written 27 communications that qualify so that other portions of the material, documents, items, 28 or communications for which protection is not warranted are not swept unjustifiably 6 Case 2:22-cv-08371-SVW-PD Document 24 Filed 02/09/23 Page 7 of 17 Page ID #:178

1 within the ambit of this Order. 2 Mass, indiscriminate, or routinized designations are prohibited. Designations 3 that are shown to be clearly unjustified or that have been made for an improper 4 purpose (e.g., to unnecessarily encumber the case development process or to impose 5 unnecessary expenses and burdens on other parties) may expose the Designating 6 Party to sanctions. 7 If it comes to a Designating Party’s attention that information or items that it 8 designated for protection do not qualify for protection, that Designating Party must 9 promptly notify all other Parties that it is withdrawing the inapplicable designation. 10 5.2 Manner and Timing of Designations. Except as otherwise provided in 11 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 12 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 13 under this Order must be clearly so designated before the material is disclosed or 14 produced. 15 Designation in conformity with this Order requires: 16 (a) for information in documentary form (e.g., paper or electronic 17 documents, but excluding transcripts of depositions or other pretrial or trial 18 proceedings), that the Producing Party affix at a minimum, the legend 19 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 20 contains protected material. If only a portion or portions of the material on a page 21 qualifies for protection, the Producing Party also must clearly identify the protected 22 portion(s) (e.g., by making appropriate markings in the margins). 23 A Party or Non-Party that makes original documents available for inspection 24 need not designate them for protection until after the inspecting Party has indicated 25 which documents it would like copied and produced. During the inspection and 26 before the designation, all of the material made available for inspection shall be 27 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 28 documents it wants copied and produced, the Producing Party must determine which 7 Case 2:22-cv-08371-SVW-PD Document 24 Filed 02/09/23 Page 8 of 17 Page ID #:179

1 documents, or portions thereof, qualify for protection under this Order. Then, before 2 producing the specified documents, the Producing Party must affix the 3 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 4 portion or portions of the material on a page qualifies for protection, the Producing 5 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 6 markings in the margins). 7 (b) for testimony given in depositions that the Designating Party identify 8 the Disclosure or Discovery Material on the record, before the close of the deposition 9 all protected testimony. 10 (c) for information produced in some form other than documentary and for 11 any other tangible items, that the Producing Party affix in a prominent place on the 12 exterior 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 18 the 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 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 28 resolution process under Local Rule 37.1 et seq. 8 Case 2:22-cv-08371-SVW-PD Document 24 Filed 02/09/23 Page 9 of 17 Page ID #:180

1 6.3 The burden of persuasion in any such challenge proceeding shall be on 2 the Designating Party. Frivolous challenges, and those made for an improper purpose 3 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 4 expose the Challenging Party to sanctions. Unless the Designating Party has waived 5 or withdrawn the confidentiality designation, all parties shall continue to afford the 6 material in question the level of protection to which it is entitled under the Producing 7 Party’s designation until the Court rules on the challenge. 8 7. ACCESS TO AND USE OF PROTECTED MATERIAL 9 7.1 Basic Principles. A Receiving Party may use Protected Material that is 10 disclosed or produced by another Party or by a Non-Party in connection with this 11 Action only for prosecuting, defending, or attempting to settle this Action. Such 12 Protected Material may be disclosed only to the categories of persons and under the 13 conditions described in this Order. When the Action has been terminated, a 14 Receiving Party must comply with the provisions of section 13 below (FINAL 15 DISPOSITION). 16 Protected Material must be stored and maintained by a Receiving Party at a 17 location and in a secure manner that ensures that access is limited to the persons 18 authorized under this Order. 19 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 20 otherwise ordered by the court or permitted in writing by the Designating Party, a 21 Receiving Party may disclose any information or item designated 22 “CONFIDENTIAL” only to: 23 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 24 as employees of said Outside Counsel of Record to whom it is reasonably necessary 25 to disclose the information for this Action; 26 (b) the officers, directors, employees (including House Counsel) and 27 applicable third-party administrators of the Receiving Party to whom disclosure is 28 reasonably necessary for this Action; 9 Case 2:22-cv-08371-SVW-PD Document 24 Filed 02/09/23 Page 10 of 17 Page ID #:181

1 (c) Experts (as defined in this Order) of the Receiving Party to whom 2 disclosure is reasonably necessary for this Action and who have signed the 3 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 4 (d) the court and its personnel; 5 (e) court reporters and their staff; 6 (f) professional jury or trial consultants, mock jurors, and Professional 7 Vendors to whom disclosure is reasonably necessary for this Action and who have 8 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 9 (g) the author or recipient of a document containing the information or a 10 custodian or other person who otherwise possessed or knew the information; 11 (h) during their depositions, witnesses ,and attorneys for witnesses, in the 12 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 13 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will 14 not be permitted to keep any confidential information unless they sign the 15 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 16 agreed by the Designating Party or ordered by the court. Pages of transcribed 17 deposition testimony or exhibits to depositions that reveal Protected Material may 18 be separately bound by the court reporter and may not be disclosed to anyone except 19 as permitted under this Stipulated Protective Order; and 20 (i) any mediator or settlement officer, and their supporting personnel, 21 mutually agreed upon by any of the parties engaged in settlement discussions. 22 23 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 24 IN OTHER LITIGATION 25 If a Party is served with a subpoena or a court order issued in other litigation 26 that compels disclosure of any information or items designated in this Action as 27 “CONFIDENTIAL,” that Party must: 28 10 Case 2:22-cv-08371-SVW-PD Document 24 Filed 02/09/23 Page 11 of 17 Page ID #:182

1 (a) promptly notify in writing the Designating Party. Such notification shall 2 include a copy of the subpoena or court order; 3 (b) promptly notify in writing the party who caused the subpoena or order 4 to issue in the other litigation that some or all of the material covered by the subpoena 5 or order is subject to this Protective Order. Such notification shall include a copy of 6 this Stipulated Protective Order; and 7 (c) cooperate with respect to all reasonable procedures sought to be pursued 8 by the Designating Party whose Protected Material may be affected. 9 If the Designating Party timely seeks a protective order, the Party served 10 with the subpoena or court order shall not produce any information designated in this 11 action as “CONFIDENTIAL” before a determination by the court from which the 12 subpoena or order issued, unless the Party has obtained the Designating Party’s 13 permission. The Designating Party shall bear the burden and expense of seeking 14 protection in that court of its confidential material and nothing in these provisions 15 should be construed as authorizing or encouraging a Receiving Party in this Action 16 to disobey a lawful directive from another court. 17 18 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT 19 TO BE PRODUCED IN THIS LITIGATION 20 (a) The terms of this Order are applicable to information produced by a 21 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 22 produced by Non-Parties in connection with this litigation is protected by the 23 remedies and relief provided by this Order. Nothing in these provisions should be 24 construed as prohibiting a Non-Party from seeking additional protections. 25 (b) In the event that a Party is required, by a valid discovery request, to 26 produce a Non-Party’s confidential information in its possession, and the Party is 27 subject to an agreement with the Non-Party not to produce the Non-Party’s 28 confidential information, then the Party shall: 11 Case 2:22-cv-08371-SVW-PD Document 24 Filed 02/09/23 Page 12 of 17 Page ID #:183

1 (1) promptly notify in writing the Requesting Party and the Non-Party 2 that some or all of the information requested is subject to a confidentiality agreement 3 with a Non-Party; 4 (2) promptly provide the Non-Party with a copy of the Stipulated 5 Protective Order in this Action, the relevant discovery request(s), and a reasonably 6 specific description of the information requested; and 7 (3) make the information requested available for inspection by the 8 Non-Party, if requested. 9 (c) If the Non-Party fails to seek a protective order from this court within 10 14 days of receiving the notice and accompanying information, the Receiving Party 11 may produce the Non-Party’s confidential information responsive to the discovery 12 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 13 not produce any information in its possession or control that is subject to the 14 confidentiality agreement with the Non-Party before a determination by the court. 15 Absent a court order to the contrary, the Non-Party shall bear the burden and expense 16 of seeking protection in this court of its Protected Material. 17 18 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 19 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 20 Protected Material to any person or in any circumstance not authorized under this 21 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 22 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 23 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 24 persons to whom unauthorized disclosures were made of all the terms of this Order, 25 and (d) request such person or persons to execute the “Acknowledgment and 26 Agreement to Be Bound” that is attached hereto as Exhibit A. 27 28 12 Case 2:22-cv-08371-SVW-PD Document 24 Filed 02/09/23 Page 13 of 17 Page ID #:184

1 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 2 PROTECTED MATERIAL 3 When a Producing Party gives notice to Receiving Parties that certain 4 inadvertently produced material is subject to a claim of privilege or other protection, 5 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 6 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 7 may be established in an e-discovery order that provides for production without prior 8 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 9 parties reach an agreement on the effect of disclosure of a communication or 10 information covered by the attorney-client privilege or work product protection, the 11 parties may incorporate their agreement in the stipulated protective order submitted 12 to the court. 13 14 12. MISCELLANEOUS 15 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 16 person to seek its modification by the Court in the future. 17 12.2 Right to Assert Other Objections. By stipulating to the entry of this 18 Protective Order no Party waives any right it otherwise would have to object to 19 disclosing or producing any information or item on any ground not addressed in this 20 Stipulated Protective Order. Similarly, no Party waives any right to object on any 21 ground to use in evidence of any of the material covered by this Protective Order. 22 12.3 Filing Protected Material. A Party that seeks to file under seal any 23 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 24 only be filed under seal pursuant to a court order authorizing the sealing of the 25 specific Protected Material at issue. If a Party's request to file Protected Material 26 under seal is denied by the court, then the Receiving Party may file the information 27 in the public record unless otherwise instructed by the court. 28 13 Case 2:22-cv-08371-SVW-PD Document 24 Filed 02/09/23 Page 14 of 17 Page ID #:185

1 13. FINAL DISPOSITION 2 After the final disposition of this Action, as defined in paragraph 4, within 60 3 days of a written request by the Designating Party, each Receiving Party must return 4 all Protected Material to the Producing Party or destroy such material. As used in 5 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 6 summaries, and any other format reproducing or capturing any of the Protected 7 Material. Whether the Protected Material is returned or destroyed, the Receiving 8 Party must submit a written certification to the Producing Party (and, if not the same 9 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 10 (by category, where appropriate) all the Protected Material that was returned or 11 destroyed and (2)affirms that the Receiving Party has not retained any copies, 12 abstracts, compilations, summaries or any other format reproducing or capturing any 13 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 14 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 15 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 16 reports, attorney work product, and consultant and expert work product, even if such 17 materials contain Protected Material. Any such archival copies that contain or 18 constitute Protected Material remain subject to this Protective Order as set forth in 19 Section 4 (DURATION). 20 The Parties agree to treat documents/information as CONFIDENTIAL under 21 this Protective Order if so marked/designated even prior to the Court’s entry of this 22 Order. 23 // 24 // 25 // 26 // 27 // 28 // 14 Case 2:22-cv-08371-SVW-PD Document 24 Filed 02/09/23 Page 15 of 17 Page ID #:186

1 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: February 8, 2023 MAYNARD COOPER & GALE LLP

8 By: /s/ Vivian I. Orlando 9 VIVIAN I. ORLANDO KAREN T. TSUI 10 Attorneys for Plaintiff-in-Interpleader Transamerica Life Insurance Company 11

12 Dated: February 8, 2023 PETTLER & MILLER, LLP

13 By: /s/ Ernesto F. Aldover 14 JAY RILEY ERNESTO F. ALDOVER 15 Attorneys for Defendant-in-Interpleader Carmen Chavez 16

17 Dated: February 8, 2023 KNEZ LAW GROUP, LLP

18 By: /s/ Matthew Knez 19 MATTHEW KNEZ Attorneys for Defendant-in-Interpleader 20 Elizabeth Avila

21 Signature Attestation 22 Pursuant to Local Rule 5-4, 3.4(a)(2)(l), I hereby certify that the content of this 23 document is acceptable to counsel for Defendants-in-Interpleader Carmen Chavez 24 and Elizabeth Avila, and that I have obtained authorization to affix their electronic 25 signatures to this document. 26 /s/ Vivian I. Orlando 27 Vivian I. Orlando 28 15 Case 4:22-cv-08371-SVW-PD Document 24 Filed 02/09/23 Page 16o0f17 Page ID #:187

1 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 3 os 4 || DATED: February 9, 2023 Fabia Danakoe_ 5 HON. PATRICIA DONAHUE United States Magistrate Judge 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 16

Case 2:22-cv-08371-SVW-PD Document 24 Filed 02/09/23 Page 17 of 17 Page ID #:188

1 EXHIBIT A ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 2

3 I, ________________________ [print or type full name], of 4 _________________ [print or type full address], declare under penalty of perjury 5 that I have read in its entirety and understand the Stipulated Protective Order that 6 was issued by the United States District Court for the Central District of California 7 on [date] in the case of Transamerica Life Insurance Company v. Elizabeth 8 Avila, et al., Case No. 2:22-cv-08371-SVW-PD. 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 11 punishment in the nature of contempt. I solemnly promise that I will not disclose 12 in any manner any information or item that is subject to this Stipulated Protective 13 Order to any person or entity except in strict compliance with the provisions of this 14 Order. 15 I further agree to submit to the jurisdiction of the United States District Court for 16 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 full address and telephone number] as 20 my California agent for service of process in connection with this action or any 21 proceedings related to enforcement of this Stipulated Protective Order. 22

23 Date: __________________________ 24 City and State where sworn and signed: _____________________________ 25

26 Printed name: ____________________________________ 27

28 Signature: ________________________________ 17