1 Gretchen M. Nelson, SBN 112566 Charles J. Crueger, Esq. (PHV forthcoming) [email protected] [email protected] 2 Gabriel S. Barenfeld, SBN 224146 Erin K. Dickinson, Esq. (PHV forthcoming) 3 [email protected] [email protected] NELSON & FRAENKEL LLP Ben Kaplan, Esq. (PHV forthcoming) 4 601 S. Figueroa St., Suite 2050 [email protected] 5 Los Angeles, CA 90017 CRUEGER DICKINSON LLC Telephone No.: (844) 622-6469 4532 North Oakland Avenue 6 Facsimile No.: (213) 622-6019 Whitefish Bay, WI 53211 Tel.: (414) 210-3868 7

8 Edward A. Wallace (PHV forthcoming) [email protected] 9 Mark R. Miller (PHV forthcoming) [email protected] 10 WALLACE MILLER 11 150 N. Wacker Drive, Suite 1100 Chicago, IL 60606 12 Tel.: (312) 626-9760 13 Counsel for Plaintiff & the Proposed 14 Classes 15 16 UNITED STATES DISTRICT COURT 17 CENTRAL DISTRICT OF CALIFORNIA 18

19 JASIBEL CANCHOLA, individually Case No.: 8:23-cv-00734-FWS-ADS and on behalf of all others similarly 20 STIPULATED PROTECTIVE situated; 21 ORDER Plaintiffs, 22 CLASS ACTION vs.

23

24 ALLSTATE INSURANCE

25 COMPANY, et al., Defendants 26

27 N O T E: C H AN G E S M A D E B Y TH E C O U R T 28 Plaintiffs Jasibel Canchola and Carlos Ochoa (“Plaintiffs”) and Defendant Allstate 1 Insurance Company (“Allstate”) (together, “parties”), by and through their undersigned 2 attorneys of record, hereby stipulate and agree to the following. 3 I. PURPOSES AND LIMITATIONS 4 A. Discovery in this action is likely to involve production of confidential, 5 proprietary, or private information for which special protection from public disclosure 6 and from use for any purpose other than prosecuting this litigation may be warranted. 7 Accordingly, the parties hereby stipulate to and petition the Court to enter the following 8 Stipulated Protective Order (the “Order”). The parties acknowledge that this Order does 9 not confer blanket protections on all disclosures or responses to discovery and that the 10 protection it affords from public disclosure and use extends only to the limited 11 information or items that are entitled to confidential treatment under the applicable legal 12 principles. The parties further acknowledge, as set forth in Section XIII(C), below, that 13 this Order does not entitle them to file confidential or highly confidential information 14 under seal; Civil Local Rule 79-5 sets forth the procedures that must be followed and the 15 standards that will be applied when a party seeks permission from the Court to file 16 material under seal. 17 II. GOOD CAUSE STATEMENT 18 A. This action is likely to involve valuable commercial, financial, proprietary, 19 and/or private information for which special protection from public disclosure and from 20 use for any purpose other than prosecution of this action is warranted. Such confidential 21 and proprietary materials and information consist of, among other things, confidential 22 business or financial information, information regarding confidential business practices, 23 private financial or tax information, or other confidential commercial information 24 (including information implicating privacy rights of third parties), information otherwise 25 generally unavailable to the public, or which may be privileged or otherwise protected 26 from disclosure under state or federal statutes, court rules, case decisions, or common 27 law. Moreover, this action is likely to involve certain information that contains highly 28 sensitive materials about business strategy which could cause irreparable damage to certain parties and non-parties if reviewed by other parties or non-parties themselves, as 1 opposed to their outside counsel only. Accordingly, to expedite the flow of information, 2 to facilitate the prompt resolution of disputes over confidentiality of discovery materials, 3 to adequately protect information the parties are entitled to keep confidential, to ensure 4 that the parties are permitted reasonable necessary uses of such material in preparation 5 for and in the conduct of trial, to address their handling at the end of the litigation, and 6 serve the ends of justice, a protective order for such information is justified in this matter. 7 It is the intent of the parties that information will not be designated as confidential or 8 highly confidential for tactical reasons and that nothing be so designated without a good 9 faith belief that it has been maintained in a confidential, non-public manner, and there is 10 good cause why it should not be part of the public record of this case. 11 III. DEFINITIONS 12 A. Action: This pending federal law suit. 13 B. Challenging Party: A Party or Non-Party that challenges the designation of 14 information or items under this Order. 15 C. “CONFIDENTIAL” Information or Items: Information (regardless of how it 16 is generated, stored or maintained) or tangible things that qualify for protection under 17 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 18 Statement. 19 D. Counsel: Outside Counsel of Record and House Counsel (as well as their 20 support staff). 21 E. Designating Party: A Party or Non-Party that designates information or 22 items that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 23 F. Disclosure or Discovery Material: All items or information, regardless of 24 the medium or manner in which it is generated, stored, or maintained (including, among 25 other things, testimony, transcripts, and tangible things), that are produced or generated in 26 disclosures or responses to discovery in this matter. 27 28 G. Expert: A person with specialized knowledge or experience in a matter 1 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 2 expert witness or as a consultant in this Action. 3 H. “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” Information 4 or Items: any Confidential Information about a Designating Party’s finances or business 5 strategy that the Designating Party reasonably believes to be competitively sensitive such 6 that the Designating Party could suffer competitive harm if such information were 7 disclosed to persons other than the Designating Party’s employees. 8 I. House Counsel: Attorneys who are employees of a party to this Action. 9 House Counsel does not include Outside Counsel of Record or any other outside counsel. 10 J. Non-Party: Any natural person, partnership, corporation, association, or 11 other legal entity not named as a Party to this action. 12 K. Outside Counsel of Record: Attorneys who are not employees of a party to 13 this Action but are retained to represent or advise a party to this Action and have 14 appeared in this Action on behalf of that party or are affiliated with a law firm which has 15 appeared on behalf of that party, and includes support staff. 16 L. Party: Jasibel Canchola, Carlos Ochoa, Allstate Insurance Company, and 17 any other person or entity who is subsequently added as a named party in this action, 18 including all of their officers, directors, employees, consultants, Experts, and Outside 19 Counsel of Record (and their support staffs). 20 M. Producing Party: A Party or Non-Party that produces Disclosure or 21 Discovery Material in this Action. 22 N. Professional Vendors: Persons or entities that provide litigation support 23 services (e.g., photocopying, videotaping, translating, preparing exhibits or 24 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 25 their employees and subcontractors. 26 O. Protected Material: Any Disclosure or Discovery Material that is designated 27 as “CONFIDENTIAL” or as “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 28 ONLY.” P. Receiving Party: A Party that receives Disclosure or Discovery Material 1 from a Producing Party. 2 IV. SCOPE 3 A. The protections conferred by this Stipulation and Order cover not only 4 Protected Material (as defined above), but also (1) any information copied or extracted 5 from Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 6 Material; and (3) any testimony, conversations, or presentations by Parties or their 7 Counsel that might reveal Protected Material. 8 B. Any use of Protected Material at trial shall be governed by the orders of the 9 trial judge. This Order does not govern the use of Protected Material at trial. 10 V. DURATION 11 A. Once a case proceeds to trial, all of the information that was designated as 12 confidential or highly confidential or maintained pursuant to this Protective Order 13 becomes public and will be presumptively available to all members of the public if part 14 of the court record, including the press, unless compelling reasons supported by specific 15 factual findings to proceed otherwise are made to the trial judge in advance of the trial. 16 See Kamakana v. City and County of Honolulu,

(9th Cir. 2006) 17 (distinguishing “good cause” showing for sealing documents produced in discovery from 18 “compelling reasons” standard when merits-related documents are part of court record). 19 Accordingly, the terms of this Protective Order do not extend beyond the commencement 20 of the trial for any material made part of the court record. 21 B. For information not subject to Section V.A, even after final disposition of 22 this litigation, the confidentiality obligations imposed by this Order shall remain in effect 23 until a Designating Party agrees otherwise in writing or a court order otherwise directs. 24 Final disposition shall be deemed to be the later of (1) dismissal of all claims and 25 defenses in this Action, with or without prejudice; and (2) final judgment herein after the 26 completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of this 27 Action, including the time limits for filing any motions or applications for extension of 28 time pursuant to applicable law. VI. DESIGNATING PROTECTED MATERIAL 1 A. Exercise of Restraint and Care in Designating Material for Protection 2 1. Each Party or Non-Party that designates information or items for 3 protection under this Order must take care to limit any such designation to specific 4 material that qualifies under the appropriate standards. The Designating Party must 5 designate for protection only those parts of material, documents, items, or oral or written 6 communications that qualify so that other portions of the material, documents, items, or 7 communications for which protection is not warranted are not swept unjustifiably within 8 the ambit of this Order. 9 2. Mass, indiscriminate, or routinized designations not supported by the 10 Good Cause Statement above are prohibited. Designations that are shown to be clearly 11 unjustified or that have been made for an improper purpose (e.g., to unnecessarily 12 encumber the case development process or to impose unnecessary expenses and burdens 13 on other parties) may expose the Designating Party to sanctions. 14 3. Redacting responsive documents exclusively for relevancy purposes is 15 prohibited. This Order will protect any sensitive information a Designating Party alleges 16 is irrelevant within the relevant and responsive document. 17 4. If it comes to a Designating Party’s attention that information or items 18 that it designated for protection do not qualify for protection, that Designating Party must 19 promptly notify all other Parties that it is withdrawing the inapplicable designation. 20 B. Manner and Timing of Designations 21 1. Except as otherwise provided in this Order (see, e.g., Section B(2)(b) 22 below), or as otherwise stipulated or ordered, Disclosure or Discovery Material that 23 qualifies for protection under this Order must be clearly so designated before or at the 24 time the material is disclosed or produced. 25 2. Designation in conformity with this Order requires the following: 26 a. For information in documentary form (e.g., paper or electronic 27 documents, but excluding transcripts of depositions or other pretrial or trial proceedings), 28 that the Producing Party affix at a minimum, the legend “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” (hereinafter 1 “CONFIDENTIAL legend”), to each page that contains protected material. If only a 2 portion or portions of the material on a page qualifies for protection, the Producing Party 3 also must clearly identify the protected portion(s) (e.g., by making appropriate markings 4 in the margins). 5 b. A Party or Non-Party that makes original documents available 6 for inspection need not designate them for protection until after the inspecting Party has 7 indicated which documents it would like copied and produced. During the inspection and 8 before the designation, all of the material made available for inspection shall be deemed 9 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY.” After the inspecting 10 Party has identified the documents it wants copied and produced, the Producing Party 11 must determine which documents, or portions thereof, qualify for protection under this 12 Order. Then, before producing the specified documents, the Producing Party must affix 13 the “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 14 portion or portions of the material on a page qualifies for protection, the Producing Party 15 also must clearly identify the protected portion(s) (e.g., by making appropriate markings 16 in the margins). 17 c. For testimony given in depositions, that the Designating Party 18 identify the Disclosure or Discovery Material on the record, before the close of the 19 deposition all protected testimony. 20 d. For information produced in form other than document and for 21 any other tangible items, that the Producing Party affix in a prominent place on the 22 exterior of the container or containers in which the information is stored the legend 23 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY.” 24 If only a portion or portions of the information warrants protection, the Producing Party, 25 to the extent practicable, shall identify the protected portion(s). 26 C. Inadvertent Failure to Designate 27 1. If timely corrected, an inadvertent failure to designate qualified 28 information or items does not, standing alone, waive the Designating Party’s right to secure protection under this Order for such material. Upon timely correction of a 1 designation, the Receiving Party must make reasonable efforts to assure that the material 2 is treated in accordance with the provisions of this Order. 3 VII. CHALLENGING CONFIDENTIALITY DESIGNATIONS 4 A. Timing of Challenges 5 1. Any Party or Non-Party may challenge a designation of 6 confidentiality at any time that is consistent with the Court’s Scheduling Order. 7 B. Meet and Confer 8 1. The Challenging Party shall initiate the dispute resolution process 9 under Local Rule 37.1 et seq. 10 C. The burden of persuasion in any such challenge proceeding shall be on the 11 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., 12 to harass or impose unnecessary expenses and burdens on other parties) may expose the 13 Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn 14 the confidentiality designation, all parties shall continue to afford the material in question 15 the level of protection to which it is entitled under the Producing Party’s designation until 16 the Court rules on the challenge. 17 VIII. ACCESS TO AND USE OF PROTECTED MATERIAL 18 A. Basic Principles 19 1. A Receiving Party may use Protected Material that is disclosed or 20 produced by another Party or by a Non-Party in connection with this Action only for 21 prosecuting, defending, or attempting to settle this Action. Such Protected Material may 22 be disclosed only to the categories of persons and under the conditions described in this 23 Order. When the Action has been terminated, a Receiving Party must comply with the 24 provisions of Section XIV below. 25 2. Protected Material must be stored and maintained by a Receiving 26 Party at a location and in a secure manner that ensures that access is limited to the 27 persons authorized under this Order. 28 B. Disclosure of “CONFIDENTIAL” Information or Items 1. Unless otherwise ordered by the Court or permitted in writing by the 1 Designating Party, a Receiving Party may disclose any information or item designated 2 “CONFIDENTIAL” only to: 3 a. The Receiving Party’s Outside Counsel of Record in this 4 Action, as well as employees of said Outside Counsel of Record to whom it is reasonably 5 necessary to disclose the information for this Action; 6 b. The officers, directors, and employees (including House 7 Counsel) of the Receiving Party to whom disclosure is reasonably necessary for this 8 Action; 9 c. Experts (as defined in this Order) of the Receiving Party to 10 whom disclosure is reasonably necessary for this Action and who have signed the 11 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 12 d. The Court and its personnel; 13 e. Court reporters and their staff; 14 f. Professional jury or trial consultants, mock jurors, and 15 Professional Vendors to whom disclosure is reasonably necessary for this Action and 16 who have signed the “Acknowledgment and Agreement to be Bound” attached as Exhibit 17 A hereto; 18 g. The author or recipient of a document containing the 19 information or a custodian or other person who otherwise possessed or knew the 20 information; 21 h. During their depositions, witnesses, and attorneys for witnesses, 22 in the Action to whom disclosure is reasonably necessary provided: (i) the deposing party 23 requests that the witness sign the “Acknowledgment and Agreement to Be Bound;” and 24 (ii) they will not be permitted to keep any confidential information unless they sign the 25 “Acknowledgment and Agreement to Be Bound,” unless otherwise agreed by the 26 Designating Party or ordered by the Court. Pages of transcribed deposition testimony or 27 exhibits to depositions that reveal Protected Material may be separately bound by the 28 court reporter and may not be disclosed to anyone except as permitted under this Order; 1 and 2 i. Any mediator or settlement officer, and their supporting 3 personnel, mutually agreed upon by any of the parties engaged in settlement discussions. 4 C. Disclosure of “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 5 ONLY” Information or Items. 6 1. Unless otherwise ordered by the court or permitted in writing by the 7 Designating Party, a Receiving Party may disclose any information or item designated 8 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” only to: 9 a. the Receiving Party’s Outside Counsel of Record in this action, 10 as well as Professional Vendors of said Outside Counsel of Record to whom it is 11 reasonably necessary to disclose the information for this litigation and who have signed 12 the “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit A; 13 b. Experts of the Receiving Party (1) to whom disclosure is 14 reasonably necessary for this litigation, and (2) who have signed the “Acknowledgment 15 and Agreement to Be Bound” (Exhibit A); 16 c. the court and its personnel and court reporters and their staff; 17 d. professional jury or trial consultants, and Professional Vendors 18 to whom disclosure is reasonably necessary for this litigation and who have signed the 19 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 20 f. the author or recipient of a document containing the 21 information or a custodian or other person who otherwise possessed or knew the 22 information; 23 g. During their depositions, witnesses, and attorneys for witnesses, 24 in the Action to whom disclosure is reasonably necessary provided: (i) the witness and 25 court reporter, prior to being shown the document, sign the “Acknowledgment and 26 Agreement to Be Bound;” and (ii) the witness is not permitted to keep any confidential 27 information, unless otherwise agreed by the Designating Party or ordered by the Court. If 28 the deposed witness is an Allstate employee who is requested, but declines, to sign the “Acknowledgement and Agreement to be Bound,” then the deposing party may use the 1 document designated “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” 2 during the deposition notwithstanding limitation (i) above. Pages of transcribed 3 deposition testimony or exhibits to depositions that reveal Protected Material may be 4 separately bound by the court reporter and may not be disclosed to anyone except as 5 permitted under this Order; and 6 h. Any mediator or settlement officer, and their supporting 7 personnel, mutually agreed upon by any of the parties engaged in settlement discussions 8 and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A). 9 IX. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 10 OTHER LITIGATION 11 A. If a Party is served with a subpoena or a court order issued in other litigation 12 that compels disclosure of any information or items designated in this Action as 13 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY,” 14 that Party must: 15 1. Promptly notify in writing the Designating Party. Such notification 16 shall include a copy of the subpoena or court order; 17 2. Promptly notify in writing the party who caused the subpoena or order 18 to issue in the other litigation that some or all of the material covered by the subpoena or 19 order is subject to this Protective Order. Such notification shall include a copy of this 20 Order; and 21 3. Cooperate with respect to all reasonable procedures sought to be 22 pursued by the Designating Party whose Protected Material may be affected. 23 B. If the Designating Party timely seeks a protective order, the Party served 24 with the subpoena or court order shall not produce any information designated in this 25 action as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 26 ONLY” before a determination by the Court from which the subpoena or order issued, 27 unless the Party has obtained the Designating Party’s permission. The Designating Party 28 shall bear the burden and expense of seeking protection in that court of its confidential material. Nothing in these provisions should be construed as authorizing or encouraging 1 a Receiving Party in this Action to disobey a lawful directive from another court. 2 X. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 3 PRODUCED IN THIS LITIGATION 4 A. The terms of this Order are applicable to information produced by a Non- 5 Party in this Action and designated as “CONFIDENTIAL” or “HIGHLY 6 CONFIDENTIAL – ATTORNEYS’ EYES ONLY.” Such information produced by 7 Non-Parties in connection with this litigation is protected by the remedies and relief 8 provided by this Order. Nothing in these provisions should be construed as prohibiting a 9 Non-Party from seeking additional protections. 10 B. In the event that a Party is required, by a valid discovery request, to produce 11 a Non-Party’s confidential information in its possession, and the Party is subject to an 12 agreement with the Non-Party not to produce the Non-Party’s confidential information, 13 then the Party shall: 14 1. Promptly notify in writing the Requesting Party and the Non-Party 15 that some or all of the information requested is subject to a confidentiality agreement 16 with a Non-Party; 17 2. Promptly provide the Non-Party with a copy of the Stipulated 18 Protective Order in this Action, the relevant discovery request(s), and a reasonably 19 specific description of the information requested; and 20 3. Make the information requested available for inspection by the Non- 21 Party, if requested. 22 C. If the Non-Party fails to seek a protective order from this court within 14 23 days of receiving the notice and accompanying information, the Receiving Party may 24 produce the Non-Party’s confidential information responsive to the discovery request. If 25 the Non-Party timely seeks a protective order, the Receiving Party shall not produce any 26 information in its possession or control that is subject to the confidentiality agreement 27 with the Non-Party before a determination by the court. Absent a court order to the 28 contrary, the Non-Party shall bear the burden and expense of seeking protection in this 1 court of its Protected Material. 2 XI. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 3 A. If a Receiving Party learns that, by inadvertence or otherwise, it has 4 disclosed Protected Material to any person or in any circumstance not authorized under 5 this Order, the Receiving Party must immediately (1) notify in writing the Designating 6 Party of the unauthorized disclosures, (2) use its best efforts to retrieve all unauthorized 7 copies of the Protected Material, (3) inform the person or persons to whom unauthorized 8 disclosures were made of all the terms of this Order, and (4) request such person or 9 persons to execute the “Acknowledgment and Agreement to be Bound” that is attached 10 hereto as Exhibit A. 11 XII. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 12 PROTECTED MATERIAL 13 A. When a Producing Party gives notice to Receiving Parties that certain 14 inadvertently produced material is subject to a claim of privilege or other protection, the 15 obligations of the Receiving Parties are those set forth in Federal Rule of Civil Procedure 16 26(b)(5)(B). This provision is not intended to modify whatever procedure may be 17 established in an e-discovery order that provides for production without prior privilege 18 review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the parties reach 19 an agreement on the effect of disclosure of a communication or information covered by 20 the attorney-client privilege or work product protection, the parties may incorporate their 21 agreement in the Stipulated Protective Order submitted to the Court. 22 XIII. MISCELLANEOUS 23 A. Right to Further Relief 24 1. Nothing in this Order abridges the right of any person to seek its 25 modification by the Court in the future. 26 B. Right to Assert Other Objections 27 1. By stipulating to the entry of this Order, no Party waives any right it 28 otherwise would have to object to disclosing or producing any information or item on any ground not addressed in this Order. Similarly, no Party waives any right to object on any 1 ground to use in evidence of any of the material covered by this Order. 2 C. Filing Protected Material 3 1. A Party that seeks to file under seal any Protected Material must 4 comply with Civil Local Rule 79-5. Protected Material may only be filed under seal 5 pursuant to a court order authorizing the sealing of the specific Protected Material at 6 issue. If a Party's request to file Protected Material under seal is denied by the Court, 7 then the Receiving Party may file the information in the public record unless otherwise 8 instructed by the Court. 9 XIV. FINAL DISPOSITION 10 A. After the final disposition of this Action, as defined in Section V, within 11 sixty (60) days of a written request by the Designating Party, each Receiving Party must 12 return all Protected Material to the Producing Party or destroy such material. As used in 13 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 14 summaries, and any other format reproducing or capturing any of the Protected Material. 15 Whether the Protected Material is returned or destroyed, the Receiving Party must submit 16 a written certification to the Producing Party (and, if not the same person or entity, to the 17 Designating Party) by the 60 day deadline that (1) identifies (by category, where 18 appropriate) all the Protected Material that was returned or destroyed and (2) affirms that 19 the Receiving Party has not retained any copies, abstracts, compilations, summaries or 20 any other format reproducing or capturing any of the Protected Material. 21 Notwithstanding this provision, Counsel are entitled to retain an archival copy of all 22 pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda, 23 correspondence, deposition and trial exhibits, expert reports, attorney work product, and 24 consultant and expert work product, even if such materials contain Protected Material. 25 Any such archival copies that contain or constitute Protected Material remain subject to 26 this Protective Order as set forth in Section V. 27 B. Any violation of this Order may be punished by any and all appropriate 28 measures including, without limitation, contempt proceedings and/or monetary sanctions. IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 1

2 DATED: July 19, 2023 NELSON & FRAENKEL LLP 3 4

5 By: /s/ Gabriel S. Barenfeld 6 Gretchen Nelson Gabriel S. Barenfeld 7

8 Attorneys for Plaintiff and the Proposed Class

9 DATED: July 19, 2023 CRUEGER DICKINSON LLC 10

11

12 By: /s/ Charles J. Crueger 13 Charles J. Crueger 14 Erin K. Dickinson

15 Attorneys for Plaintiff and the Proposed Class 16

17 DATED: July 19, 2023 WALLACE MILLER 18

19

20 By: /s/ Edward A. Wallace 21 Edward A. Wallace 22 Mark R. Miller

23 Attorneys for Plaintiff and the Proposed 24 Class 25 26 27 28 1 DATED: July 19, 2023 LITTLER MENDELSON P.C.

2

3 4 By: /s/ Robert S. Blumberg Keith A. Jacoby 5 Robert S. Blumberg 6 Jaime B. Laurent Emily J. Atherton 7

8 Attorneys for Defendant Allstate Insurance 9 Company

10 11 12 DATED: July 19, 2023 AKIN GUMP STRAUSS HAUER & FELD LLP 13

14

15 By: /s/ Neal Marder 16 Robert G. Lian Jr. Neal Marder 17 Josh Rubin 18 Donna Mezias

19 Attorneys for Defendant Allstate Insurance 20 Company 21 22

23 24 25

26 27 28 *Pursuant to L.R. 5-4.3.4(a)(2)(i), the undersigned attorney hereby attests that all 1 other signatories listed, and on whose behalf the filing is submitted, concur in the filing’s 2 content and have authorized the filing. 3

4 DATED: July 19, 2023 NELSON & FRAENKEL LLP 5

6

7 By: /s/ Gabriel S. Barenfeld 8 Gabriel S. Barenfeld 9 Attorneys Plaintiff & the Proposed Classes 10 ORDER 11 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 12

13 DATED: July 19, 2023 14

15

16 /s/ Autumn D. Spaeth 17 Honorable Autumn D. Spaeth

18 United States Magistrate Judge 19 20 21 22 23 24 25 26 27 28 EXHIBIT A 1 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 2 I, [print or type full name], of 3 [print or type full address], declare under penalty of perjury that I have read in its entirety 4 and understand the Stipulated Protective Order that was issue by the United States 5 District Court for the Central District of California on [DATE] in the case of Canchola v. 6 Allstate Insurance Company, Case No. 8:23-cv-00734-FWS-ADS . I agree to comply 7 with and to be bound by all the terms of this Stipulated Protective Order and I understand 8 and acknowledge that failure to so comply could expose me to sanctions and punishment 9 in the nature of contempt. I solemnly promise that I will not disclose in any manner any 10 information or item that is subject to this Stipulated Protective Order to any person or 11 entity except in strict compliance with the provisions of this Order. 12 I further agree to submit to the jurisdiction of the United States District Court for 13 the Central District of California for the purpose of enforcing the terms of this Stipulated 14 Protective Order, even if such enforcement proceedings occur after termination of this 15 action. I hereby appoint [print or type full name] of 16 [print or type full address and telephone number] as my California 17 agent for service of process in connection with this action or any proceedings related to 18 enforcement of this Stipulated Protective Order. 19 Date: ______________________________________ 20 City and State where sworn and signed: ________________________________ 21 Printed name: _______________________________ 22 Signature: __________________________________ 23 24 25 26 27 28