1 |} MICHAEL A.S. NEWMAN (SBN 205299) [email protected] 2 || JOHN R. HORSTMANN (SBN 327129) Tlorsmann cemay nar dnexsen.com 3 || MAYNARD NEXSEN LLP 10100 Santa Monica Boulevard, Suite 550 4 || Los Angeles, CA 90067 5 Telephone: 310.596.4500 Attorneys for Defendant 6 || Farmers New World Life Insurance Company 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 ||) ISABEL SHAFF, Case No. 2:17-cv-03610-JAK-E 12 Plaintiff, (Honorable John A. Kronstadt)

||} FARMERS NEW WORLD LIFE STIPULATED PROTECTIVE INSURANCE COMPANY AKA ORDER 15 || FARMERS LIFE INSURANCE, and 6 DOES | to 50, inclusive, Defendants. 17 18 Complaint Filed: December 14, 2016 19 20 21 22 23 24 25 26 27 28 STIPLIT ATED PROTECTIVE ORDER

I 1. A. PURPOSES AND LIMITATIONS 2 Discovery in this action is likely to involve production of confidential, 3 || proprietary or private information for which special protection from public disclosure 4 || and from use for any purpose other than prosecuting this litigation may be warranted. 5 || Accordingly, the parties hereby stipulate to and petition the Court to enter the 6 || following Stipulated Protective Order. The parties acknowledge that this Order does 7 ||not confer blanket protections on all disclosures or responses to discovery and that 8 ||the protection it affords from public disclosure and use extends only to the limited 9 ||information or items that are entitled to confidential treatment under the applicable 10 || legal principles. 11 B. GOOD CAUSE STATEMENT 12 This action is likely to involve trade secrets, customer and pricing lists and 13 |/other valuable research, development, commercial, financial, technical and/or 14 || proprietary information for which special protection from public disclosure and from IS |)use for any purpose other than prosecution of this action is warranted. Such 16 || confidential and proprietary materials and information consist of, among other things, 17 ||confidential business or financial information, information regarding confidential 18 |/business practices, or other confidential research, development, or commercial 19 |/information (including information implicating privacy rights of third parties), 20 || information otherwise generally unavailable to the public, or which may be privileged 21 || or otherwise protected from disclosure under state or federal statutes, court rules, case 22 decisions, or common law. Accordingly, to expedite the flow of information, to 23 || facilitate the prompt resolution of disputes over confidentiality of discovery materials, 24 ||to adequately protect information the parties are entitled to keep confidential, to 25 || ensure that the parties are permitted reasonable necessary uses of such material in 26 || preparation for and in the conduct of trial, to address their handling at the end of the 27 || litigation, and serve the ends of justice, a protective order for such information is 28 justified in this matter. It is the intent of the parties that information will not be STIPL]T ATED PROTECTIVE ORDER

1 ||designated as confidential for tactical reasons and that nothing be so designated 2 || without a good faith belief that it has been maintained in a confidential, non-public 3 manner, and there is good cause why it should not be part of the public record of this 4 || case. 5 C. ACKNOWLEDGEMENT OF PROCEDURE FOR FILING UNDER 6 SEAL 7 The parties further acknowledge, as set forth in Section 12.3, below, that this 8 Stipulated Protective Order does not entitle them to file confidential information 9 || under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and 10 || the standards that will be applied when a party seeks permission from the court to file 11 |) material under seal. 12 There is a strong presumption that the public has a right of access to judicial 13 || proceedings and records in civil cases. In connection with non-dispositive motions, 14 || good cause must be shown to support a filing under seal. See Kamakana v. City and 1S || County of Honolulu,

, 1176 (9th Cir._2006), Phillips v. Gen. Motors 16 || Corp.,

, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc., 17 ||

(E.D. Wis. 1999) (even stipulated protective orders require good 18 ||cause showing), and a specific showing of good cause or compelling reasons with 19 ||)proper evidentiary support and legal justification, must be made with respect to 20 || Protected Material that a party seeks to file under seal. The parties’ mere designation 21 ||of Disclosure or Discovery Material as CONFIDENTIAL does not— without the 22 ||submission of competent evidence by declaration, establishing that the material 23 ||sought to be filed under seal qualifies as confidential, privileged, or otherwise 24 || protectable—constitute good cause. 25 Further, if a party requests sealing related to a dispositive motion or trial, then 26 || compelling reasons, not only good cause, for the sealing must be shown, and the relief 27 ||sought shall be narrowly tailored to serve the specific interest to be protected. See 28 || Pintos v. Pacific Creditors Ass’n.,

(9th Cir_2010). For each - STIPL]T ATED PROTECTIVE ORDER

1 || item or type of information, document, or thing sought to be filed or introduced under 2 || seal in connection with a dispositive motion or trial, the party seeking protection must 3 || articulate compelling reasons, supported by specific facts and legal justification, for 4 || the requested sealing order. Again, competent evidence supporting the application to 5 || file documents under seal must be provided by declaration. 6 Any document that is not confidential, privileged, or otherwise protectable in 7 entirety will not be filed under seal if the confidential portions can be redacted. If 8 || documents can be redacted, then a redacted version for public viewing, omitting only 9 || the confidential, privileged, or otherwise protectable portions of the document, shall 10 filed. Any application that seeks to file documents under seal in their entirety 11 || should include an explanation of why redaction is not feasible. 12 DEFINITIONS 13 2.1 Action: Isabel Shaff v. Farmers New World Life Insurance Company, 14 || United States District Court for the Central District of California, Case No. 2:17-cv- 15 ||03610-JAK-E. 16 2.2 Challenging Party: a Party or Non-Party that challenges the designation 17 || of information or items under this Order. 18 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 19 || how it is generated, stored or maintained) or tangible things that qualify for protection 20 || under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 21 || Cause Statement. 22 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 23 || support staff). 24 2.5 Designating Party: a Party or Non-Party that designates information or 25 ||items that it produces in disclosures or in responses to discovery as 26 || “CONFIDENTIAL.” 27 2.6 Disclosure or Discovery Material: all items or information, regardless of 28 ||the medium or manner in which it is generated, stored, or maintained (including, ; STIPL]T ATED PROTECTIVE ORDER

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

1 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 extracted 4 ||from Protected Material; (2) all copies, excerpts, summaries, or compilations of 5 || Protected Material; and (3) any testimony, conversations, or presentations by Parties 6 || 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 IS |/of the trial. See Kamakana, 447 F.3d at 1180-81 (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, the 18 || terms of this protective order do not extend beyond the commencement of the trial. 19 ||5. DESIGNATED PROTECTED MATERIAL 20 5.1 Exercise of Restraint and Care in Designating Material for Protection. 21 || Each Party or Non-Party that designates information or items for protection under this 22 || Order must take care to limit any such designation to specific material that qualifies 23 || under the appropriate standards. The Designating Party must designate for protection 24 || only those parts of material, documents, items or oral or written communications that 25 || qualify so that other portions of the material, documents, items or communications 26 || for which protection is not warranted are not swept unjustifiably within the ambit of 27 || this Order, 28 > STIPL]T ATED PROTECTIVE ORDER

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 Party 5 || 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 of the material on a page qualifies for 20 || protection, the Producing Party also must clearly identify the protected portion(s) 21 || (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 before 25 ||the designation, all of the material made available for inspection shall be deemed 26 ||“CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 27 ||copied and produced, the Producing Party must determine which documents, or 28 || portions thereof, qualify for protection under this Order. Then, before producing the 6 STIPL]T ATED PROTECTIVE ORDER

1 || specified documents, the Producing Party must affix the “CONFIDENTIAL legend” 2 ||to each page that contains Protected Material. If only a portion of the material on a 3 ||page qualifies for protection, the Producing Party also must clearly identify the 4 || protected portion(s) (e.g., by making appropriate markings in the margins). 5 (b) for testimony given in depositions that the Designating Party identifies 6 || the Disclosure or Discovery Material on the record, before the close of the deposition 7 all protected testimony. 8 (c) for information produced in some form other than documentary and for 9 || any other tangible items, that the Producing Party affix in a prominent place on the 10 || exterior of the container or containers in which the information is stored the legend 11 }|}“CONFIDENTIAL.” If only a portion or portions of the information warrants 12 || protection, the Producing Party, to the extent practicable, shall identify the protected 13 |) portion(s). 14 5.3. Inadvertent Failures to Designate. If timely corrected, an inadvertent 15 || failure to designate qualified information or items does not, standing alone, waive the 16 || Designating Party’s right to secure protection under this Order for such material. 17 || Upon timely correction of a designation, the Receiving Party must make reasonable 18 || efforts to assure that the material is treated in accordance with the provisions of this 19 || Order. 20 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 21 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 22 ||designation of confidentiality at any time that is consistent with the Court’s 23 || Scheduling Order, 24 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 25 || resolution process under Local Rule 37-1 et seq. 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 STIPL]T ATED PROTECTIVE ORDER

1 6.4 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 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 Receiving 14 || Party must comply with the provisions of section 13 below (FINAL DISPOSITION). 15 Protected Material must be stored and maintained by a Receiving Party at a 16 location and in a secure manner that ensures that access is limited to the persons 17 || authorized under this Order. 18 72 Disclosure _of “CONFIDENTIAL” Information or Items. Unless 19 || otherwise ordered by the court or permitted in writing by the Designating Party, a 20 ||Receiving Party may disclose any information or item designated 21 ||“CONFIDENTIAL” only to: 22 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 23 ||as employees of said Outside Counsel of Record to whom it is reasonably necessary 24 || to disclose the information for this Action; 25 (b) the officers, directors, and employees (including House Counsel) of the 26 || Receiving Party to whom disclosure is reasonably necessary for this Action; 27 28 STIPL]T ATED PROTECTIVE ORDER

(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; 1] (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 | hereto; and (2) they will 14 |;not be permitted to keep any confidential information unless they sign the IS ||“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 be 18 || separately bound by the court reporter and may not be disclosed to anyone except as 19 || 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 1\8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 23 OTHER LITIGATION 24 If a Party is served with a subpoena or a court order issued in other litigation 25 ||that compels disclosure of any information or items designated in this Action as 26 ||““CONFIDENTIAL,” that Party must: 27 (a) promptly notify in writing the Designating Party. Such notification shall 28 || include a copy of the subpoena or court order; STIPL]T ATED PROTECTIVE ORDER

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

1 (2) promptly provide the Non-Party with a copy of the Stipulated 2 || Protective Order in this Action, the relevant discovery request(s), and a reasonably 3 || specific description of the information requested; and 4 (3) make the information requested available for inspection by the 5 || Non-Party, if requested. 6 (c) Ifthe Non-Party fails to seek a protective order from this court within 14 7 || days of receiving the notice and accompanying information, the Receiving Party may 8 || produce the Non-Party’s confidential information responsive to the discovery request. 9 || If the Non-Party timely seeks a protective order, the Receiving Party shall not produce 10 ||any information in its possession or control that is subject to the confidentiality 11 |)agreement with the Non-Party before a determination by the court. Absent a court 12 || order to the contrary, the Non-Party shall bear the burden and expense of seeking 13 || protection in this court of its Protected Material. 14 |}10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 15 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 16 || Protected Material to any person or in any circumstance not authorized under this 17 || Stipulated Protective Order, the Receiving Party must immediately (a) notify in 18 || writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 19 |) to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 20 || persons to whom unauthorized disclosures were made of all the terms of this Order, 21 ||and (d) request such person or persons to execute the “Acknowledgment and 22 || Agreement to Be Bound” that is attached hereto as Exhibit A. 23 |}11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 24 PROTECTED MATERIAL 25 When a Producing Party gives notice to Receiving Parties that certain 26 || inadvertently produced material is subject to a claim of privilege or other protection, 27 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 28 || Procedure 26(b)\(5)\(B). This provision is not intended to modify whatever procedure STIPL]T ATED PROTECTIVE ORDER

1 || may be established in an e-discovery order that provides for production without prior 2 || privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 3 ||parties reach an agreement on the effect of disclosure of a communication or 4 || information covered by the attorney-client privilege or work product protection, the 5 || parties may incorporate their agreement in the stipulated protective order submitted 6 || to the court. 7{|12. MISCELLANEOUS 8 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 9 || person to seek its modification by the Court in the future. 10 12.2 Right to Assert Other Objections. By stipulating to the entry of this 11 || Protective Order, no Party waives any right it otherwise would have to object to 12 || disclosing or producing any information or item on any ground not addressed in this 13 || Stipulated Protective Order. Similarly, no Party waives any right to object on any 14 |) ground to use in evidence of any of the material covered by this Protective Order. 15 12.3 Filing Protected Material. A Party that seeks to file under seal any 16 || Protected Material must comply with Local Civil Rule 79-5. Protected Material may 17 || only be filed under seal pursuant to a court order authorizing the sealing of the specific 18 || Protected Material at issue. If a Party’s request to file Protected Material under seal is 19 || denied by the court, then the Receiving Party may file the information in the public 20 ||record unless otherwise instructed by the court. 21 ||/13. FINAL DISPOSITION 22 After the final disposition of this Action, as defined in paragraph 4, within 60 23 || days of a written request by the Designating Party, each Receiving Party must return 24 || all Protected Material to the Producing Party or destroy such material. As used in this 25 || subdivision, “all Protected Material” includes all copies, abstracts, compilations, 26 ||summaries, and any other format reproducing or capturing any of the Protected 27 || Material. Whether the Protected Material is returned or destroyed, the Receiving Party 28 || must submit a written certification to the Producing Party (and, if not the same person - STIPL]T ATED PROTECTIVE ORDER

1 |/or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by 2 || category, where appropriate) all the Protected Material that was returned or destroyed 3 ||and (2) affirms that the Receiving Party has not retained any copies, abstracts, 4 ||compilations, summaries or any other format reproducing or capturing any of the 5 || Protected Material. Notwithstanding this provision, Counsel are entitled to retain an 6 ||archival copy of all pleadings, motion papers, trial, deposition, and hearing 7 ||transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 8 || reports, attorney work product, and consultant and expert work product, even if such 9 ||materials contain Protected Material. Any such archival copies that contain or 10 || constitute Protected Material remain subject to this Protective Order as set forth in 11 || Section 4 (DURATION). 12 |}14. VIOLATION 13 Any violation of this Order may be punished by appropriate measures 14 |) including, without limitation, contempt proceedings and/or monetary sanctions. 15 IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 16 We hereby attest that concurrence in the filing of this stipulation was obtained 17 || by each of the below identified signatories. 18 19 20 21 ||DATED: April 29, 2025 WINTERS & ASSOCIATES 22 By: /s/Sarah Ball 23 JACK B. WINTERS, JR. □□□ 24 Attorneys. for Plaintiff 5 Isabel Shaft 26 27 28 13 STIPL]T ATED PROTECTIVE ORDER

1 2 3 4 ||DATED: April 29, 2025 MAYNARD NEXSEN LLP 5 By: /s/Michael A.S. Newman 6 MICHAEL A.S.NEWMAN.— JOHN R. HORSTMAN 7 ttorneys for _efendant Farmers New World Life Insurance 8 Company 9 10 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 11 ZB Zz

3 DATED: April 30, 2025 Charles F. Eick 4 United States Magistrate Judge 15 16 17 Pursuant to Local Rule 5-4.3.4(a)(2)(i), the filer attests that all other 18 || signatories listed, and on whose behalf the filing is submitted, concur in the filing’s 19 || content and have authorized the filing. 20 21 22 23 24 25 26 27 28 14 STIPLIT ATED PROTECTIVE ORDER

l EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 41 [print or type full name], of 5 [print or type full address], declare under penalty of perjury 6 || that I have read in its entirety and understand the Stipulated Protective Order that was 7 || issued by the United States District Court for the Central District of California on [date] 8 ||in the case of Isabel Shaff v. Farmers New World Life Insurance Company, United 9 || States District Court for the Central District of California, Case No. 2:17-cv-03610- 10 || JAK-E. I agree to comply with and to be bound by all the terms of this Stipulated 11 || Protective Order and I understand and acknowledge that failure to so comply could 12 || expose me to sanctions and punishment in the nature of contempt. I solemnly promise 13 || that I will not disclose in any manner any information or item that is subject to this 14 || Stipulated Protective Order to any person or entity except in strict compliance with the 15 || provisions of this Order. 16 ||I further agree to submit to the jurisdiction of the United States District Court for the 17 || Central District of California for enforcing the terms of this Stipulated Protective Order, 18 || even if such enforcement proceedings occur after termination of this action. 19 ||T hereby appoint [print or type full name] of 20 [print or type full address and 21 telephone number] as my California agent for service of process in connection with 22 ||this action or any proceedings related to enforcement of this Stipulated Protective 23 || Order. 24 || Date: 25 || City and State where sworn and signed: 26 || Printed name: 27 28 || Signature: 15 STIPL]T ATED PROTECTIVE ORDER