1 MSCICOHTTA EEL. C BA. LHVOERRRTO (WSB (NSB 2N10 1768279)1 7) 2 DONAHUE & HORROW, LLP 1960 E. Grand Avenue, Suite 1215 3 El Segundo, California 90245 Telephone: (310) 322-0300 4 Email: [email protected] Email: [email protected] 5 Attorneys for Plaintiff John Webster 6 SCHWARTZ SEMERDJIAN CAULEY 7 SCHENA & BUSH LLP Dick A. Semerdjian (SBN 123630) 8 9000 Sunset Blvd., Suite 1260 West Hollywood, CA 90069 9 Telephone: (310) 550-8857 Email: [email protected] 10 BURR & FORMAN LLP 11 Jennifer M. Busby (Admitted Pro Hac Vice) 420 20th Street North, Suite 3400 12 Birmingham, AL 35203 Telephone: (205) 251-3000 13 Email: [email protected]

14 Attorneys for Defendant Allianz Life Insurance Company of North America 15

16 UNITED STATES DISTRICT COURT 17 CENTRAL DISTRICT OF CALIFORNIA 18

19

20 JOHN WEBSTER, Case No.: 5:25-cv-00810-SSS(SPx)

Plaintiff, 21 ORDER APPROVING vs. STIPULATED PROTECTIVE 22 ORDER ALLIANZ LIFE INSURANCE 23 COMPANY OF NORTH AMERICA; DOES 1-10 24

Defendants. 25

26 27 28 1 Plaintiff John Webster (“Plaintiff”) and Defendant Allianz Life Insurance 2 Company of North America (“Defendant”) (collectively, “the Parties”) hereby submit 3 the following Stipulated Protective Order. 4 1. PURPOSES AND LIMITATIONS 5 Discovery in this action is likely to involve production of confidential, 6 proprietary, or private information for which special protection from public disclosure 7 and from use for any purpose other than prosecuting this litigation may be warranted. 8 Accordingly, the parties hereby stipulate to and petition the Court to enter the 9 following Stipulated Protective Order. The parties acknowledge that this Order does 10 not confer blanket protections on all disclosures or responses to discovery and that the 11 protection it affords from public disclosure and use extends only to the limited 12 information or items that are entitled to confidential treatment under the applicable 13 legal principles. The parties further acknowledge, as set forth in Section 12.3, below, 14 that this Stipulated Protective Order does not entitle them to file confidential 15 information under seal; Civil Local Rule 79-5 sets forth the procedures that must be 16 followed and the standards that will be applied when a party seeks permission from 17 the court to file material under seal. 18 B. GOOD CAUSE STATEMENT 19 In this dispute over insurance benefits, the discovery materials requested and 20 exchanged throughout the course of the litigation will include confidential and 21 proprietary materials and information regarding Defendant’s claims handling 22 standards. Such confidential and proprietary materials and information consist of, 23 among other things, confidential business or financial information, information 24 regarding confidential business practices, or other confidential research, development, 25 or commercial information (including information implicating privacy rights of third 26 parties), information otherwise generally unavailable to the public, or which may be 27 privileged or otherwise protected from disclosure under state or federal statutes, court 28 rules, case decisions, or common law. In addition, discovery will necessarily include 1 Plaintiff’s private, sensitive medical documents. 2 Accordingly, to expedite the flow of information, to facilitate the prompt 3 resolution of disputes over confidentiality of discovery materials, to adequately 4 protect information the parties are entitled to keep confidential, to ensure that the 5 parties are permitted reasonable necessary uses of such material in preparation for and 6 in the conduct of trial, to address their handling at the end of the litigation, and serve 7 the ends of justice, a protective order for such information is justified in this matter. It 8 is the intent of the parties that information will not be designated as confidential for 9 tactical reasons and that nothing be so designated without a good faith belief that it 10 has been maintained in a confidential, non-public manner, and there is good cause 11 why it should not be part of the public record of this case. 12 2. DEFINITIONS 13 2.1 Action: the above captioned pending federal lawsuit. 14 2.2 Challenging Party: a Party or Non-Party that challenges the designation 15 of information or items under this Order. 16 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 17 how it is generated, stored or maintained) or tangible things that qualify for protection 18 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 19 Cause Statement. 20 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 21 support staff). 22 2.5 Designating Party: a Party or Non-Party that designates information or 23 items that it produces in disclosures or in responses to discovery as 24 “CONFIDENTIAL.” 25 2.6 Disclosure or Discovery Material: all items or information, regardless of 26 the medium or manner in which it is generated, stored, or maintained (including, 27 among other things, testimony, transcripts, and tangible things), that are produced or 28 generated in disclosures or responses to discovery. 1 2.7 Expert: a person with specialized knowledge or experience in a matter 2 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 3 expert witness or as a consultant in this Action. 4 2.8 House Counsel: attorneys who are employees of a party to this Action. 5 House Counsel does not include Outside Counsel of Record or any other outside 6 counsel. 7 2.9 Non-Party: any natural person, partnership, corporation, association or 8 other legal entity not named as a Party to this action. 9 2.10 Outside Counsel of Record: attorneys who are not employees of a party 10 to this Action but are retained to represent a party to this Action and have appeared in 11 this Action on behalf of that party or are affiliated with a law firm that has appeared 12 on behalf of that party, and includes support staff. 13 2.11 Party: any party to this Action, including all of its officers, directors, 14 employees, consultants, retained experts, and Outside Counsel of Record (and their 15 support staffs). 16 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 17 Discovery Material in this Action. 18 2.13 Professional Vendors: persons or entities that provide litigation support 19 services (e.g., photocopying, videotaping, translating, preparing exhibits or 20 demonstrations, and organizing, storing, or retrieving data in any form or medium) 21 and their employees and subcontractors. 22 2.14 Protected Material: any Disclosure or Discovery Material that is 23 designated as “CONFIDENTIAL.” 24 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 25 from a Producing Party. 26 3. SCOPE 27 The protections conferred by this Stipulation and Order cover not only 28 Protected Material (as defined above), but also (1) any information copied or extracted 1 from Protected Material; (2) all copies, excerpts, summaries, or compilations of 2 Protected Material; and (3) any testimony, conversations, or presentations by Parties 3 or their Counsel that might reveal Protected Material. 4 Any use of Protected Material at trial shall be governed by the orders of the trial 5 judge. This Order does not govern the use of Protected Material at trial. 6 4. DURATION 7 Once a case proceeds to trial, all of the information that was designated as 8 confidential or maintained pursuant to this protective order becomes public and will 9 be presumptively available to all members of the public, including the press, unless 10 compelling reasons supported by specific factual findings to proceed otherwise are 11 made to the trial judge in advance of the trial. See Kamakana v. City and County of 12 Honolulu,

, 1180-81 (9th Cir. 2006) (distinguishing “good cause” 13 showing for sealing documents produced in discovery from “compelling reasons” 14 standard when merits-related documents are part of court record). Accordingly, the 15 terms of this protective order do not extend beyond the commencement of the trial. 16 5. DESIGNATING PROTECTED MATERIAL 17 5.1 Exercise of Restraint and Care in Designating Material for Protection. 18 Each Party or Non-Party that designates information or items for protection under this 19 Order must take care to limit any such designation to specific material that qualifies 20 under the appropriate standards. The Designating Party must designate for protection 21 only those parts of material, documents, items, or oral or written communications that 22 qualify so that other portions of the material, documents, items, or communications 23 for which protection is not warranted are not swept unjustifiably within the ambit of 24 this Order. 25 Mass, indiscriminate, or routinized designations are prohibited. Designations 26 that are shown to be clearly unjustified or that have been made for an improper 27 purpose (e.g., to unnecessarily encumber the case development process or to impose 28 unnecessary expenses and burdens on other parties) may expose the Designating Party 1 to sanctions. 2 If it comes to a Designating Party’s attention that information or items that it 3 designated for protection do not qualify for protection, that Designating Party must 4 promptly notify all other Parties that it is withdrawing the inapplicable designation. 5 5.2 Manner and Timing of Designations. Except as otherwise provided in 6 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 7 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 8 under this Order must be clearly so designated before the material is disclosed or 9 produced. 10 Designation in conformity with this Order requires: 11 (a) for information in documentary form (e.g., paper or electronic 12 documents, but excluding transcripts of depositions or other pretrial or trial 13 proceedings), that the Producing Party affix at a minimum, the legend 14 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 15 contains protected material. If only a portion or portions of the material on a page 16 qualifies for protection, the Producing Party also must clearly identify the protected 17 portion(s) (e.g., by making appropriate markings in the margins). 18 A Party or Non-Party that makes original documents available for inspection 19 need not designate them for protection until after the inspecting Party has indicated 20 which documents it would like copied and produced. During the inspection and before 21 the designation, all of the material made available for inspection shall be deemed 22 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 23 copied and produced, the Producing Party must determine which documents, or 24 portions thereof, qualify for protection under this Order. Then, before producing the 25 specified documents, the Producing Party must affix the “CONFIDENTIAL legend” 26 to each page that contains Protected Material. If only a portion or portions of the 27 material on a page qualifies for protection, the Producing Party also must clearly 28 identify the protected portion(s) (e.g., by making appropriate markings in the 1 margins). 2 (b) for testimony given in depositions that the Designating Party identify the 3 Disclosure or Discovery Material on the record, before the close of the deposition all 4 protected testimony. 5 (c) for information produced in some form other than documentary and for 6 any other tangible items, that the Producing Party affix in a prominent place on the 7 exterior of the container or containers in which the information is stored the legend 8 “CONFIDENTIAL.” If only a portion or portions of the information warrants 9 protection, the Producing Party, to the extent practicable, shall identify the protected 10 portion(s). 11 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 12 failure to designate qualified information or items does not, standing alone, waive the 13 Designating Party’s right to secure protection under this Order for such material. 14 Upon timely correction of a designation, the Receiving Party must make reasonable 15 efforts to assure that the material is treated in accordance with the provisions of this 16 Order. 17 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 18 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 19 designation of confidentiality at any time that is consistent with the Court’s 20 Scheduling Order. 21 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 22 resolution process under Local Rule 37.1 et seq. 23 6.3 The burden of persuasion in any such challenge proceeding shall be on 24 the Designating Party. Frivolous challenges, and those made for an improper purpose 25 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 26 expose the Challenging Party to sanctions. Unless the Designating Party has waived or 27 withdrawn the confidentiality designation, all parties shall continue to afford the 28 material in question the level of protection to which it is entitled under the Producing 1 Party’s designation until the Court rules on the challenge. 2 7. ACCESS TO AND USE OF PROTECTED MATERIAL 3 7.1 Basic Principles. A Receiving Party may use Protected Material that is 4 disclosed or produced by another Party or by a Non-Party in connection with this 5 Action only for prosecuting, defending, or attempting to settle this Action. Such 6 Protected Material may be disclosed only to the categories of persons and under the 7 conditions described in this Order. When the Action has been terminated, a Receiving 8 Party must comply with the provisions of section 13 below (FINAL DISPOSITION). 9 Protected Material must be stored and maintained by a Receiving Party at a location 10 and in a secure manner that ensures that access is limited to the persons authorized 11 under this Order. 12 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 13 otherwise ordered by the court or permitted in writing by the Designating Party, a 14 Receiving Party may disclose any information or item designated “CONFIDENTIAL” 15 only to: 16 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 17 as employees of said Outside Counsel of Record to whom it is reasonably necessary to 18 disclose the information for this Action; 19 (b) the officers, directors, and employees (including House Counsel) of the 20 Receiving Party to whom disclosure is reasonably necessary for this Action; 21 (c) Experts (as defined in this Order) of the Receiving Party to whom 22 disclosure is reasonably necessary for this Action and who have signed the 23 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 24 (d) the court and its personnel; 25 (e) court reporters and their staff; 26 (f) professional jury or trial consultants, mock jurors, and Professional 27 Vendors to whom disclosure is reasonably necessary for this Action and who have 28 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 1 (g) the author or recipient of a document containing the information or a 2 custodian or other person who otherwise possessed or knew the information; 3 (h) during their depositions, witnesses ,and attorneys for witnesses, in the 4 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 5 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will 6 not be permitted to keep any confidential information unless they sign the 7 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed 8 by the Designating Party or ordered by the court. Pages of transcribed deposition 9 testimony or exhibits to depositions that reveal Protected Material may be separately 10 bound by the court reporter and may not be disclosed to anyone except as permitted 11 under this Stipulated Protective Order; and 12 (i) any mediator or settlement officer, and their supporting personnel, 13 mutually agreed upon by any of the parties engaged in settlement discussions. 14 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 15 PRODUCED IN OTHER LITIGATION 16 If a Party is served with a subpoena or a court order issued in other litigation that 17 compels disclosure of any information or items designated in this Action as 18 “CONFIDENTIAL,” that Party must: 19 (a) promptly notify in writing the Designating Party. Such notification shall 20 include a copy of the subpoena or court order; 21 (b) promptly notify in writing the party who caused the subpoena or order to 22 issue in the other litigation that some or all of the material covered by the subpoena or 23 order is subject to this Protective Order. Such notification shall include a copy of this 24 Stipulated Protective Order; and 25 (c) cooperate with respect to all reasonable procedures sought to be pursued by 26 the Designating Party whose Protected Material may be affected. 27 If the Designating Party timely seeks a protective order, the Party served with 28 the subpoena or court order shall not produce any information designated in this 1 action as “CONFIDENTIAL” before a determination by the court from which the 2 subpoena or order issued, unless the Party has obtained the Designating Party’s 3 permission. The Designating Party shall bear the burden and expense of seeking 4 protection in that court of its confidential material and nothing in these provisions 5 should be construed as authorizing or encouraging a Receiving Party in this Action to 6 disobey a lawful directive from another court. 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 7 PRODUCED IN THIS LITIGATION 8 (a) The terms of this Order are applicable to information produced by a Non- 9 Party in this Action and designated as “CONFIDENTIAL.” Such information 10 produced by Non-Parties in connection with this litigation is protected by the 11 remedies and relief provided by this Order. Nothing in these provisions should be 12 construed as prohibiting a Non-Party from seeking additional protections. 13 (b) In the event that a Party is required, by a valid discovery request, to 14 produce a Non-Party’s confidential information in its possession, and the Party is 15 subject to an agreement with the Non-Party not to produce the Non-Party’s 16 confidential information, then the Party shall: 17 (1) promptly notify in writing the Requesting Party and the Non-Party that 18 some or all of the information requested is subject to a confidentiality agreement with 19 a Non-Party; 20 (2) promptly provide the Non-Party with a copy of the Stipulated Protective 21 Order in this Action, the relevant discovery request(s), and a reasonably specific 22 description of the information requested; and 23 (3) make the information requested available for inspection by the Non- 24 Party, if requested. 25 (c) If the Non-Party fails to seek a protective order from this court within 14 26 days of receiving the notice and accompanying information, the Receiving Party may 27 produce the Non-Party’s confidential information responsive to the discovery request. 28 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce 1 any information in its possession or control that is subject to the confidentiality 2 agreement with the Non-Party before a determination by the court. Absent a court 3 order to the contrary, the Non-Party shall bear the burden and expense of seeking 4 protection in this court of its Protected Material. 5 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 6 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 7 Protected Material to any person or in any circumstance not authorized under this 8 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 9 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 10 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 11 persons to whom unauthorized disclosures were made of all the terms of this Order, 12 and (d) request such person or persons to execute the “Acknowledgment and 13 Agreement to Be Bound” that is attached hereto as Exhibit A. 14 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 15 PROTECTED MATERIAL 16 17 When a Producing Party gives notice to Receiving Parties that certain 18 inadvertently produced material is subject to a claim of privilege or other protection, 19 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 20 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 21 may be established in an e-discovery order that provides for production without prior 22 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 23 parties reach an agreement on the effect of disclosure of a communication or 24 information covered by the attorney-client privilege or work product protection, the 25 parties may incorporate their agreement in the stipulated protective order submitted to 26 the court. 27 12. MISCELLANEOUS 28 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 1 person to seek its modification by the Court in the future. 2 12.2 Right to Assert Other Objections. By stipulating to the entry of this 3 Protective Order no Party waives any right it otherwise would have to object to 4 disclosing or producing any information or item on any ground not addressed in this 5 Stipulated Protective Order. Similarly, no Party waives any right to object on any 6 ground to use in evidence of any of the material covered by this Protective Order. 7 12.3 Filing Protected Material. A Party that seeks to file under seal any 8 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 9 only be filed under seal pursuant to a court order authorizing the sealing of the 10 specific Protected Material at issue. If a Party's request to file Protected Material 11 under seal is denied by the court, then the Receiving Party may file the information in 12 the public record unless otherwise instructed by the court. 13 13. FINAL DISPOSITION 14 After the final disposition of this Action, as defined in paragraph 4, within 60 15 days of a written request by the Designating Party, each Receiving Party must return 16 all Protected Material to the Producing Party or destroy such material. As used in this 17 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 18 summaries, and any other format reproducing or capturing any of the Protected 19 Material. Whether the Protected Material is returned or destroyed, the Receiving Party 20 must submit a written certification to the Producing Party (and, if not the same person 21 or entity, to the Designating Party) by the 60-day deadline that (1) identifies (by 22 category, where appropriate) all the Protected Material that was returned or destroyed 23 and (2) affirms that the Receiving Party has not retained any copies, abstracts, 24 compilations, summaries or any other format reproducing or capturing any of the 25 Protected Material. Notwithstanding this provision, Counsel are entitled to retain an 26 archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, 27 legal memoranda, correspondence, deposition and trial exhibits, expert reports, 28 attorney work product, and consultant and expert work product, even if such materials 1 || contain Protected Material. Any such archival copies that contain or constitute 2 || Protected Material remain subject to this Protective Order as set forth in Section 4 3 || (DURATION). 4 14. Any violation of this Order may be punished by any and all appropriate 5 || measures including, without limitation, contempt proceedings and/or monetary 6 || sanctions. 7 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 8 9 || DATED: August 26, 2025 DONAHUE & HORROW, LLP 10

5 /s/ Scott E. Calvert z= 12 MICHAEL B. HORROW SCOTT E. CALVERT S 13 Attorneys for Plaintiff John Webster gy = 15

z 16 DATED: August 26, 2025 BURR & FORMAN LLP 17 18 /s/ Jennifer M. Busb 19 JENNIFER M. BUSBY 0 Attorneys for Defendant Allianz Life Insurance Company of North America 21 22 23 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 24 25 DATED: August 29, 2025 26 27 28 HONORABLE SHERI PYM United States Magistrate Judge 412,

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, _____________________________ [print or type full name], of 4 _________________ [print or type full address], declare under penalty of perjury that 5 I have read in its entirety and understand the Stipulated Protective Order that was 6 issued by the United States District Court for the Central District of California on 7 [date] in the case of ___________ [insert formal name of the case and the number 8 and initials assigned to it by the court]. I agree to comply with and to be bound by all 9 the terms of this Stipulated Protective Order and I understand and acknowledge that 10 failure to so comply could expose me to sanctions and punishment in the nature of 11 contempt. I solemnly promise that I will not disclose in any manner any information 12 or item that is subject to this Stipulated Protective Order to any person or entity 13 except in strict compliance with the provisions of this Order. 14 I further agree to submit to the jurisdiction of the United States District Court 15 for the Central District of California for the purpose of enforcing the terms of this 16 Stipulated Protective Order, even if such enforcement proceedings occur after 17 termination of this action. I hereby appoint __________________________ [print or 18 type full name] of _______________________________________ [print or type full 19 address and telephone number] as my California agent for service of process in 20 connection with this action or any proceedings related to enforcement of this 21 Stipulated Protective Order. 22 Date: ______________________________________ 23 City and State where sworn and signed: _________________________________ 24 Printed name: _______________________________ 25 Signature: __________________________________ 26 27

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