1 OPHIR JOHNA (SBN 228193) [email protected] 2 KAREN T. TSUI (SBN 305869) [email protected] 3 MAYNARD NEXSEN LLP 10100 Santa Monica Boulevard, Ste. 550 4 Los Angeles, CA 90067 Telephone: 310.596.4500 5 Attorneys for Defendant 6 Life Insurance Company of the Southwest erroneously sued as Life Insurance of the Southwest 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 JOCELYN SUAREZ, Case No. 2:25-cv-02476-MRA-AJRx 12 Plaintiff, (Honorable Monica Ramirez Almadani, Crtrm. 10B) 13 vs.

14 LIFE INSURANCE OF THE SOUTHWEST; FRANCIS VILLAREAL; [PROPOSED] STIPULATED 15 RED FINANCIAL, INC., and DOES 1 to PROTECTIVE ORDER 25, inclusive, 16 Defendants. 17 Complaint Filed: February 14, 2025 18

19 20 21 22 23 24 25 26 27 28 1 1. GENERAL 2 1.1 Purposes and Limitations. Discovery in this action is likely to involve 3 production of confidential, proprietary, or private information for which special 4 protection from public disclosure and from use for any purpose other than prosecuting 5 this litigation may be warranted. Accordingly, the parties hereby stipulate to and petition 6 the Court to enter the following Stipulated Protective Order. The parties acknowledge 7 that this Order does not confer blanket protections on all disclosures or responses to 8 discovery and that the protection it affords from public disclosure and use extends only 9 to the limited information or items that are entitled to confidential treatment under the 10 applicable legal principles. The parties further acknowledge, as set forth in Section 12.3, 11 below, that this Stipulated Protective Order does not entitle them to file confidential 12 information under seal; Civil Local Rule 79-5 sets forth the procedures that must be 13 followed and the standards that will be applied when a party seeks permission from the 14 court to file material under seal. 15 1.2 Good Cause Statement. This action involves a dispute over benefits under 16 a life insurance policy that was rescinded by Defendant Life Insurance Company of the 17 Southwest (“LSW”). This action is likely to involve confidential and proprietary 18 materials such as LSW’s underwriting guidelines, records reflecting operational policies 19 and procedures, other company manuals, private information pertaining to individuals, 20 etc., for which special protection from public disclosure and from use for any purpose 21 other than prosecution of this action is warranted. 22 Accordingly, to expedite the flow of information, to facilitate the prompt 23 resolution of disputes over confidentiality of discovery materials, to adequately protect 24 information the parties are entitled to keep confidential, to ensure that the parties are 25 permitted reasonable necessary uses of such material in preparation for and in the conduct 26 of trial, to address their handling at the end of the litigation, and serve the ends of justice, 27 a protective order for such information is justified in this matter. It is the intent of the 28 parties that information will not be designated as confidential for tactical reasons and that 1 nothing be so designated without a good faith belief that it has been maintained in a 2 confidential, non-public manner, and there is good cause why it should not be part of the 3 public record of this case. 4 2. DEFINITIONS 5 2.1 Action: this pending federal lawsuit. 6 2.2 Challenging Party: a Party or Non-Party that challenges the designation of 7 information or items under this Order. 8 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how 9 it is generated, stored or maintained) or tangible things that qualify for protection under 10 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 11 Statement. 12 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 13 support staff). 14 2.5 Designating Party: a Party or Non-Party that designates information or 15 items that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 16 2.6 Disclosure or Discovery Material: all items or information, regardless of 17 the medium or manner in which it is generated, stored, or maintained (including, among 18 other things, testimony, transcripts, and tangible things), that are produced or generated 19 in disclosures or responses to discovery in this matter. 20 2.7 Expert: a person with specialized knowledge or experience in a matter 21 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 22 expert witness or as a consultant in this Action. 23 2.8 House Counsel: attorneys who are employees of a party to this Action. 24 House Counsel does not include Outside Counsel of Record or any other outside counsel. 25 2.9 Non-Party: any natural person, partnership, corporation, association, or 26 other legal entity not named as a Party to this action. 27 2.10 Outside Counsel of Record: attorneys who are not employees of a party to 28 this Action but are retained to represent or advise a party to this Action and have appeared 1 in this Action on behalf of that party or are affiliated with a law firm that has appeared 2 on behalf of that party, including support staff. 3 2.11 Party: any party to this Action, including all of its officers, directors, 4 employees, consultants, retained experts, and Outside Counsel of Record (and their 5 support staffs). 6 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 7 Discovery Material in this Action. 8 2.13 Professional Vendors: persons or entities that provide litigation support 9 services (e.g., photocopying, videotaping, translating, preparing exhibits or 10 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 11 their employees and subcontractors. 12 2.14 Protected Material: any Disclosure or Discovery Material that is designated 13 as “CONFIDENTIAL.” 14 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 15 from a Producing Party. 16 17 3. SCOPE 18 The protections conferred by this Stipulation and Order cover not only Protected 19 Material (as defined above), but also (1) any information copied or extracted from 20 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 21 Material; and (3) any testimony, conversations, or presentations by Parties or their 22 Counsel that might reveal Protected Material. 23 Any use of Protected Material at trial shall be governed by the orders of the trial 24 judge. This Order does not govern the use of Protected Material at trial. 25 26 4. DURATION 27 Once a case proceeds to trial, all of the court-filed information to be introduced 28 that was previously designated as confidential or maintained pursuant to this protective 1 order becomes public and will be presumptively available to all members of the public, 2 including the press, unless compelling reasons supported by specific factual findings to 3 proceed otherwise are made to the trial judge in advance of the trial. See Kamakana v. 4 City and Cty. of Honolulu,

, 1180-81 (9th Cir. 2006) (distinguishing “good 5 cause” showing for sealing documents produced in discovery from “compelling reasons” 6 standard when merits-related documents are part of court record). Accordingly, the terms 7 of this protective order do not extend beyond the commencement of the trial. 8 9 5. DESIGNATING PROTECTED MATERIAL 10 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each 11 Party or Non-Party that designates information or items for protection under this Order 12 must take care to limit any such designation to specific material that qualifies under the 13 appropriate standards. The Designating Party must designate for protection only those 14 parts of material, documents, items, or oral or written communications that qualify so 15 that other portions of the material, documents, items, or communications for which 16 protection is not warranted are not swept unjustifiably within the ambit of this Order. 17 Mass, indiscriminate, or routinized designations are prohibited. Designations that 18 are shown to be clearly unjustified or that have been made for an improper purpose (e.g., 19 to unnecessarily encumber the case development process or to impose unnecessary 20 expenses and burdens on other parties) may expose the Designating Party to sanctions. 21 If it comes to a Designating Party’s attention that information or items that it 22 designated for protection do not qualify for protection, that Designating Party must 23 promptly notify all other Parties that it is withdrawing the inapplicable designation. 24 5.2 Manner and Timing of Designations. Except as otherwise provided in this 25 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or 26 ordered, Disclosure or Discovery Material that qualifies for protection under this Order 27 must be clearly so designated before the material is disclosed or produced. 28 Designation in conformity with this Order requires: 1 (a) for information in documentary form (e.g., paper or electronic documents, but 2 excluding transcripts of depositions or other pretrial or trial proceedings), that the 3 Producing Party affix, at a minimum, the legend “CONFIDENTIAL” (hereinafter 4 “CONFIDENTIAL legend”), to each page that contains protected material. If only a 5 portion or portions of the material on a page qualifies for protection, the Producing Party 6 also must clearly identify the protected portion(s) (e.g., by making appropriate markings 7 in the margins). 8 A Party or Non-Party that makes original documents available for inspection need 9 not designate them for protection until after the inspecting Party has indicated which 10 documents it would like copied and produced. During the inspection and before the 11 designation, all of the material made available for inspection shall be deemed 12 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 13 copied and produced, the Producing Party must determine which documents, or portions 14 thereof, qualify for protection under this Order. Then, before producing the specified 15 documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page 16 that contains Protected Material. If only a portion or portions of the material on a page 17 qualifies for protection, the Producing Party also must clearly identify the protected 18 portion(s) (e.g., by making appropriate markings in the margins). 19 (b) for testimony given in depositions that the Designating Party identify the 20 Disclosure or Discovery Material on the record, before the close of the deposition, or in 21 writing to all parties within 30 days after the Designating Party’s receipt of the deposition 22 transcript. 23 (c) for information produced in some form other than documentary and for any 24 other tangible items, that the Producing Party affix in a prominent place on the exterior 25 of the container or containers in which the information is stored the legend 26 “CONFIDENTIAL.” If only a portion or portions of the information warrants protection, 27 the Producing Party, to the extent practicable, shall identify the protected portion(s). 28 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure 1 to designate qualified information or items does not, standing alone, waive the 2 Designating Party’s right to secure protection under this Order for such material. Upon 3 timely correction of a designation, the Receiving Party must make reasonable efforts to 4 assure that the material is treated in accordance with the provisions of this Order. 5 6 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 7 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation 8 of confidentiality at any time that is consistent with the Court’s Scheduling Order. 9 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution 10 process under Local Rule 37-1, et seq. Any discovery motion must strictly comply with 11 the procedures set forth in Local Rules 37-1, 37-2, and 37-3. 12 6.3 Burden. The burden of persuasion in any such challenge proceeding shall 13 be on the Designating Party. Frivolous challenges, and those made for an improper 14 purpose (e.g., to harass or impose unnecessary expenses and burdens on other parties) 15 may expose the Challenging Party to sanctions. Unless the Designating Party has waived 16 or withdrawn the confidentiality designation, all parties shall continue to afford the 17 material in question the level of protection to which it is entitled under the Producing 18 Party’s designation until the Court rules on the challenge. 19 20 7. ACCESS TO AND USE OF PROTECTED MATERIAL 21 7.1 Basic Principles. A Receiving Party may use Protected Material that is 22 disclosed or produced by another Party or by a Non-Party in connection with this Action 23 only for prosecuting, defending, or attempting to settle this Action. Such Protected 24 Material may be disclosed only to the categories of persons and under the conditions 25 described in this Order. When the Action has been terminated, a Receiving Party must 26 comply with the provisions of section 13 below (FINAL DISPOSITION). 27 Protected Material must be stored and maintained by a Receiving Party at a 28 location and in a secure manner that ensures that access is limited to the persons 1 authorized under this Order. 2 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise 3 ordered by the Court or permitted in writing by the Designating Party, a Receiving Party 4 may disclose any information or item designated “CONFIDENTIAL” only to: 5 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as 6 employees of said Outside Counsel of Record to whom it is reasonably necessary to 7 disclose the information for this Action; 8 (b) the officers, directors, and employees (including House Counsel) of the 9 Receiving Party to whom disclosure is reasonably necessary for this Action; 10 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure 11 is reasonably necessary for this Action and who have signed the “Acknowledgment and 12 Agreement to Be Bound” (Exhibit A); 13 (d) the Court and its personnel; 14 (e) court reporters and their staff; 15 (f) professional jury or trial consultants, mock jurors, and Professional Vendors to 16 whom disclosure is reasonably necessary for this Action and who have signed the 17 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 18 (g) the author or recipient of a document containing the information or a custodian 19 or other person who otherwise possessed or knew the information; 20 (h) during their depositions, witnesses, and attorneys for witnesses, in the Action 21 to whom disclosure is reasonably necessary provided: (1) the deposing party requests that 22 the witness sign the form attached as Exhibit A hereto; and (2) they will not be permitted 23 to keep any confidential information unless they sign the “Acknowledgment and 24 Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party 25 or ordered by the Court. Pages of transcribed deposition testimony or exhibits to 26 depositions that reveal Protected Material may be separately bound by the court reporter 27 and may not be disclosed to anyone except as permitted under this Stipulated Protective 28 Order; and 1 (i) any mediator or settlement officer, and their supporting personnel, mutually 2 agreed upon by any of the parties engaged in settlement discussions. 3 4 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 5 IN OTHER LITIGATION 6 If a Party is served with a subpoena or a court order issued in other litigation that 7 compels disclosure of any information or items designated in this Action as 8 “CONFIDENTIAL,” that Party must: 9 (a) promptly notify in writing the Designating Party. Such notification shall 10 include a copy of the subpoena or court order; 11 (b) promptly notify in writing the party who caused the subpoena or order to issue 12 in the other litigation that some or all of the material covered by the subpoena or order is 13 subject to this Protective Order. Such notification shall include a copy of this Stipulated 14 Protective Order; and 15 (c) cooperate with respect to all reasonable procedures sought to be pursued by 16 the Designating Party whose Protected Material may be affected. 17 If the Designating Party timely seeks a protective order, the Party served with the 18 subpoena or court order shall not produce any information designated in this action as 19 “CONFIDENTIAL” before a determination by the court from which the subpoena or 20 order issued, unless the Party has obtained the Designating Party’s permission. The 21 Designating Party shall bear the burden and expense of seeking protection in that court 22 of its confidential material and nothing in these provisions should be construed as 23 authorizing or encouraging a Receiving Party in this Action to disobey a lawful directive 24 from another court. 25 26 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 27 PRODUCED IN THIS LITIGATION 28 (a) The terms of this Order are applicable to information produced by a Non-Party 1 in this Action and designated as “CONFIDENTIAL.” Such information produced by 2 Non-Parties in connection with this litigation is protected by the remedies and relief 3 provided by this Order. Nothing in these provisions should be construed as prohibiting 4 a Non-Party from seeking additional protections. 5 (b) In the event that a Party is required, by a valid discovery request, to produce a 6 Non-Party’s confidential information in its possession, and the Party is subject to an 7 agreement with the Non-Party not to produce the Non-Party’s confidential information, 8 then the Party shall: 9 (1) promptly notify in writing the Requesting Party and the Non-Party that some 10 or all of the information requested is subject to a confidentiality agreement with a Non- 11 Party; 12 (2) promptly provide the Non-Party with a copy of the Stipulated Protective Order 13 in this Action, the relevant discovery request(s), and a reasonably specific description of 14 the information requested; and 15 (3) make the information requested available for inspection by the Non-Party, if 16 requested. 17 (c) If the Non-Party fails to seek a protective order from this Court within 14 days 18 of receiving the notice and accompanying information, the Receiving Party may produce 19 the Non-Party’s confidential information responsive to the discovery request. If the Non- 20 Party timely seeks a protective order, the Receiving Party shall not produce any 21 information in its possession or control that is subject to the confidentiality agreement 22 with the Non-Party before a determination by the Court. Absent a court order to the 23 contrary, the Non-Party shall bear the burden and expense of seeking protection in this 24 Court of its Protected Material. 25 26 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 27 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 28 Protected Material to any person or in any circumstance not authorized under this 1 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 2 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 3 all unauthorized copies of the Protected Material, (c) inform the person or persons to 4 whom unauthorized disclosures were made of all the terms of this Order, and (d) request 5 such person or persons to execute the “Acknowledgment and Agreement to Be Bound” 6 that is attached hereto as Exhibit A. 7 8 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 9 PROTECTED MATERIAL 10 When a Producing Party gives notice to Receiving Parties that certain 11 inadvertently produced material is subject to a claim of privilege or other protection, the 12 obligations of the Receiving Parties are those set forth in Federal Rule of Civil Procedure 13 26(b)(5)(B). This provision is not intended to modify whatever procedure may be 14 established in an e-discovery order that provides for production without prior privilege 15 review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the parties reach 16 an agreement on the effect of disclosure of a communication or information covered by 17 the attorney-client privilege or work product protection, the parties may incorporate their 18 agreement in the stipulated protective order submitted to the Court. 19 20 12. MISCELLANEOUS 21 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 22 person to seek its modification by the Court in the future. 23 12.2 Right to Assert Other Objections. By stipulating to the entry of this 24 Protective Order, no Party waives any right it otherwise would have to object to 25 disclosing or producing any information or item on any ground not addressed in this 26 Stipulated Protective Order. Similarly, no Party waives any right to object on any ground 27 to use in evidence of any of the material covered by this Protective Order. 28 12.3 Filing Protected Material. A Party that seeks to file under seal any Protected 1 Material must comply with Civil Local Rule 79-5. Protected Material may only be filed 2 under seal pursuant to a court order authorizing the sealing of the specific Protected 3 Material at issue; good cause must be shown in the request to file under seal. If a Party’s 4 request to file Protected Material under seal is denied by the Court, then the Receiving 5 Party may file the information in the public record unless otherwise instructed by the 6 Court. 7 8 13. FINAL DISPOSITION 9 After the final disposition of this Action, within 60 days of a written request by the 10 Designating Party, each Receiving Party must return all Protected Material to the 11 Producing Party or destroy such material. As used in this subdivision, “all Protected 12 Material” includes all copies, abstracts, compilations, summaries, and any other format 13 reproducing or capturing any of the Protected Material. Whether the Protected Material 14 is returned or destroyed, the Receiving Party must submit a written certification to the 15 Producing Party (and, if not the same person or entity, to the Designating Party) by the 16 60 day deadline that (1) identifies (by category, where appropriate) all the Protected 17 Material that was returned or destroyed, and (2) affirms that the Receiving Party has not 18 retained any copies, abstracts, compilations, summaries or any other format reproducing 19 or capturing any of the Protected Material. Notwithstanding this provision, counsel are 20 entitled to retain an archival copy of all pleadings, motion papers, trial, deposition, and 21 hearing transcripts, legal memoranda, correspondence, deposition and trial exhibits, 22 expert reports, attorney work product, and consultant and expert work product, even if 23 such materials contain Protected Material. Any such archival copies that contain or 24 constitute Protected Material remain subject to this Protective Order as set forth in 25 Section 4 (DURATION). 26 /// 27 /// 28 /// 1 14. VIOLATION OF ORDER 2 Any violation of this Order may be punished by any and all appropriate measures 3 including, without limitation, contempt proceedings and/or monetary sanctions. 4 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 5 Dated: November 14, 2025 MAYNARD NEXSEN LLP 6

7 By: /s/ Ophir Johna OPHIR JOHNA 8 KAREN TSUI Attorneys for Defendant Life Insurance 9 Company of the Southwest

10 Dated: November 14, 2025 THE FIRM LA, P.C. 11

12 By: /s/ Joseph Hakopian JOSEPH HAKOPIAN 13 Attorneys for Plaintiff Jocelyn Suarez 14

15

16 Filer’s Attestation: Pursuant to Local Rule 5-4.3.4(a)(2)(i) regarding signatures, Ophir Johna hereby attests that concurrence in the filing of this document and its content 17 has been obtained by all signatories listed. 18 /s/ Ophir Johna 19 OPHIR JOHNA 20

21

22 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 23

24

25 DATED:_1_1/_1_7_/2_0_2_5_______ __________________________________ HON. A. JOEL RICHLIN 26 United States Magistrate Judge 27 28 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 I, _____________________________ [print or type full name], of 5 _________________ [print or type full address], declare under penalty of perjury that I 6 have read in its entirety and understand the Stipulated Protective Order that was issued 7 by the United States District Court for the Central District of California on [date] in the 8 case of ___________ Jocelyn Suarez v. Life Insurance Company of the Southwest, et al., 9 Case No. 2:25-cv-02476-MRA-AJRx. I agree to comply with and to be bound by all the 10 terms of this Stipulated Protective Order, and I understand and acknowledge that failure 11 to so comply could expose me to sanctions and punishment in the nature of contempt. I 12 solemnly promise that I will not disclose in any manner any information or item that is 13 subject to this Stipulated Protective Order to any person or entity except in strict 14 compliance with the provisions of this 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 Stipulated 17 Protective Order, even if such enforcement proceedings occur after termination of this 18 action. I hereby appoint __________________________ [print or type full name] of 19 _______________________________________ [print or type full address and 20 telephone number] as my California agent for service of process in connection with this 21 action or any proceedings related to enforcement of this Stipulated Protective Order. 22 Date: ______________________________________ 23 City and State where sworn and signed: _________________________________ 24 25 Printed name: _______________________________ 26 Signature: __________________________________ 27 28