1 MATTHEW J. HAFEY (admitted Pro Hac Vice) [email protected] 2 TIMOTHY P. KITT (SBN: 11828) [email protected] 3 KHRYS WU (admitted Pro Hac Vice) 4 [email protected] NICOLAIDES FINK THORPE 5 MICHAELIDES SULLIVAN LLP 6 777 South Figueroa Street, Suite 750 Los Angeles, CA 90017 7 Telephone: (213) 402-1245 Facsimile: (213) 402-1246 8 9 Jeffrey W. Saab (Nevada SBN: 11261) [email protected] 10 BREMER, WHYTE, BROWN & O’MEARA, LLP 1160 N. Town Center Drive, Suite 250 11 Las Vegas, Nevada 89144 12 Telephone: (702) 258-6665 Facsimile: (702) 258-6662 13 Designated solely for personal service pursuant to Nev. SCR 42.1 14 Attorneys for Plaintiff 15 KINSALE INSURANCE COMPANY 16 UNITED STATES DISTRICT COURT 17 DISTRICT OF NEVADA 18 KINSALE INSURANCE COMPANY, Case No. 2:24-cv-00997-RFB-DJA an Arkansas corporation, 19 STIPULATION FOR PROTECTIVE 20 Plaintiff, ORDER 21 v. 22 SVS SECURITY LLC, a Nevada 23 limited liability company; HENRY WILLIS WEBB, JR., an individual; 24 MEISHA LARITA WEBB, an 25 individual and Special Administrator of the Estate of Breeana Larita 26 Webb (Deceased), 27 Defendants. 1 TO THE HONORABLE COURT, AND TO ALL PARTIES AND 2 THEIR ATTORNEYS OF RECORD: 3 WHEREAS the parties reasonably believe that certain documents 4 and deposition testimony in this action may contain information which is 5 either confidential, subject to a party’s right to privacy (either under the 6 Constitution of the United States or the State of Nevada), proprietary, a 7 trade secret, or otherwise worthy of protection from disclosure to the 8 general public; and 9 WHEREAS the parties have met and conferred and agree that 10 certain materials and deposition testimony in this action are worthy of such 11 protection and that an appropriate, agreed Protective Order will suffice to 12 afford the parties of that protection; 13 IT IS HEREBY STIPULATED AND AGREED and requested by the 14 parties to this action that the Court enter a Protective Order in the form 15 attached as Exhibit “A” for the use of the parties and protection of certain 16 documents and testimony in this action only. 17 IT IS FURTHER STIPULATED AND AGREED that until this 18 proposed Protective Order has been signed and entered by the Court, any 19 documents or testimony designated “CONFIDENTIAL” pursuant to the 20 terms of the proposed Protective Order shall be treated by the parties as 21 22 23 24 25 26 27 1 |} CONFIDENTIAL according to its terms and not disclosed to any third party 2 ||absent a court order. 3 ||Dated: October 15, 2025 NICOLAIDES FINK THORPE 4 MICHAELIDES SULLIVAN LLP 5 By: □□□ 6 Matthew J. Hafey Gamitted Pro Hac Vice) 7 Timothy P. Kitt 8 Khrys Wu (admitted Pro Hac Vice) 9 Attorneys for Plaintiff KINSALE 10 INSURANCE COMPANY 11 ||Dated: October 15, 2025 REISMAN SOROKAC 12 . By:__/s/ Jody Hagins 13 Joshua Reisman 14 Jody Hagins Attorneys for Defendant SVS 15 SECURITY LLC 16 17 ||Dated: October 15, 2025 CHRISTIANSEN TRIAL LAWYERS 18 By:___/s/ Whitney Barrett 19 Peter S. Christiansen 20 Whitney Barrett Attorneys for Defendants HENRY 21 WILLIS WEBB, JR. and MEISHA 99 LARITA WEBB 23 STATEMENT OF AUTHORITY TO FILE 24 | attest that all signatories on this document and on whose behalf the 25 |\filing is submitted concur in the filing’s content and have authorized the filing 26 this document. 27 By: Mal Ue 28 Matthew J. Hafey

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 DISTRICT OF NEVADA 10 KINSALE INSURANCE COMPANY, Case No. 2:24-cv-00997-RFB-DJA an Arkansas corporation, 11 PROTECTIVE ORDER 12 Plaintiff, 13 v. 14 SVS SECURITY LLC, a Nevada 15 limited liability company; HENRY WILLIS WEBB, JR., an individual; 16 MEISHA LARITA WEBB, an 17 individual and Special Administrator of the Estate of Breeana Larita 18 Webb (Deceased), 19 Defendants. 20 21 1. PURPOSE AND LIMITS OF THIS ORDER 22 Discovery in this action is likely to involve confidential, proprietary, or 23 private information requiring special protection from public disclosure and 24 from use for any purpose other than this litigation. Thus, the Court enters 25 this Protective Order (“Order”). This Order does not confer blanket 26 protections on all disclosures or responses to discovery, and the protection 27 it gives from public disclosure and use extends only to the specific material 1 Order does not automatically authorize the filing under seal of material 2 designated under this Order. Instead, the parties must comply with L.R. IA 3 10-5 if they seek to file anything under seal. This Order does not govern 4 the use at trial of material designated under this Order. Any use of 5 Protected Material at trial shall be governed by the orders of the trial judge. 6 2. DESIGNATING PROTECTED MATERIAL 7 2.1 Over-Designation Prohibited. Any party or non-party who 8 designates information or items for protection under this Order as 9 “CONFIDENTIAL” (a “designator”) must only designate specific material 10 that qualifies under the appropriate standards. To the extent practicable, 11 only those parts of documents, items, or oral or written communications 12 that require protection shall be designated. Mass, indiscriminate, or 13 routinized designations are prohibited. Unjustified designations expose 14 the designator to sanctions, including the Court’s striking all confidentiality 15 designations made by that designator. Designation under this Order is 16 allowed only if the designation is necessary to protect material that, if 17 disclosed to persons not authorized to view it, would cause competitive or 18 other recognized harm. Material may not be designated if it has been 19 made public, or if designation is otherwise unnecessary to protect a 20 secrecy interest. If a designator learns that information or items that it 21 designated for protection do not qualify for protection at all or do not 22 qualify for the level of protection initially asserted, that designator must 23 promptly notify all parties that it is withdrawing the mistaken designation. 24 2.2 Manner and Timing of Designations. Designation under this 25 Order requires the designator to affix the applicable legend 26 “CONFIDENTIAL” to each page that contains protected material. For 27 testimony given in deposition or other proceeding, the designator shall 1 It may make that designation during the deposition or proceeding, or may 2 invoke, on the record or by written notice to all parties on or before the 3 next business day, a right to have up to 21 days from receipt of the 4 deposition transcript or proceeding to make its designation. 5 2.2.1 A party or non-party that makes original documents or 6 materials available for inspection need not designate them for protection 7 until after the inspecting party has identified which material it would like 8 copied and produced. During the inspection and before the designation, 9 all material shall be treated as CONFIDENTIAL. After the inspecting party 10 has identified the documents it wants copied and produced, the producing 11 party must designate the documents, or portions thereof, that qualify for 12 protection under this Order. 13 2.2.2 If a party anticipates that anyone not authorized to 14 receive designated material may be present at a deposition or other 15 proceeding, the party shall give advance notice so that the other parties 16 have the opportunity to object. The use of a document as an exhibit at a 17 deposition shall not in any way affect its designation. Transcripts 18 containing designated material shall have a legend on the title page noting 19 the presence of designated material, and the title page shall be followed 20 by a list of all pages (including line numbers as appropriate) that have 21 been designated, and the level of protection being asserted. The 22 designator shall inform the court reporter of these requirements. Any 23 transcript that is prepared shall be treated as if it had been designated 24 CONFIDENTIAL for a period of 21 days from the delivery of the transcript 25 to the parties. After the expiration of the 21-day period, the transcript shall 26 be treated only as actually designated. 27 A party may designate the entirety of the Testimony at the 1 the right to identify more specific portions of the Testimony as to which 2 protection is sought within 21 days following receipt of the deposition 3 transcript. In circumstances where portions of the deposition Testimony 4 are designated for protection, the transcript pages containing 5 CONFIDENTIAL Information may be separately bound by the court 6 reporter, who must affix to the top of each page the legend 7 CONFIDENTIAL as instructed by the designator. 8 2.3 Inadvertent Failures to Designate. An inadvertent failure to 9 designate does not, standing alone, waive protection under this Order. 10 Upon timely assertion or correction of a designation, all recipients must 11 make reasonable efforts to ensure that the materials is treated according 12 to this Order. 13 3. CHALLENGING CONFIDENTIALITY DESIGNATIONS 14 All challenges to confidentiality designations shall proceed under 15 L.R. 26-6. 16 4. ACCESS TO DESIGNATED MATERIAL 17 4.1 Basic Principles. A receiving party may use designated 18 material only for this litigation. Designated material may be disclosed only 19 to the categories of persons and under the conditions described in this 20 Order. Attorneys for a party or the party itself / himself / themselves shall 21 not be permitted to use any designated material obtained in this case as 22 proof of facts in any other case. Any such evidence or discovery for use in 23 another case must be conducted independently of any information 24 designated as CONFIDENTIAL in this case. 25 4.2 Disclosure of CONFIDENTIAL Material Without Further 26 Approval. Unless otherwise ordered by the Court or permitted in writing 27 by the designator, a receiving party may disclose any material designated 1 4.2.1 The receiving party’s outside counsel of record in this 2 action and employees of outside counsel of record to whom disclosure is 3 reasonably necessary; 4 4.2.2 The officers, directors, and employees of the receiving 5 party to whom disclosure is reasonably necessary, and who have signed 6 the Agreement to Be Bound (Exhibit A); 7 4.2.3 Experts retained by the receiving party’s outside counsel 8 of record to whom disclosure is reasonably necessary, and who have 9 signed the Agreement to Be Bound (Exhibit A); 10 4.2.4 The Court and its personnel; 11 4.2.5 Outside court reporters and their staff, professional jury 12 or trial consultants, and professional vendors to whom disclosure is 13 reasonably necessary, and who have signed the Agreement to Be Bound 14 (Exhibit A); 15 4.2.6 During their depositions, witnesses in the action to whom 16 disclosure is reasonably necessary and who have signed the Agreement 17 to Be Bound (Exhibit A); and 18 4.2.7 The author or recipient of a document containing the 19 material, or a custodian or other person who otherwise possessed or knew 20 the information. 21 5. PROTECTED MATERIAL SUBPOENAED OR ORDERED 22 PRODUCED IN OTHER LITIGATION 23 5.1 Subpoenas and Court Orders. This Order in no way excuses 24 non-compliance with a lawful subpoena or court order. The purpose of the 25 duties described in this section is to alert the interested parties to the 26 existence of this Order and to give the designator an opportunity to protect 27 its confidentiality interests in the court where the subpoena or order 1 5.2 Notification requirement. If a party is served with a 2 subpoena or a court order issued in other litigation that compels disclosure 3 of any information or items designated in this action as CONFIDENTIAL 4 that party must: 5 5.2.1 Promptly notify the designator in writing. Such 6 notification shall include a copy of the subpoena or court order; 7 5.2.2 Promptly notify in writing the party who caused the 8 subpoena or order to issue in the other litigation that some or all of the 9 material covered by the subpoena or order is subject to this Order. Such 10 notification shall include a copy of this Order; and 11 5.2.3 Cooperate with all reasonable procedures sought by the 12 designator whose material may be affected. 13 5.3 Wait for Resolution of Protective Order. If the designator 14 timely seeks a protective order, the party served with the subpoena or 15 court order shall not produce any information designated in this action as 16 CONFIDENTIAL before a determination by the court where the subpoena 17 or order issued, unless the party has obtained the designator’s permission. 18 The designator shall bear the burden and expense of seeking protection of 19 its confidential material in that court. 20 6. UNAUTHORIZED DISCLOSURE OF DESIGNATED MATERIAL 21 If a receiving party learns that, by inadvertence or otherwise, it has 22 disclosed designated material to any person or in any circumstance not 23 authorized under this Order, it must immediately (1) notify in writing the 24 designator of the unauthorized disclosures, (2) use its best efforts to 25 retrieve all unauthorized copies of the designated material, (3) inform the 26 person or persons to whom unauthorized disclosures were made of all the 27 terms of this Order, and (4) use reasonable efforts to have such person or 1 7. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 2 PROTECTED MATERIAL 3 When a producing party gives notice that certain inadvertently 4 produced material is subject to a claim of privilege or other protection, the 5 obligations of the receiving parties are those set forth in Federal Rule of 6 Civil Procedure 26(b)(5)(B). This provision is not intended to modify 7 whatever procedure may be established in an e-discovery order that 8 provides for production without prior privilege review pursuant to Federal 9 Rule of Evidence 502(d) and (e). 10 8. FILING UNDER SEAL 11 Without written permission from the designator or a Court order, a 12 party may not file in the public record in this action any designated 13 material. A party seeking to file under seal any designated material must 14 comply with L.R. IA 10-5. Filings may be made under seal only pursuant 15 to a court order authorizing the sealing of the specific material at issue. 16 The fact that a document has been designated under this Order is 17 insufficient to justify filing under seal. Instead, parties must explain the 18 basis for confidentiality of each document sought to be filed under seal, 19 addressing the standards articulated in Kamakana v. City and County of 20 Honolulu,

(9th Cir. 2006) and Center for Auto Safety v. 21 Chrysler Group, LLC,

(9th Cir. 2016). Because a 22 party other than the designator will often be seeking to file designated 23 material, cooperation between the parties in preparing, and in reducing the 24 number and extent of, requests for under seal filing is essential. If a 25 receiving party’s request to file designated material under seal pursuant to 26 L.R. IA 10-5 is denied by the Court, then the receiving party may file the 27 material in the public record unless (1) the designator seeks 1 reconsideration within four days of the denial, or (2) as otherwise 2 instructed by the Court. 3 9. FINAL DISPOSITION 4 After termination of the representation of a client, counsel in 5 possession of any material designated as confidential at the expiration of 6 the appropriate amount of time as required by Rule 1.15 of the Nevada 7 Rules of Professional Responsibility (“NRPC”) and, to the extent longer 8 than the timeframe required by NRPC 1.15(a), the expiration of applicable 9 statutes of limitation for collateral claims, will destroy or return the 10 documents to the designating party. Counsel in possession of the 11 materials has the option to determine whether the materials are destroyed 12 or returned. Upon the request of counsel for the Designating Party or the 13 Court, counsel in possession of the materials will execute an affidavit or 14 declaration attesting that all such documents and copies of such 15 documents have been returned or destroyed. Any other person in receipt 16 of confidential material as set forth in § 4.2, supra, aside from counsel, to 17 whom disclosure was made agree to return or destroy all confidential 18 material to the designating party within ninety (90) days of the conclusion 19 of litigation between the parties, including final appellate action or the 20 expiration of time to appeal or seek further review. This provision shall not 21 prevent counsel from retaining an archival copy of all pleadings, motion 22 papers, trial, deposition, and hearing transcripts, legal memoranda, 23 correspondence, deposition and trial exhibits, expert reports, attorney work 24 product, and consultant and expert work product, even if such materials 25 26 27 1 ||contain designated material. Any such archival copies remain subject to 2 ||this Order. 3 IT IS SO ORDERED. ~ 4 ||DATED: 10/16/2025 OO 5 United States\Magistrate Judge 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

1 EXHIBIT A 2 CERTIFICATION RE CONFIDENTIAL DISCOVERY MATERIALS 3 I hereby acknowledge that I, ____________, [POSITION AND 4 EMPLOYER], am about to receive confidential materials supplied in 5 connection with the Proceeding, Civil Action No. _____________. I certify 6 that I understand that the confidential materials are provided to me subject 7 to the terms and restrictions of the Order filed in this Proceeding. I have 8 been given a copy of the Order; I have read it, and I agree to be bound by 9 its terms. 10 I understand that the confidential materials, as defined in the Order, 11 including any notes or other records that may be made regarding any such 12 materials, shall not be disclosed to anyone except as expressly permitted 13 by the Order. I will not copy or use, except solely for the purposes of this 14 Proceeding, any confidential materials obtained pursuant to this Order, 15 except as provided therein or otherwise ordered by the Court in the 16 Proceeding. 17 I further understand that I am to retain all copies of all confidential 18 materials provided to me in the Proceeding in a secure manner, and that 19 all copies of such materials are to remain in my personal custody until 20 termination of my participation in this 21 Proceeding, whereupon the copies of such materials will be returned to 22 counsel who provided me with such materials. 23 I declare under penalty of perjury, under the laws of the State 24 of ______________, that the foregoing is true and correct. Executed this 25 _____ day of ______, 20___, at _________________. 26 Signature: _________________________ 27 Printed Name: _________________________