NATIONAL GENERAL INSURANCE COMPANY v. DOYLE LAW, APC

• Court: District Court, C.D. California
• Decided: October 3, 2025
• Docket: 5:25-cv-00441
• Status: Unknown

Opinion

1 FREEMAN MATHIS & GARY, LLP Albert K. Alikin (SBN 265119) 2 Albert.Alikin@fmglaw.com 3 Alexander G. Meissner (SBN 315437) Alex.Meissner@fmglaw.com 4 550 South Hope Street, Suite 2200 Los Angeles, California 90071 5 Tel.: (213) 615-7000 Fax: (833) 264-2083 6 7 FREEMAN MATHIS & GARY, LLP P. Betty Su (SBN 229103) 8 pbetty.su@fmglaw.com 1850 Mt Diablo Blvd,, Ste 510 9 Walnut Creek, California 94596 10 Tel.: (925) 446-2612 Fax: (833) 330-3669 11 Attorneys for Defendant 12 NATIONAL GENERAL INSURANCE COMPANY 13 DOYLE LAW, APC 14 CONAL DOYLE, ESQ., SBN 227554 conal@conaldoylelaw.com 15 IAIN HILL, ESQ., SBN 336825 iain@conaldoylelaw.com 16 280 S. Beverly Drive, Penthouse 17 Beverly Hills, California 90212 Tel.: (310) 385-056 18 Attorneys for Plaintiff 19 SARAH MONTALVAN 20 DOYLE LAW GROUP 21 Daniel W. Doyle, Esq., SBN 147705 ddoyle@doyle-lawgroup.com 22 34022 Selva Road, Suite 52 23 Dana Point, CA 92629 Tel: (949) 233-5166 24 25 Attorneys for Plaintiff ANITA MYERS 26 27 1 UNITED STATES DISTRICT COURT 2 CENTRAL DISTRICT OF CALIFORNIA 3 SARAH MONTALVAN; and ANITA Case No. 5:25-cv-00441 SPG (SSCx) 4 MYERS, 5 Plaintiffs, 6 STIPULATED PROTECTIVE v. ORDER 7 NATIONAL GENERAL INSURANCE 8 COMPANY; and DOES 1-50, 9 Defendants. 10 11 12 13 IT IS HEREBY STIPULATED by and between Plaintiffs SARAH 14 MONTALVAN and ANITA MYERS and Defendant NATIONAL GENERAL 15 INSURANCE COMPANY, by and through their respective counsel of record, that in 16 order to facilitate discovery in this Action while addressing potential confidentiality 17 concerns under federal law, state law, and applicable privacy rights, the Parties 18 stipulate to the following Protective Order: 19 20 21 1. INTRODUCTION 22 1.1 Purposes and Limitations. Discovery in this action is likely to 23 involve production of confidential, proprietary, or private information for 24 which special protection from public disclosure and from use for any 25 purpose other than prosecuting this litigation may be warranted. 26 Accordingly, the parties hereby stipulate to and petition the court to 27 1 acknowledge that this Order does not confer blanket protections on all 2 disclosures or responses to discovery and that the protection it affords 3 from public disclosure and use extends only to the limited information or 4 items that are entitled to confidential treatment under the applicable 5 legal principles. 6 1.2 Good Cause Statement. ( [*The “Good Cause Statement” 7 should be edited to include or exclude specific information that 8 applies to the particular case, i.e., what harm will result from the 9 disclosure of the confidential information likely to be produced 10 in this case? Below is an example]: (Original Emphasis.) 11 This action is likely to involve trade secrets, customer and pricing 12 lists and other valuable research, development, commercial, financial, 13 technical and/or proprietary information for which special protection 14 from public disclosure and from use for any purpose other than 15 prosecution of this action is warranted. Such confidential and 16 proprietary materials and information consist of, among other things, 17 confidential business or financial information, information regarding 18 confidential business practices, or other confidential research, 19 development, or commercial information (including information 20 implicating privacy rights of third parties), information otherwise 21 22 generally unavailable to the public, or which may be privileged or 23 otherwise protected from disclosure under state or federal statutes, court 24 rules, case decisions, or common law. Accordingly, to expedite the flow of 25 information, to facilitate the prompt resolution of disputes over 26 confidentiality of discovery materials, to adequately protect information 27 the parties are entitled to keep confidential, to ensure that the parties 1 for and in the conduct of trial, to address their handling at the end of the 2 litigation, and serve the ends of justice, a protective order for such 3 information is justified in this matter. It is the intent of the parties that 4 information will not be designated as confidential for tactical reasons 5 and that nothing be so designated without a good faith belief that it has 6 been maintained in a confidential, non-public manner, and there is good 7 cause why it should not be part of the public record of this case. 8 1.3 Acknowledgment of Procedure for Filing Under Seal. The 9 parties further acknowledge, as set forth in Section 12.3, below, that this 10 Stipulated Protective Order does not entitle them to file confidential 11 information under seal; Local Rule 79-5 sets forth the procedures that 12 must be followed and the standards that will be applied when a party 13 seeks permission from the court to file material under seal. 14 There is a strong presumption that the public has a right of access 15 to judicial proceedings and records in civil cases. In connection with 16 non-dispositive motions, good cause must be shown to support a filing 17 under seal. See Kamakana v. City and Cnty. of Honolulu, 447 F.3d 18 1172, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd v. Gen. Motors 19 Corp., 307 F.3d 1206, 1210–11 (9th Cir. 2002), Makar-Welbon v. Sony 20 Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated 21 22 protective orders require good cause showing), and a specific showing of 23 good cause or compelling reasons with proper evidentiary support and 24 legal justification, must be made with respect to Protected Material that 25 a party seeks to file under seal. The parties’ mere designation of 26 Disclosure or Discovery Material as CONFIDENTIAL does not— 27 without the submission of competent evidence by declaration, 1 confidential, privileged, or otherwise protectable—constitute good cause. 2 Further, if a party requests sealing related to a dispositive motion 3 or trial, then compelling reasons, not only good cause, for the sealing 4 must be shown, and the relief sought shall be narrowly tailored to serve 5 the specific interest to be protected. See Pintos v. Pac. Creditors Ass’n, 6 605 F.3d 665, 677–79 (9th Cir. 2010). For each item or type of 7 information, document, or thing sought to be filed or introduced under 8 seal in connection with a dispositive motion or trial, the party seeking 9 protection must articulate compelling reasons, supported by specific 10 facts and legal justification, for the requested sealing order. Again, 11 competent evidence supporting the application to file documents under 12 seal must be provided by declaration. 13 Any document that is not confidential, privileged, or otherwise 14 protectable in its entirety will not be filed under seal if the confidential 15 portions can be redacted. If documents can be redacted, then a redacted 16 version for public viewing, omitting only the confidential, privileged, or 17 otherwise protectable portions of the document, shall be filed. Any 18 application that seeks to file documents under seal in their entirety 19 should include an explanation of why redaction is not feasible. 20 21 22 2. DEFINITIONS 23 2.1 Action. means Case No. 5:25-cv-00441 SPG (SHKx). 24 2.2 Challenging Party: a Party or Non-Party that challenges the 25 designation of information or items under this Order. 26 2.3 “CONFIDENTIAL” Information or Items: information 27 (regardless of how it is generated, stored or maintained) or tangible 1 things that qualify for protection under Rule 26(c) of the Federal Rules of 2 Civil Procedure, and as specified above in the Good Cause Statement. 3 2.4 Counsel: Outside Counsel of Record and House Counsel (as 4 well as their support staff). 5 2.5 Designating Party: a Party or Non-Party that designates 6 information or items that it produces in disclosures or in responses to 7 discovery as “CONFIDENTIAL.” 8 2.6 Disclosure or Discovery Material: all items or information, 9 regardless of the medium or manner in which it is generated, stored, or 10 maintained (including, among other things, testimony, transcripts, and 11 tangible things), that are produced or generated in disclosures or 12 responses to discovery in this matter. 13 2.7 Expert: a person with specialized knowledge or experience in 14 a matter pertinent to the litigation who has been retained by a Party or 15 its counsel to serve as an expert witness or as a consultant in this Action. 16 2.8 Final Disposition: the later of (1) dismissal of all claims and 17 defenses in this Action, with or without prejudice; and (2) final judgment 18 herein after the completion and exhaustion of all appeals, rehearings, 19 remands, trials, or reviews of this Action, including the time limits for 20 filing any motions or applications for extension of time pursuant to 21 22 applicable law. 23 2.9 In-House Counsel: attorneys who are employees of a party to 24 this Action. In-House Counsel does not include Outside Counsel of 25 Record or any other outside counsel. 26 2.10 Non-Party: any natural person, partnership, corporation, 27 association, or other legal entity not named as a Party to this action. 1 of a party to this Action but are retained to represent or advise a party to 2 this Action and have appeared in this Action on behalf of that party or 3 are affiliated with a law firm which has appeared on behalf of that party, 4 and includes support staff. 5 2.12 Party: any party to this Action, including all of its officers, 6 directors, employees, consultants, retained experts, and Outside Counsel 7 of Record (and their support staffs). 8 2.13 Producing Party: a Party or Non-Party that produces 9 Disclosure or Discovery Material in this Action. 10 2.14 Professional Vendors: persons or entities that provide 11 litigation- support services (e.g., photocopying, videotaping, translating, 12 preparing exhibits or demonstrations, and organizing, storing, or 13 retrieving data in any form or medium) and their employees and 14 subcontractors. 15 2.15 Protected Material: any Disclosure or Discovery Material that 16 is designated as “CONFIDENTIAL.” 17 2.16 Receiving Party: a Party that receives Disclosure or Discovery 18 Material from a Producing Party. 19 20 21 3. SCOPE 22 The protections conferred by this Stipulation and Order cover not 23 only Protected Material (as defined above), but also (1) any information 24 copied or extracted from Protected Material; (2) all copies, excerpts, 25 summaries, or compilations of Protected Material; and (3) any 26 testimony, conversations, or presentations by Parties or their Counsel 27 that might reveal Protected Material. 1 Any use of Protected Material at trial shall be governed by the 2 orders of the trial judge. This Stipulated Protective Order does not 3 govern the use of Protected Material at trial. 4 5 4. TRIAL AND DURATION 6 The terms of this Stipulated Protective Order apply through Final 7 Disposition of the Action. 8 Once a case proceeds to trial, information that was designated as 9 CONFIDENTIAL or maintained pursuant to this Stipulated Protective 10 Order and used or introduced as an exhibit at trial becomes public and 11 will be presumptively available to all members of the public, including 12 the press, unless compelling reasons supported by specific factual 13 14 findings to proceed otherwise are made to the trial judge in advance of 15 the trial. See Kamakana, 447 F.3d at 1180–81 (distinguishing “good 16 cause” showing for sealing documents produced in discovery from 17 “compelling reasons” standard when merits-related documents are part 18 of court record). Accordingly, for such materials, the terms of this 19 Stipulated Protective Order do not extend beyond the commencement of 20 the trial. 21 22 5. DESIGNATING PROTECTED MATERIAL 23 5.1 Exercise of Restraint and Care in Designating Material for 24 Protection. Each Party or Non-Party that designates information or 25 items for protection under this Order must take care to limit any such 26 designation to specific material that qualifies under the appropriate 27 1 those parts of material, documents, items, or oral or written 2 communications that qualify so that other portions of the material, 3 documents, items, or communications for which protection is not 4 warranted are not swept unjustifiably within the ambit of this Order. 5 Mass, indiscriminate, or routinized designations are prohibited. 6 Designations that are shown to be clearly unjustified or that have been 7 made for an improper purpose (e.g., to unnecessarily encumber the case 8 development process or to impose unnecessary expenses and burdens on 9 other parties) may expose the Designating Party to sanctions. 10 If it comes to a Designating Party’s attention that information or 11 items that it designated for protection do not qualify for protection, that 12 Designating Party must promptly notify all other Parties that it is 13 withdrawing the inapplicable designation. 14 5.2 Manner and Timing of Designations. Except as otherwise 15 provided in this Stipulated Protective Order (see, e.g., second paragraph 16 of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure 17 18 or Discovery Material that qualifies for protection under this Stipulated 19 Protective Order must be clearly so designated before the material is 20 disclosed or produced. 21 Designation in conformity with this Stipulated Protective Order 22 requires: 23 (a) for information in documentary form (e.g., paper or electronic 24 documents, but excluding transcripts of depositions or other pretrial or 25 trial proceedings), that the Producing Party affix at a minimum, the 26 legend “CONFIDENTIAL” to each page that contains protected 27 material. If only a portion or portions of the material on a page 1 qualifies for protection, the Producing Party also must clearly identify 2 the protected portion(s) (e.g., by making appropriate markings in the 3 margins). 4 A Party or Non-Party that makes original documents available for 5 inspection need not designate them for protection until after the 6 inspecting Party has indicated which documents it would like copied 7 and produced. During the inspection and before the designation, all of 8 the material made available for inspection shall be deemed 9 CONFIDENTIAL. After the inspecting Party has identified the 10 documents it wants copied and produced, the Producing Party must 11 determine which documents, or portions thereof, qualify for protection 12 under this Stipulated Protective Order. Then, before producing the 13 specified documents, the Producing Party must affix the 14 “CONFIDENTIAL” legend to each page that contains Protected 15 Material. If only a portion or portions of the material on a page 16 qualifies for protection, the Producing Party also must clearly identify 17 the protected portion(s) (e.g., by making appropriate markings in the 18 margins). 19 (b) for testimony given in depositions that the Designating Party 20 identify the Disclosure or Discovery Material on the record, before the 21 22 close of the deposition all protected testimony. 23 (c) for information produced in some form other than 24 documentary and for any other tangible items, that the Producing Party 25 affix in a prominent place on the exterior of the container or containers 26 in which the information is stored the “CONFIDENTIAL” legend. If only 27 a portion or portions of the information warrants protection, the 1 portion(s). 2 5.3 Inadvertent Failures to Designate. If timely corrected, an 3 inadvertent failure to designate qualified information or items does not, 4 standing alone, waive the Designating Party’s right to secure protection 5 under this Order for such material. Upon timely correction of a 6 designation, the Receiving Party must make reasonable efforts to assure 7 that the material is treated in accordance with the provisions of this 8 Stipulated Protective Order. 9 10 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 11 6.1 Timing of Challenges. Any Party or Non-Party may 12 challenge a designation of confidentiality at any time that is consistent 13 14 with the court’s Scheduling Order. 15 6.2 Meet and Confer. The Challenging Party shall initiate the 16 dispute resolution process under Local Rule 37.1 et seq. 17 6.3 The burden of persuasion in any such challenge proceeding 18 shall be on the Designating Party. Frivolous challenges, and those 19 made for an improper purpose (e.g., to harass or impose unnecessary 20 expenses and burdens on other parties) may expose the Challenging 21 Party to sanctions. Unless the Designating Party has waived or 22 withdrawn the confidentiality designation, all parties shall continue to 23 afford the material in question the level of protection to which it is 24 entitled under the Producing Party’s designation until the court rules on 25 the challenge. 26 /// 27 /// 1 7. ACCESS TO AND USE OF PROTECTED MATERIAL 2 7.1 Basic Principles. A Receiving Party may use Protected 3 Material that is disclosed or produced by another Party or by a Non- 4 Party in connection with this Action only for prosecuting, defending, or 5 attempting to settle this Action. Such Protected Material may be 6 disclosed only to the categories of persons and under the conditions 7 described in this Order. When the Action reaches a Final Disposition, a 8 Receiving Party must comply with the provisions of section 13 below. 9 Protected Material must be stored and maintained by a Receiving 10 Party at a location and in a secure manner that ensures that access is 11 limited to the persons authorized under this Stipulated Protective 12 Order. 13 7.2 Disclosure of “CONFIDENTIAL” Information or Items. 14 Unless otherwise ordered by the court or permitted in writing by the 15 Designating Party, a Receiving Party may disclose any information or 16 item designated “CONFIDENTIAL” only: 17 18 (a) to the Receiving Party’s Outside Counsel of Record in this 19 Action, as well as employees of said Outside Counsel of Record to whom 20 it is reasonably necessary to disclose the information for this Action; 21 (b) to the officers, directors, and employees (including House 22 Counsel) of the Receiving Party to whom disclosure is reasonably 23 necessary for this Action; 24 (c) to Experts (as defined in this Order) of the Receiving Party to 25 whom disclosure is reasonably necessary for this Action and who have 26 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 27 (d) to the court and its personnel; 1 (e) to court reporters and their staff; 2 (f) to professional jury or trial consultants, mock jurors, and 3 Professional Vendors to whom disclosure is reasonably necessary for 4 this Action and who have signed the “Acknowledgment and Agreement 5 to Be Bound” (Exhibit A); 6 (g) to the author or recipient of a document containing the 7 information or a custodian or other person who otherwise possessed or 8 knew the information; 9 (h) during their depositions, to witnesses, and attorneys for 10 witnesses, in the Action to whom disclosure is reasonably necessary, 11 provided: (1) the deposing party requests that the witness sign the 12 “Acknowledgment and Agreement to Be Bound” (Exhibit A); and (2) the 13 witness will not be permitted to keep any confidential information 14 unless they sign the “Acknowledgment and Agreement to Be Bound” 15 (Exhibit A), unless otherwise agreed by the Designating Party or 16 ordered by the court. Pages of transcribed deposition testimony or 17 exhibits to depositions that reveal Protected Material may be separately 18 bound by the court reporter and may not be disclosed to anyone except 19 as permitted under this Stipulated Protective Order; and 20 (i) to any mediator or settlement officer, and their supporting 21 22 personnel, mutually agreed upon by any of the parties engaged in 23 settlement discussions. 24 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 25 26 PRODUCED IN OTHER LITIGATION 27 If a Party is served with a subpoena or a court order issued in 1 designated in this Action as “CONFIDENTIAL,” that Party must: 2 (a) promptly notify in writing the Designating Party. Such 3 notification shall include a copy of the subpoena or court order; 4 (b) promptly notify in writing the party who caused the 5 subpoena or order to issue in the other litigation that some or all of the 6 material covered by the subpoena or order is subject to this Protective 7 Order. Such notification shall include a copy of this Stipulated 8 Protective Order; and 9 (c) cooperate with respect to all reasonable procedures sought to 10 be pursued by the Designating Party whose Protected Material may be 11 affected. 12 If the Designating Party timely seeks a protective order, the 13 Party served with the subpoena or court order shall not produce any 14 information designated in this action as “CONFIDENTIAL” before a 15 determination by the court from which the subpoena or order issued, 16 unless the Party has obtained the Designating Party’s permission. The 17 18 Designating Party shall bear the burden and expense of seeking 19 protection in that court of its confidential material and nothing in these 20 provisions should be construed as authorizing or encouraging a 21 Receiving Party in this Action to disobey a lawful directive from another 22 court. 23 24 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 25 PRODUCED IN THIS LITIGATION 26 9.1 Application. The terms of this Stipulated Protective Order 27 are applicable to information produced by a Non-Party in this Action and 1 designated as “CONFIDENTIAL.” Such information produced by Non- 2 Parties in connection with this litigation is protected by the remedies 3 and relief provided by this Order. Nothing in these provisions should be 4 construed as prohibiting a Non-Party from seeking additional 5 protections. 6 9.2 Notification. In the event that a Party is required, by a valid 7 discovery request, to produce a Non-Party’s confidential information in 8 its possession, and the Party is subject to an agreement with the Non- 9 Party not to produce the Non-Party’s confidential information, then the 10 Party shall: 11 (a) promptly notify in writing the Requesting Party and the 12 Non-Party that some or all of the information requested is subject to a 13 confidentiality agreement with a Non-Party; 14 (b) make the information requested available for inspection by 15 the Non-Party, if requested. 16 9.3 Conditions of Production. If the Non-Party fails to seek a 17 protective order from this court within 14 days of receiving the notice 18 and accompanying information, the Receiving Party may produce the 19 Non-Party’s confidential information responsive to the discovery request. 20 If the Non-Party timely seeks a protective order, the Receiving Party 21 22 shall not produce any information in its possession or control that is 23 subject to the confidentiality agreement with the Non-Party before a 24 determination by the court. Absent a court order to the contrary, the 25 Non-Party shall bear the burden and expense of seeking protection in 26 this court of its Protected Material. 27 10. UNAUTHORIZED DISCLOSURE OF PROTECTED 1 If a Receiving Party learns that, by inadvertence or otherwise, it 2 has disclosed Protected Material to any person or in any circumstance 3 not authorized under this Stipulated Protective Order, the Receiving 4 Party must immediately (a) notify in writing the Designating Party of 5 the unauthorized disclosures, (b) use its best efforts to retrieve all 6 unauthorized copies of the Protected Material, (c) inform the person or 7 persons to whom unauthorized disclosures were made of all the terms of 8 this Order, and (d) request such person or persons to execute the 9 “Acknowledgment and Agreement to Be Bound” (Exhibit A). 10 11 11. INADVERTENT PRODUCTION OF PRIVILEGED OR 12 OTHERWISE PROTECTED MATERIAL 13 14 When a Producing Party gives notice to Receiving Parties that 15 certain inadvertently produced material is subject to a claim of privilege 16 or other protection, the obligations of the Receiving Parties are those set 17 forth in Rule 26(b)(5)(B) of the Federal Rules of Civil Procedure. This 18 provision is not intended to modify whatever procedure may be 19 established in an e-discovery order that provides for production without 20 prior privilege review. Pursuant to Rules 502(d) and (e) of the Federal 21 Rules of Evidence, insofar as the parties reach an agreement on the 22 effect of disclosure of a communication or information covered by the 23 attorney-client privilege or work product protection, the parties may 24 incorporate their agreement in the stipulated protective order 25 submitted to the court. 26 27 1 12. MISCELLANEOUS 2 12.1 Right to Further Relief. Nothing in this Stipulated 3 Protective Order abridges the right of any person to seek its 4 modification by the court in the future. 5 12.2 Right to Assert Other Objections. By stipulating to the entry 6 of this Stipulated Protective Order no Party waives any right it 7 otherwise would have to object to disclosing or producing any 8 information or item on any ground not addressed in this Stipulated 9 Protective Order. Similarly, no Party waives any right to object on any 10 ground to use in evidence of any of the material covered by this 11 Stipulated Protective Order. 12 12.3 Filing Protected Material. A Party that seeks to file under 13 seal any Protected Material must comply with Local Rule 79-5. 14 Protected Material may only be filed under seal pursuant to a court 15 order authorizing the sealing of the specific Protected Material at issue. 16 If a Party's request to file Protected Material under seal is denied by the 17 18 court, then the Receiving Party may file the information in the public 19 record unless otherwise instructed by the court. 20 21 13. FINAL DISPOSITION 22 After the Final Disposition of this Action, as defined in paragraph 23 4, within 60 days of a written request by the Designating Party, each 24 Receiving Party must return all Protected Material to the Producing 25 Party or destroy such material. As used in this subdivision, “all 26 Protected Material” includes all copies, abstracts, compilations, 27 summaries, and any other format reproducing or capturing any of the 1 Protected Material. Whether the Protected Material is returned or 2 destroyed, the Receiving Party must submit a written certification to 3 the Producing Party (and, if not the same person or entity, to the 4 Designating Party) by the 60 day deadline that (1) identifies (by 5 category, where appropriate) all the Protected Material that was 6 returned or destroyed and (2) affirms that the Receiving Party has not 7 retained any copies, abstracts, compilations, summaries or any other 8 format reproducing or capturing any of the Protected Material. 9 Notwithstanding this provision, Counsel is entitled to retain an archival 10 copy of all pleadings, motion papers, trial, deposition, and hearing 11 transcripts, legal memoranda, correspondence, deposition and trial 12 exhibits, expert reports, attorney work product, and consultant and 13 expert work product, even if such materials contain Protected Material. 14 Any such archival copies that contain or constitute Protected Material 15 remain subject to this Protective Order as set forth in Section 4. 16 14. VIOLATION 17 Any violation of this Stipulated Protective Order may be punished 18 by any and all appropriate measures including, without limitation, 19 contempt proceedings and/or monetary sanctions. 20 21 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 22 Dated: June 27, 2025 FREEMAN MATHIS & GARY, LLP 23 September 23, 2025 24 By: 25 Albert K. Alikin Alexander G. Meissner 26 P. Betty Su Attorneys for Defendant 27 NATIONAL GENERAL Dated: September 22, 2025 DOYLE LAW, APC

By Conad Pegle lain Hill

7 || Dated: 09 22, 2025 DOYLE LAW GROUP 8 \} Ke °Y Daniel W-Doyle

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

13 ia || DATED: Oct. 3, 2025 /s/

15 Hon. Stephanie 8. Christensen 6 United States Magistrate Judge

17 18 19 20 21 22 23 24 25 26 27 28

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