Starline Tours of Hollywood, Inc. v. Carolina Casualty Insurance Company

1 SCOTT SVESLOSKY, Cal Bar No. 217660 PATRICK R. EMERSON, Cal Bar No. 330610 2 SHEPPARD, MULLIN, RICHTER & HAMPTON LLP 350 South Grand Avenue, 40th Floor 3 Los Angeles, California 90071-3460 Telephone: 213.620.1780 4 Facsimile: 213.620.1398 Email: ssveslosky@sheppardmullin.com 5 pemerson@sheppardmullin.com 6 Attorneys for Defendant PRIME INSURANCE COMPANY 7 (erroneously sued as Prime Insurance Company, Inc.) 8 9 10 UNITED STATES DISTRICT COURT 11 CENTRAL DISTRICT OF CALIFORNIA 12 WESTERN DIVISION 13 14 STARLINE TOURS OF Case No. 2:25-cv-08254-MCS-RAO HOLLYWOOD, INC., a California 15 corporation; SCREAMLINE INVESTMENT CORPORATION, a 16 California corporation, DISCOVERY MATTER 17 Plaintiffs, STIPULATED PROTECTIVE 18 v. ORDER1 19 CAROLINA CASUALTY INSURANCE COMPANY, an Iowa Complaint filed: July 14, 2025 20 corporation; PRIME INSURANCE Removal date: September 2, 2025 COMPANY, INC., an Unknown Trial date: December 8, 2026 21 Business Entity; and DOES 1 TO 50, INCLUSIVE, 22 Defendants. 23 24 25 26 27 1 This Stipulated Protective Order is substantially based on the model protective 1 Plaintiffs Starline Tours of Hollywood, Inc. and Screamline Investment 2 Corporation and defendants Carolina Casualty Insurance Company and Prime 3 Insurance Company, by and through their respective attorneys of record, hereby 4 enter into this stipulation and respectfully request this Court’s entry of the following 5 Protective Order, pursuant to Rules 26(c) and 29(b) of the Federal Rules of Civil 6 Procedure, and Local Rule 7-1: 7 8 1. A. PURPOSES AND LIMITATIONS 9 Discovery in this action is likely to involve production of confidential, 10 proprietary and/or private information for which special protection from public 11 disclosure and from use for any purpose other than this litigation may be warranted. 12 Accordingly, the parties hereby stipulate to and petition the Court to enter the 13 following Stipulated Protective Order. The parties acknowledge that this Order does 14 not confer blanket protections on all disclosures or responses to discovery and that 15 the protection it affords from public disclosure and use extends only to the limited 16 information or items that are entitled to confidential treatment under the applicable 17 legal principles. 18 19 B. GOOD CAUSE STATEMENT 20 This action involves an insurance claim arising from a lawsuit against 21 Plaintiff Starline by one of its competitors which alleges, among other things, “false 22 advertising” by Starline. Plaintiffs assert breach of contract and “bad faith” claims 23 against Defendants, which are Plaintiffs’ insurers, for not defending Starline in the 24 underlying lawsuit, for failure to pay claims, and a for converting monies against 25 Defendant Carolina Casualty. Defendants assert that they did not owe Starline a 26 defense and otherwise deny any liability. 27 This action will involve commercial, financial and/or proprietary information 1 special protection from public disclosure and from use for any purpose other than 2 this action. Such confidential and proprietary materials and information may consist 3 of, among other things: (i) confidential business or financial information, (ii) 4 confidential business practices, (iii) confidential underwriting information, and (iv) 5 information otherwise generally unavailable to the public, or which may be 6 privileged or otherwise protected from disclosure under state or federal statutes, 7 court rules, case decisions, or common law. 8 For example, Plaintiffs have asked Prime and Carolina Casualty to produce 9 their underwriting files. Those materials contain confidential underwriting 10 information, confidential business or financial information, and reflect confidential 11 business practices, including in relation to premium pricing models and calculations. 12 Plaintiffs have also asked Prime and Carolina Casualty to produce claims handling 13 manuals, bulletins, rules, and the like, pertaining to handling, processing, 14 investigating, evaluating, and decision making for claims. Those materials contain 15 confidential business or financial information and reflect confidential business 16 practices. Plaintiffs may also propound other written discovery and/or seek 17 deposition testimony relating to information in the underwriting and/or claim 18 handling documents. 19 Absent a Protective Order barring public dissemination of this information, 20 Prime and Carolina Casualty risk competitive disadvantage, as competitors could 21 access their pricing models to lure away current and potential customers, and could 22 exploit their proprietary claim handling materials and information. Further, each of 23 the defendants Carolina Casualty and Prime risks competitive disadvantage unless a 24 Protective order limits the other’s internal dissemination and use of confidential 25 materials. 26 Accordingly, to expedite the flow of information, to facilitate the prompt 27 resolution of disputes over confidentiality of discovery materials, to adequately 1 parties are permitted reasonable necessary uses of such material in preparation for 2 and in the conduct of trial, to address their handling at the end of litigation, and to 3 serve the ends of justice, a Protective Order for such information is justified in this 4 matter. It is the intent of the parties that information will not be designated as 5 confidential for tactical reasons and that nothing be so designated without a good- 6 faith belief that it has been maintained in a confidential, non-public manner, and 7 there is good cause why it should not be part of the public record of this case. 8 9 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER 10 SEAL 11 The parties further acknowledge, as set forth in Section 12.3, below, that this 12 Stipulated Protective Order does not entitle them to file confidential information 13 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed 14 and the standards that will be applied when a party seeks permission from the court 15 to file material under seal. 16 There is a strong presumption that the public has a right of access to judicial 17 proceedings and records in civil cases. In connection with non-dispositive motions, 18 good cause must be shown to support a filing under seal. See Kamakana v. City and 19 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006); Phillips v. Gen. Motors 20 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002); Makar-Welbon v. Sony Electrics, 21 Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders 22 require good cause showing), and a specific showing of good cause or compelling 23 reasons with proper evidentiary support and legal justification, must be made with 24 respect to Protected Material that a party seeks to file under seal. The parties’ mere 25 designation of Disclosure or Discovery Material as CONFIDENTIAL does not— 26 without the submission of competent evidence by declaration, establishing that the 27 material sought to be filed under seal qualifies as confidential, privileged, or 1 Further, if a party requests sealing related to a dispositive motion or trial, then 2 compelling reasons, not only good cause, for the sealing must be shown, and the 3 relief sought shall be narrowly tailored to serve the specific interest to be protected. 4 See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For 5 each item or type of information, document, or thing sought to be filed or introduced 6 under seal in connection with a dispositive motion or trial, the party seeking 7 protection must articulate compelling reasons, supported by specific facts and legal 8 justification, for the requested sealing order. Again, competent evidence supporting 9 the application to file documents under seal must be provided by declaration. 10 Any document that is not confidential, privileged, or otherwise protectable in 11 its entirety will not be filed under seal if the confidential portions can be redacted. 12 If documents can be redacted, then a redacted version for public viewing, omitting 13 only the confidential, privileged, or otherwise protectable portions of the document 14 shall be filed. Any application that seeks to file documents under seal in their 15 entirety should include an explanation of why redaction is not feasible. 16 17 2. DEFINITIONS 18 2.1 Action: This pending federal lawsuit. 19 2.2 Challenging Party: a Party or Non-Party that challenges the 20 designation of information or items under this Order. 21 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 22 how it is generated, stored or maintained) or tangible things that qualify for 23 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 24 the Good Cause Statement. 25 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 26 their support staff). 27 1 2.5 Designating Party: a Party or Non-Party that designates information or 2 items that it produces in disclosures or in responses to discovery as 3 “CONFIDENTIAL.” 4 2.6 Disclosure or Discovery Material: all items or information, regardless 5 of the medium or manner in which it is generated, stored, or maintained (including, 6 among other things, testimony, transcripts, and tangible things) that are produced or 7 generated in disclosures or responses to discovery in this matter. 8 2.7 Expert: a person with specialized knowledge or experience in a matter 9 pertinent to the litigation who has been retained by a Party or its counsel to serve as 10 an expert witness or as a consultant in this Action. 11 2.8 House Counsel: attorneys who are employees of a party to this Action. 12 House Counsel does not include Outside Counsel of Record or any other outside 13 counsel. 14 2.9 Non-Party: any natural person, partnership, corporation, association or 15 other legal entity not named as a Party to this action. 16 2.10 Outside Counsel of Record: attorneys who are not employees of a 17 party to this Action but are retained to represent or advise a party to this Action and 18 have appeared in this Action on behalf of that party or are affiliated with a law firm 19 that has appeared on behalf of that party, and includes support staff. 20 2.11 Party: any party to this Action, including all of its officers, directors, 21 employees, consultants, retained experts, and Outside Counsel of Record (and their 22 support staffs). 23 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 24 Discovery Material in this Action. 25 2.13 Professional Vendors: persons or entities that provide litigation 26 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 27 demonstrations, and organizing, storing, or retrieving data in any form or medium) 1 2.14 Protected Material: any Disclosure or Discovery Material that is 2 designated as “CONFIDENTIAL.” 3 2.15 Receiving Party: a Party that receives Disclosure or Discovery 4 Material from a Producing Party. 5 6 3. SCOPE 7 The protections conferred by this Stipulation and Order cover not only 8 Protected Material (as defined above), but also (1) any information copied or 9 extracted from Protected Material; (2) all copies, excerpts, summaries, or 10 compilations of Protected Material; and (3) any testimony, conversations, or 11 presentations by Parties or their Counsel that might reveal Protected Material. 12 Any use of Protected Material at trial shall be governed by the orders of the 13 trial judge. This Order does not govern the use of Protected Material at trial. 14 15 4. DURATION 16 Once a case proceeds to trial, information that was designated as 17 CONFIDENTIAL or maintained pursuant to this protective order used or introduced 18 as an exhibit at trial becomes public and will be presumptively available to all 19 members of the public, including the press, unless compelling reasons supported by 20 specific factual findings to proceed otherwise are made to the trial judge in advance 21 of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” 22 showing for sealing documents produced in discovery from “compelling reasons” 23 standard when merits-related documents are part of court record). Accordingly, the 24 terms of this protective order do not extend beyond the commencement of the trial. 25 26 5. DESIGNATING PROTECTED MATERIAL 27 5.1 Exercise of Restraint and Care in Designating Material for Protection. 1 this Order must take care to limit any such designation to specific material that 2 qualifies under the appropriate standards. The Designating Party must designate for 3 protection only those parts of material, documents, items or oral or written 4 communications that qualify so that other portions of the material, documents, items 5 or communications for which protection is not warranted are not swept unjustifiably 6 within the ambit of this Order. 7 Mass, indiscriminate or routinized designations are prohibited. Designations 8 that are shown to be clearly unjustified or that have been made for an improper 9 purpose (e.g., to unnecessarily encumber the case development process or to impose 10 unnecessary expenses and burdens on other parties) may expose the Designating 11 Party to sanctions. 12 If it comes to a Designating Party’s attention that information or items that it 13 designated for protection do not qualify for protection, that Designating Party must 14 promptly notify all other Parties that it is withdrawing the inapplicable designation. 15 5.2 Manner and Timing of Designations. Except as otherwise provided in 16 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 17 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 18 under this Order must be clearly so designated before the material is disclosed or 19 produced. 20 Designation in conformity with this Order requires: 21 (a) for information in documentary form (e.g., paper or electronic 22 documents, but excluding transcripts of depositions or other pretrial or trial 23 proceedings), that the Producing Party affix at a minimum, the legend 24 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 25 contains protected material. If only a portion of the material on a page qualifies for 26 protection, the Producing Party also must clearly identify the protected portion(s) 27 (e.g., by making appropriate markings in the margins). 1 A Party or Non-Party that makes original documents available for inspection 2 need not designate them for protection until after the inspecting Party has indicated 3 which documents it would like copied and produced. During the inspection and 4 before the designation, all of the material made available for inspection shall be 5 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 6 documents it wants copied and produced, the Producing Party must determine which 7 documents, or portions thereof, qualify for protection under this Order. Then, 8 before producing the specified documents, the Producing Party must affix the 9 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 10 portion of the material on a page qualifies for protection, the Producing Party also 11 must clearly identify the protected portion(s) (e.g., by making appropriate markings 12 in the margins). 13 (b) for testimony given in depositions that the Designating Party identifies 14 the Disclosure or Discovery Material on the record, before the close of the 15 deposition all protected testimony. 16 (c) for information produced in some form other than documentary and 17 for any other tangible items, that the Producing Party affix in a prominent place on 18 the exterior of the container or containers in which the information is stored the 19 legend “CONFIDENTIAL.” If only a portion or portions of the information 20 warrants protection, the Producing Party, to the extent practicable, shall identify the 21 protected portion(s). 22 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 23 failure to designate qualified information or items does not, standing alone, waive 24 the Designating Party’s right to secure protection under this Order for such material. 25 Upon timely correction of a designation, the Receiving Party must make reasonable 26 efforts to assure that the material is treated in accordance with the provisions of this 27 Order. 1 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 2 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 3 designation of confidentiality at any time that is consistent with the Court’s 4 Scheduling Order. 5 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 6 resolution process under Local Rule 37.1 et seq. 7 6.3 The burden of persuasion in any such challenge proceeding shall be on 8 the Designating Party. Frivolous challenges, and those made for an improper 9 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 10 parties) may expose the Challenging Party to sanctions. Unless the Designating 11 Party has waived or withdrawn the confidentiality designation, all parties shall 12 continue to afford the material in question the level of protection to which it is 13 entitled under the Producing Party’s designation until the Court rules on the 14 challenge. 15 16 7. ACCESS TO AND USE OF PROTECTED MATERIAL 17 7.1 Basic Principles. A Receiving Party may use Protected Material that is 18 disclosed or produced by another Party or by a Non-Party in connection with this 19 Action only for prosecuting, defending or attempting to settle this Action. Such 20 Protected Material may be disclosed only to the categories of persons and under the 21 conditions described in this Order. When the Action has been terminated, a 22 Receiving Party must comply with the provisions of Section 13 below (FINAL 23 DISPOSITION). 24 Protected Material must be stored and maintained by a Receiving Party at a 25 location and in a secure manner that ensures that access is limited to the persons 26 authorized under this Order. 27 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 1 Receiving Party may disclose any information or item designated 2 “CONFIDENTIAL” only to: 3 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 4 well as employees of said Outside Counsel of Record to whom it is reasonably 5 necessary to disclose the information for this Action; 6 (b) in the case of Receiving Parties that are Plaintiffs, the officers, 7 directors, and employees (including House Counsel) of the Receiving Party to 8 whom disclosure is reasonably necessary for this Action; 9 (c) in the case of Receiving Parties that are Defendants who receive any 10 information or item from Plaintiffs, the officers, directors, and employees (including 11 House Counsel) of the Receiving Party to whom disclosure is reasonably necessary 12 for this Action; 13 (d) in the case of Receiving Parties that are Defendants who receive any 14 information or item from other Defendants, the House Counsel of the Receiving 15 Party. 16 (e) Experts (as defined in this Order) of the Receiving Party to whom 17 disclosure is reasonably necessary for this Action and who have signed the 18 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 19 (f) the court and its personnel; 20 (g) court reporters and their staff; 21 (h) professional jury or trial consultants, mock jurors, and Professional 22 Vendors to whom disclosure is reasonably necessary for this Action and who have 23 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 24 (i) the author or recipient of a document containing the information or a 25 custodian or other person who otherwise possessed or knew the information; 26 (j) during their depositions, witnesses, and attorneys for witnesses, in the 27 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 1 will not be permitted to keep any confidential information unless they sign the 2 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 3 agreed by the Designating Party or ordered by the court. Pages of transcribed 4 deposition testimony or exhibits to depositions that reveal Protected Material may 5 be separately bound by the court reporter and may not be disclosed to anyone except 6 as permitted under this Stipulated Protective Order; and 7 (k) any mediator or settlement officer, and their supporting personnel, 8 mutually agreed upon by any of the parties engaged in settlement discussions. 9 10 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 11 PRODUCED IN OTHER LITIGATION 12 If a Party is served with a subpoena or a court order issued in other litigation 13 that compels disclosure of any information or items designated in this Action as 14 “CONFIDENTIAL,” that Party must: 15 (a) promptly notify in writing the Designating Party. Such notification 16 shall include a copy of the subpoena or court order; 17 (b) promptly notify in writing the party who caused the subpoena or order 18 to issue in the other litigation that some or all of the material covered by the 19 subpoena or order is subject to this Protective Order. Such notification shall include 20 a copy of this Stipulated Protective Order; and 21 (c) cooperate with respect to all reasonable procedures sought to be 22 pursued by the Designating Party whose Protected Material may be affected. 23 If the Designating Party timely seeks a protective order, the Party served with 24 the subpoena or court order shall not produce any information designated in this 25 action as “CONFIDENTIAL” before a determination by the court from which the 26 subpoena or order issued, unless the Party has obtained the Designating Party’s 27 permission. The Designating Party shall bear the burden and expense of seeking 1 should be construed as authorizing or encouraging a Receiving Party in this Action 2 to disobey a lawful directive from another court. 3 4 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 5 PRODUCED IN THIS LITIGATION 6 (a) The terms of this Order are applicable to information produced by a 7 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 8 produced by Non-Parties in connection with this litigation is protected by the 9 remedies and relief provided by this Order. Nothing in these provisions should be 10 construed as prohibiting a Non-Party from seeking additional protections. 11 (b) In the event that a Party is required, by a valid discovery request, to 12 produce a Non-Party’s confidential information in its possession, and the Party is 13 subject to an agreement with the Non-Party not to produce the Non-Party’s 14 confidential information, then the Party shall: 15 (1) promptly notify in writing the Requesting Party and the Non-Party 16 that some or all of the information requested is subject to a confidentiality 17 agreement with a Non-Party; 18 (2) promptly provide the Non-Party with a copy of the Stipulated 19 Protective Order in this Action, the relevant discovery request(s), and a reasonably 20 specific description of the information requested; and 21 (3) make the information requested available for inspection by the 22 Non-Party, if requested. 23 (c) If the Non-Party fails to seek a protective order from this court within 24 14 days of receiving the notice and accompanying information, the Receiving Party 25 may produce the Non-Party’s confidential information responsive to the discovery 26 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 27 not produce any information in its possession or control that is subject to the 1 Absent a court order to the contrary, the Non-Party shall bear the burden and 2 expense of seeking protection in this court of its Protected Material. 3 4 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 5 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 6 Protected Material to any person or in any circumstance not authorized under this 7 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 8 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 9 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 10 persons to whom unauthorized disclosures were made of all the terms of this Order, 11 and (d) request such person or persons to execute the “Acknowledgment and 12 Agreement to Be Bound” that is attached hereto as Exhibit A. 13 14 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 15 PROTECTED MATERIAL 16 When a Producing Party gives notice to Receiving Parties that certain 17 inadvertently produced material is subject to a claim of privilege or other protection, 18 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 19 Procedure 26(b)(5)(B). This provision is not intended to modify whatever 20 procedure may be established in an e-discovery order that provides for production 21 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and 22 (e), insofar as the parties reach an agreement on the effect of disclosure of a 23 communication or information covered by the attorney-client privilege or work 24 product protection, the parties may incorporate their agreement in the stipulated 25 protective order submitted to the court. 26 27 12. MISCELLANEOUS 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 Local Civil Rule 79-5. Protected Material 9 may 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 12 in the public record unless otherwise instructed by the court. 13 12.4 A Receiving Party who seeks to file Protected Material without seeking 14 to do so under seal shall provide reasonable notice before doing so to the Producing 15 Party, so that the Producing Party has a reasonable opportunity to comply with 16 Local Civil Rule 79-5 in seeking to seal the Protected Material. 17 18 13. FINAL DISPOSITION 19 After the final disposition and termination of this Action, including any 20 appeals, within 60 days of a written request by the Designating Party, each 21 Receiving Party must return all Protected Material to the Producing Party or destroy 22 such material, except as described below. As used in this subdivision, “all Protected 23 Material” includes all copies, abstracts, compilations, summaries, and any other 24 format reproducing or capturing any of the Protected Material. Whether the 25 Protected Material is returned or destroyed, the Receiving Party must submit a 26 written certification to the Producing Party (and, if not the same person or entity, to 27 the Designating Party) by the 60 day deadline that (1) identifies (by category, where 1 that the Receiving Party has not retained any copies, abstracts, compilations, 2 summaries or any other format reproducing or capturing any of the Protected 3 Material. Notwithstanding this provision, Counsel are entitled to retain an archival 4 copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal 5 memoranda, correspondence, deposition and trial exhibits, expert reports, attorney 6 work product, and consultant and expert work product, even if such materials 7 contain Protected Material. Any such archival copies that contain or constitute 8 Protected Material remain subject to this Protective Order as set forth in Section 4 9 (DURATION). If any Party is unable to destroy the information due to the nature of 10 any software or statutory or proprietary record-keeping requirements, the Party 11 retaining all Protected Material must ensure that it is designated confidential and 12 that a copy of this Protective Order is maintained within the information until such 13 time as it may be destroyed or archived. This includes originals and all copies, 14 duplicates, abstracts, or reproductions of all Protected Material. 15 Notwithstanding the foregoing, nothing in the Protective Order prohibits or 16 restricts either Defendant’s maintenance of information and documents in their 17 respective claim systems; documents maintained pursuant to the privacy 18 requirements of the California Department of Insurance and other applicable state 19 and federal laws; the records retention requirements of the California Department of 20 Insurance, and other applicable state and federal laws; or the records retention 21 practices of Defendants. Further, nothing in the Protective Order disallows 22 reporting of information by Defendants as permitted and/or required by applicable 23 state and federal laws. Nothing in this Protective Order shall prohibit, restrict, or 24 require any authorization for either Defendant’s retention, use or disclosure of 25 Protected Material produced by any party as authorized or required by federal or 26 state law or regulation, or court order or rule. 27 1 14. VIOLATION 2 Any violation of this Order may be punished by appropriate measures 3 including, without limitation, contempt proceedings and/or monetary sanctions. 4 March 25, 2026 SHEPPARD, MULLIN, RICHTER & HAMPTON LLP 5 6 By /s/ Patrick R. Emerson 7 SCOTT SVESLOSKY PATRICK R. EMERSON 8 Attorneys for Defendant 9 PRIME INSURANCE COMPANY 10 11 March 25, 2026 LEX OPUS 12 By /s/ Jeremy A. Rhyne 13 MOHAMMED K. GHODS 14 JEREMY A. RHYNE SANDRA J. VIVONIA 15 Attorneys for Plaintiffs 16 STARLINE TOURS OF HOLLYWOOD, INC. 17 and SCREAMLINE INVESTMENT CORPORATION 18 19 March 25, 2026 MUSICK, PEELER & GARRETT LLP 20 21 By /s/ David Tartaglio DAVID A. TARTAGLIO 22 LAURA K. KIM 23 Attorneys for Defendant CAROLINA CASUALTY INSURANCE 24 COMPANY 25 26 27 1 ATTESTATION 2 Pursuant to Local Rule 5-4.3.4(a)(2)(i), I hereby attest that all signatories 3 |) listed above, and on whose behalf this filing is submitted, concur in this filing’s 4 || content and have authorized the filing. 5 Executed this 25th day of March, 2026, at Los Angeles, California. 6 7 SHEPPARD, MULLIN, RICHTER & HAMPTON LLP 8 By /s/ Patrick Emerson 9 PATRICK EMERSON 10 Attorneys for Defendant PRIME INSURANCE COMPANY 12 13 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 14 March 25, 2026 Re □□□ Od. 15 || Dated: . HON. ROZELLA A. OLIVER 16 United States Magistrate Judge 17 18 19 20 21 22 23 24 25 26 27 28 ORADTTT.ANHNL 1909 LAZAR 7 1 EXHIBIT A 2 UNITED STATES DISTRICT COURT 3 CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION 4 STARLINE TOURS OF Case No. 2:25-cv-08245-MCS-RAO HOLLYWOOD, INC., a California 5 corporation; SCREAMLINE INVESTMENT CORPORATION, a ACKNOWLEDGMENT OF 6 California corporation, NONDISCLOSURE UNDER PROTECTIVE ORDER 7 Plaintiffs, 8 v. 9 CAROLINA CASUALTY INSURANCE COMPANY, an Iowa 10 corporation; PRIME INSURANCE COMPANY, INC., an Unknown 11 Business Entity; and DOES 1 TO 50, INCLUSIVE, 12 Defendants. 13 14 I, _________________ (name), acknowledge that I have received and read a 15 copy of the Stipulated Protective Order entered in the action presently pending in 16 the United States District Court for the Central District of California entitled 17 Starline Tours of Hollywood, Inc. & Screamline Investment Corp. v. Carolina 18 Casualty Insurance Co., et al., Case No. 2:25-cv-08245-MCS-RAO. I agree to 19 comply with and be bound by this Stipulated Protective Order, and I hereby submit 20 to the jurisdiction of the United States District Court for the Central District of 21 California with respect to any action arising out of any claim of violation of the 22 Stipulated Protective Order. 23 24 DATED: SIGNATURE: 25 26 27