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MOMMA
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
Document Scanning Lead Sheet
Nov-24-2009 10:19 am
Case Number: CGC-08-482411
Filing Date: Nov-24-2009 10:19
Juke Box: 001 Image: 02684984
ORDER
MARSHA LEVINSON et al VS. FIRE INSURANCE EXCHANGE, A CORPORATION et é
001002684984
Instructions:
Please place this sheet on top of the document to be scanned.oOo OC 6B HM DOD HH BW LB
2a Aw FO 8 FF Fe RARER HS
Lee J. Danforth, Esq. - SBN 73695
Richard S. Baum, Esq. - SBN 178760
CODDINGTON, HICKS & DANFORTH
A Professional Corporation, Lawyers ‘eS
555 Twin Dolphin Drive, Suite 300 ¥F
Redwood City, California 94065-2133 ofan ee Homie
Tel. (630) 592-5400 mens aoe
Fax.(650) 592-5027 NO¥ 24 200g
ATTORNEYS FOR Defendant . ae
FIRE INSURANCE EXCHANGE bn PARKGLI, Clerk
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN FRANCISCO
MARSHA LEVINSON AND LEON No. CGC-08-482411
TAYLOR,
Plaintiffs, STIPULATED PROTECTIVE ORDER
vs.
FIRE INSURANCE EXCHANGE, A
CORPORATION, JEFFREY LEE,
INDIVIDUALLY AND DOING BUSINESS BY F, ‘AX
AS JEFFREY LEE INSURANCE AGENCY,
DAVID BARDIN, CHANGWIN BARDIN .
AND DOES | THROUGH 60, INCLUSIVE,
Defendants.
It is stipulated by the parties, through their respective counsel of record, that the Court may
enter the following Protective Order.
IT IS ORDERED that:
1. Certain of the documents and information that has been and/or will be produced by
plaintiffs MASHA LEVINSON and LEON TAYLOR and defendants FIRE INSURANCE
EXCHANGE, JEFFREY LEE, INDIVIDUALLY AND DOING BUSINESS AS JEFFREY LEE
INSURANCE AGENCY (hereafter collectively the “parties” or individually a “party”) pursuant to
this Stipulation and Protective Order (“Order”) are claimed by that producing party to be
confidential or proprietary in nature and may have been previously designated as confidential or
Stipulated Protective Order,
Case Number: CGC-08-482411So ee ADH FW WY
28
CODDINGTON, HICKS
&DANFORTA
‘A Profesional Corp, Lawyers
{$85 Twin Dolphin Drive, #200
Redwood Ciiy, CA 94065
(650) $92.5400
oo
l ~~ a
proprietary by those party. The purpose of this Order is to protect the confidentiality of such
information and documents.
2. All documents and information produced in this case and designated by any party as
"confidential" shall be protected from disclosure in accordance with the following terms and
conditions: ,
a. Any party may, in good faith, designate documents or information which it produces
in response to discovery as “confidential” including, but not limited to:
i. all documents and/or information that such party believes to constitute or
disclose trade secrets or other confidential research, development, testing, or commercial
information ,or other information protected by that party's rights of privacy, such as financial and
other information regarding a party's financial condition, assets or property, that it is entitled to keep
in confidence;
ii. business marketing, testing, research, or strategic plans relating to any
materials, products, goods, and/or services;
iii. discovery material reflecting or relating to research, testing or financial data;
and/or
iv. all documents and/or information containing or referring to internal evaluations
or criticisms , of any of Fire Insurance Exchange's products, goods, services, practices and/or
procedures.
3. All documents and information produced by any party in this case and designated
“confidential” shall be used solely for the purpose of "this action” and shall not be made available
to persons other than "qualified persons” as defined in Paragraph 4. “This action” specifically refers
to the pretrial proceedings and trial of Marsha Levinson and Leon Taylor vs. Fire Insurance
Exchange, et al., San Francisco County Superior Court, Case No. CGC-08-482411, and all related
actions and cross-actions, including but not limited to Marsha Levinson and Leon Taylor vs. Fire
Insurance Exchange, et al.
4. “Qualified Persons" means:
a. a party to this action, an officer, director, employee or partner or a party or in-house
2
‘Stipulated Protective Order:
Case Number: CGC- 8480411-
Co oO FSI OH FF WwW WY
28
CODDINGTON, HICKS
DANFORTH
A
cofessioaal Corp., Lawyers
‘585 Twin Dolphin Drive, #200
Resiwod City, CA 94065,
(650) 592.5400
(> ~
counsel having direct responsibility for, working directly on, or testifying in connection with this
action who has executed a declaration in the form attached hereto as Exhibit A; and/or
b. counsel of record, and insurance carrier representative(s) for the parties and the legal
assistants and regularly employed office staff of the counsel of record for the parties; and/or
c a person retained by a party or its attorneys of record to assist in this action, such as
independent accountants, expert witnesses, statisticians, economists, consultants, investigators, or
other technical experts and/or consultants, who have signed acknowledgment in the form of Exhibit
A hereto, which signed acknowledgment shall be retained by such party or its attorneys who has
executed a declaration in the form attached hereto as Exhibit A; and/or
d. court officials involved in these actions, including the court and its staff, court
reporters, persons operating video equipment at depositions, and any Special Master appointed by
the Court; and/or
e actual or potential deposition witnesses in this action who are assisting counsel in the
prosecution or defense of this action or whom counsel must advise concerning the status of this
action who have executed a declaration in the form attached as Exhibit A.
5. Unless prior written consent for further disclosure has been obtained from counsel for
the party designating the information or documents as “confidential"or permission for such
disclosure has been given by the Court, each qualified person identified in Paragraph 4 (a), (c), and
{e) above, as well as counsel for third party witnesses, to whom delivery, exhibition or disclosure
of any material designated as confidential is made, shall be provided with a copy of this Order, and
shall execute a declaration in the form attached hereto as Exhibit A.
6. "Confidential" documents and other discovery materials shall include all originals and
copies of any document and/or information that any party has designated as such by stamping the
document and/or information, or the cover or other page with the word "CONFIDENTIAL" or in
any other reasonable manner appropriate to the form in which the confidential information is made
available to the qualified persons as defined in Paragraph 4. In lieu of stamping the originals of
documents, the producing party may stamp copies that are produced or exchanged, or indicate in
some appropriate fashion that the documents and/or information is confidential under this Order.
3
Stipulated Protective Order,
Case Number: CGC-08-482411So © QD DH FB Bw Ye
RPP PN NN NY eB Be ew me we Be RL
TA MVM FY NF Se we RADAR GD HTS
28
covpiGros, Hicks
& DANFORTH
A Profexional Corp, Lawyers
‘585 Twin Dolphin Drive, #300
Reéwcod Cry, CA 94065
(650) 592-5€00
>
Notwithstanding the foregoing, documents or other information produced and not so designated
through mistake, inadvertence, or for any other reasons shall likewise be deemed confidential.
7. In the event that a "qualified person" ceases to engage in the preparation for trial or
trial of this proceeding, access by such person to confidential documents and other information of
any party shall be terminated. However, the provision of this Order shall remain in full force and
effect as to all persons who have obtained access to such documents or other discovery materials of
any party designated for protection hereunder in perpetuity.
8. Counsel for the parties shall maintain a list of the names of all persons, including all
disclosed experts, who inspect, view and/or receive any copies of such confidential documents or
information and shal] make such a list available to counsel for the party producing any such
confidential documents or information at the conclusion of this litigation. Counsel shall maintain
a second list of any confidential consultants who are subject to this stipulation, whose identity may
be disclosed only on a showing of good cause by counsel for the party producing such confidential
documents or information, as it relates to attomey work product.
9. Nothing contained herein shall prevent disclosure beyond the terms of this Order if
the party producing such confidential information or documents consents in writing to such
disclosure; or if the court, sua sponte or after motion by any party and notice to all affected persons,
allows such disclosure; of if the party to whom confidential information has been produced
thereafter becomes obligated to disclose the information in response to a lawful subpoena,
PROVIDED THAT the subpoenaed party gives prompt written notice to counsel for the party
producing such confidential documents or information and permits counsel for that producing party
sufficient time to intervene and seek appropriate relief in the action in which the subpoena was
issued.
10. If any party submits and/or files with the Court any document or other discovery
information designated confidential, it shall be filed and submitted under the seal and shall be
maintained under the seal by the Court. No party shall file with the Court any motion, brief or other
Paper containing or otherwise exhibiting any confidential information designated by any party for
protection hereunder unless said motion, brief or other papers are filed in sealed envelopes or other
4
Stipulated Protective Or
Case Number: CGC-08- Seatoe HY BA WH BR ww Ww
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——
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Roe
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28
‘CODDINGTON, HICKS
4 DANFORTH
‘AProfessiousl Corps Lawyers
~
appropriate sealed container on which shall be the words "CONFIDENTIAL — SUBJECT TO
PROTECTIVE ORDER" and a statement in substantially the following form:
This envelope contains “confidential” documents and/or information that
has been produced in this case, and which is subject to a Stipulated
Protective Order. It is not to be opened or the contents thereof to be
displayed or revealed except to the Court and its authorized personnel.
11. Within sixty days after the final judgment in or settlement of this action, each party
shall assemble all originals and/or reproductions of any "confidential" documents or other discovery
information produced by any party(excluding any documents that have been filed with the Court),
which shall, upon request by the party producing such confidential information or documents be
returned to counsel for that producing party. Insofar as the provisions of this or any other discovery
materials produced hereunder, such Orders shail continuc to be binding after the conclusion of this
case.
12. Nothing in this Order, nor any action taken in compliance with it, shail:
a. operate as an admission by any party that any particular document, or discovery
material, deposition transcript, or discovery response is or is not confidential; or
b. prejudice in any way the right of any party to seek a determination by the Court
whether particular documents or other information should or should not be disclosed or, if disclosed
whether it should remain subject to the terms of this Order.
Any party may ask the Court to modify or otherwise grant relief from any provision of this
Order.
13. Nothing in this Order shall be deemed to impair any party's right to object to the
production of documents or information on any ground, including, but not limited to, an objection
that the documents or information sought are privileged or otherwise protected from disclosure or
to demand more stringent restrictions for the treatment or disclosure of any documents or discovery
information on any ground.
14. Nothing in this Order shall bar or otherwise restrict any attorney herein from
rendering advice to his client with respect to this case or doing anything necessary to prosecute or
defend this case and furthering the interest of his client or clients; however, the attorney shall not
Stipulated Protective Order,
Case Number: CGC-08-482411EEE ESSIEN SID BRB GI DEI LL CHD LAWYERS Booz
10/27/2009 16:01 FAX 850 592 3027 cD LAWYERS : ~ Taeorsooe
Seats
eure
‘disclose any ixcformation: and/or materials designated for proteotion hereunder (or information
darived therefrom) where such disclosures would ba contrary to the terms of this Order.
15. The parties and theirattomeys, and any "qualified persons" who received confidential
documents or information subject to this Order, who intentionally, knowingly, or otherwise violate
the terms of this Order shall be liable to the party producing such confidential documents or
information for all damages arising therefrom and the producing party may pursue any and all civil
remedies available to it for breach of the terms of this Order. :
“16. This Order may be modified by stipulation among ell parties approved by the Court,
or by application by noticed motion.
17. Nothing in this Order shall be construed as a waiver of any sights by any party with
respect to matters not specifically provided for herein, This Onder shalt be applicable to documenta
and discovery materials produced.
Dated: Ocroter 2 #2009 -- CODDINOTON, HICKS & DANFORTH
Br Richard 5. B: Esg.
Attorneys
Fire Exchange
end: nak” 4, 2009
Dated; October Z4_, 2009
Se Rane Seek Bsa-
So Oo Om IWR OH BR HN
28
CODDINGTON, HICKS.
& DANFORT!
Redwood City, CA. 94085
(650) 592-5400,
IT IS SO ORDERED.
DATED: Lb 3/p
ORDER
Stipulated Protective Order;
Case Number: CGC-08-482411|
1 EXWIBIT A
I, declare:
1, lam i [description of qualified person as defined by
2
3
4 || Paragraph 4 of the Stipulated Protective Order] for [name of
5] party] in the pending court action of MARSHA LEVINSON and LEON TAYLOR vs. FIRE
6 | INSURANCE EXCHANGE, JEFFREY LEE, INDIVIDUALLY AND DOING BUSINESS AS
7
8
9
0
JEFFREY LEE INSURANCE AGENCY and DAVID BARDIN, CHANGWIN. BARDIN, San Francisco
County Superior Court, Case No. CGC-08-482411. }
2. Prior to viewing or receiving document and information designated as confidential
in the above-captioned action, I was provided with a copy of the Protective Order which I have read
i] || and fully understand. I agree to be bound by the terms of the Protective Order, and I consent to the
12} exercise of and submit to the personal and continuing jurisdiction of the above-named Court
13 | concerning the enforcement of the Order.
14 3. ] viewed or received the confidential information in my capacity as an attorney, legal
15 || assistant, secretary, independent accountant, party, expert witness, statistician, economist, consultant
16}) investigator, or other technical expert and/or consultant.
74 4. T received access to this confidential information from :
18} attorney of record for [name of party} on or about
19 {date].
20 5. The confidential information I reviewed or received was limited to the documents
21 || with the following document identification Nos.:
22} I certify (or declare) under penalty of perjury under the laws of the State of California that
23 || the foregoing is true and correct and that this declaration was executed on day of
24 5200.
25 :
Print Name —
26
27
Sign Name
28 :
CODDINGTON, HICKS 8
& DANFORTH Stipulated Protective Order;
SsTwabdps binges || Case Number: CGC-08-48241 |
Preview
MOMMA SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO Document Scanning Lead Sheet Nov-24-2009 10:19 am Case Number: CGC-08-482411 Filing Date: Nov-24-2009 10:19 Juke Box: 001 Image: 02684984 ORDER MARSHA LEVINSON et al VS. FIRE INSURANCE EXCHANGE, A CORPORATION et é 001002684984 Instructions: Please place this sheet on top of the document to be scanned.oOo OC 6B HM DOD HH BW LB 2a Aw FO 8 FF Fe RARER HS Lee J. Danforth, Esq. - SBN 73695 Richard S. Baum, Esq. - SBN 178760 CODDINGTON, HICKS & DANFORTH A Professional Corporation, Lawyers ‘eS 555 Twin Dolphin Drive, Suite 300 ¥F Redwood City, California 94065-2133 ofan ee Homie Tel. (630) 592-5400 mens aoe Fax.(650) 592-5027 NO¥ 24 200g ATTORNEYS FOR Defendant . ae FIRE INSURANCE EXCHANGE bn PARKGLI, Clerk IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN FRANCISCO MARSHA LEVINSON AND LEON No. CGC-08-482411 TAYLOR, Plaintiffs, STIPULATED PROTECTIVE ORDER vs. FIRE INSURANCE EXCHANGE, A CORPORATION, JEFFREY LEE, INDIVIDUALLY AND DOING BUSINESS BY F, ‘AX AS JEFFREY LEE INSURANCE AGENCY, DAVID BARDIN, CHANGWIN BARDIN . AND DOES | THROUGH 60, INCLUSIVE, Defendants. It is stipulated by the parties, through their respective counsel of record, that the Court may enter the following Protective Order. IT IS ORDERED that: 1. Certain of the documents and information that has been and/or will be produced by plaintiffs MASHA LEVINSON and LEON TAYLOR and defendants FIRE INSURANCE EXCHANGE, JEFFREY LEE, INDIVIDUALLY AND DOING BUSINESS AS JEFFREY LEE INSURANCE AGENCY (hereafter collectively the “parties” or individually a “party”) pursuant to this Stipulation and Protective Order (“Order”) are claimed by that producing party to be confidential or proprietary in nature and may have been previously designated as confidential or Stipulated Protective Order, Case Number: CGC-08-482411So ee ADH FW WY 28 CODDINGTON, HICKS &DANFORTA ‘A Profesional Corp, Lawyers {$85 Twin Dolphin Drive, #200 Redwood Ciiy, CA 94065 (650) $92.5400 oo l ~~ a proprietary by those party. The purpose of this Order is to protect the confidentiality of such information and documents. 2. All documents and information produced in this case and designated by any party as "confidential" shall be protected from disclosure in accordance with the following terms and conditions: , a. Any party may, in good faith, designate documents or information which it produces in response to discovery as “confidential” including, but not limited to: i. all documents and/or information that such party believes to constitute or disclose trade secrets or other confidential research, development, testing, or commercial information ,or other information protected by that party's rights of privacy, such as financial and other information regarding a party's financial condition, assets or property, that it is entitled to keep in confidence; ii. business marketing, testing, research, or strategic plans relating to any materials, products, goods, and/or services; iii. discovery material reflecting or relating to research, testing or financial data; and/or iv. all documents and/or information containing or referring to internal evaluations or criticisms , of any of Fire Insurance Exchange's products, goods, services, practices and/or procedures. 3. All documents and information produced by any party in this case and designated “confidential” shall be used solely for the purpose of "this action” and shall not be made available to persons other than "qualified persons” as defined in Paragraph 4. “This action” specifically refers to the pretrial proceedings and trial of Marsha Levinson and Leon Taylor vs. Fire Insurance Exchange, et al., San Francisco County Superior Court, Case No. CGC-08-482411, and all related actions and cross-actions, including but not limited to Marsha Levinson and Leon Taylor vs. Fire Insurance Exchange, et al. 4. “Qualified Persons" means: a. a party to this action, an officer, director, employee or partner or a party or in-house 2 ‘Stipulated Protective Order: Case Number: CGC- 8480411- Co oO FSI OH FF WwW WY 28 CODDINGTON, HICKS DANFORTH A cofessioaal Corp., Lawyers ‘585 Twin Dolphin Drive, #200 Resiwod City, CA 94065, (650) 592.5400 (> ~ counsel having direct responsibility for, working directly on, or testifying in connection with this action who has executed a declaration in the form attached hereto as Exhibit A; and/or b. counsel of record, and insurance carrier representative(s) for the parties and the legal assistants and regularly employed office staff of the counsel of record for the parties; and/or c a person retained by a party or its attorneys of record to assist in this action, such as independent accountants, expert witnesses, statisticians, economists, consultants, investigators, or other technical experts and/or consultants, who have signed acknowledgment in the form of Exhibit A hereto, which signed acknowledgment shall be retained by such party or its attorneys who has executed a declaration in the form attached hereto as Exhibit A; and/or d. court officials involved in these actions, including the court and its staff, court reporters, persons operating video equipment at depositions, and any Special Master appointed by the Court; and/or e actual or potential deposition witnesses in this action who are assisting counsel in the prosecution or defense of this action or whom counsel must advise concerning the status of this action who have executed a declaration in the form attached as Exhibit A. 5. Unless prior written consent for further disclosure has been obtained from counsel for the party designating the information or documents as “confidential"or permission for such disclosure has been given by the Court, each qualified person identified in Paragraph 4 (a), (c), and {e) above, as well as counsel for third party witnesses, to whom delivery, exhibition or disclosure of any material designated as confidential is made, shall be provided with a copy of this Order, and shall execute a declaration in the form attached hereto as Exhibit A. 6. "Confidential" documents and other discovery materials shall include all originals and copies of any document and/or information that any party has designated as such by stamping the document and/or information, or the cover or other page with the word "CONFIDENTIAL" or in any other reasonable manner appropriate to the form in which the confidential information is made available to the qualified persons as defined in Paragraph 4. In lieu of stamping the originals of documents, the producing party may stamp copies that are produced or exchanged, or indicate in some appropriate fashion that the documents and/or information is confidential under this Order. 3 Stipulated Protective Order, Case Number: CGC-08-482411So © QD DH FB Bw Ye RPP PN NN NY eB Be ew me we Be RL TA MVM FY NF Se we RADAR GD HTS 28 covpiGros, Hicks & DANFORTH A Profexional Corp, Lawyers ‘585 Twin Dolphin Drive, #300 Reéwcod Cry, CA 94065 (650) 592-5€00 > Notwithstanding the foregoing, documents or other information produced and not so designated through mistake, inadvertence, or for any other reasons shall likewise be deemed confidential. 7. In the event that a "qualified person" ceases to engage in the preparation for trial or trial of this proceeding, access by such person to confidential documents and other information of any party shall be terminated. However, the provision of this Order shall remain in full force and effect as to all persons who have obtained access to such documents or other discovery materials of any party designated for protection hereunder in perpetuity. 8. Counsel for the parties shall maintain a list of the names of all persons, including all disclosed experts, who inspect, view and/or receive any copies of such confidential documents or information and shal] make such a list available to counsel for the party producing any such confidential documents or information at the conclusion of this litigation. Counsel shall maintain a second list of any confidential consultants who are subject to this stipulation, whose identity may be disclosed only on a showing of good cause by counsel for the party producing such confidential documents or information, as it relates to attomey work product. 9. Nothing contained herein shall prevent disclosure beyond the terms of this Order if the party producing such confidential information or documents consents in writing to such disclosure; or if the court, sua sponte or after motion by any party and notice to all affected persons, allows such disclosure; of if the party to whom confidential information has been produced thereafter becomes obligated to disclose the information in response to a lawful subpoena, PROVIDED THAT the subpoenaed party gives prompt written notice to counsel for the party producing such confidential documents or information and permits counsel for that producing party sufficient time to intervene and seek appropriate relief in the action in which the subpoena was issued. 10. If any party submits and/or files with the Court any document or other discovery information designated confidential, it shall be filed and submitted under the seal and shall be maintained under the seal by the Court. No party shall file with the Court any motion, brief or other Paper containing or otherwise exhibiting any confidential information designated by any party for protection hereunder unless said motion, brief or other papers are filed in sealed envelopes or other 4 Stipulated Protective Or Case Number: CGC-08- Seatoe HY BA WH BR ww Ww S —— oe Roe ne w oe ne ae Ve Fe Ee em CD Mw I DH bN NN N nn fF WwW HH = nN a 28 ‘CODDINGTON, HICKS 4 DANFORTH ‘AProfessiousl Corps Lawyers ~ appropriate sealed container on which shall be the words "CONFIDENTIAL — SUBJECT TO PROTECTIVE ORDER" and a statement in substantially the following form: This envelope contains “confidential” documents and/or information that has been produced in this case, and which is subject to a Stipulated Protective Order. It is not to be opened or the contents thereof to be displayed or revealed except to the Court and its authorized personnel. 11. Within sixty days after the final judgment in or settlement of this action, each party shall assemble all originals and/or reproductions of any "confidential" documents or other discovery information produced by any party(excluding any documents that have been filed with the Court), which shall, upon request by the party producing such confidential information or documents be returned to counsel for that producing party. Insofar as the provisions of this or any other discovery materials produced hereunder, such Orders shail continuc to be binding after the conclusion of this case. 12. Nothing in this Order, nor any action taken in compliance with it, shail: a. operate as an admission by any party that any particular document, or discovery material, deposition transcript, or discovery response is or is not confidential; or b. prejudice in any way the right of any party to seek a determination by the Court whether particular documents or other information should or should not be disclosed or, if disclosed whether it should remain subject to the terms of this Order. Any party may ask the Court to modify or otherwise grant relief from any provision of this Order. 13. Nothing in this Order shall be deemed to impair any party's right to object to the production of documents or information on any ground, including, but not limited to, an objection that the documents or information sought are privileged or otherwise protected from disclosure or to demand more stringent restrictions for the treatment or disclosure of any documents or discovery information on any ground. 14. Nothing in this Order shall bar or otherwise restrict any attorney herein from rendering advice to his client with respect to this case or doing anything necessary to prosecute or defend this case and furthering the interest of his client or clients; however, the attorney shall not Stipulated Protective Order, Case Number: CGC-08-482411EEE ESSIEN SID BRB GI DEI LL CHD LAWYERS Booz 10/27/2009 16:01 FAX 850 592 3027 cD LAWYERS : ~ Taeorsooe Seats eure ‘disclose any ixcformation: and/or materials designated for proteotion hereunder (or information darived therefrom) where such disclosures would ba contrary to the terms of this Order. 15. The parties and theirattomeys, and any "qualified persons" who received confidential documents or information subject to this Order, who intentionally, knowingly, or otherwise violate the terms of this Order shall be liable to the party producing such confidential documents or information for all damages arising therefrom and the producing party may pursue any and all civil remedies available to it for breach of the terms of this Order. : “16. This Order may be modified by stipulation among ell parties approved by the Court, or by application by noticed motion. 17. Nothing in this Order shall be construed as a waiver of any sights by any party with respect to matters not specifically provided for herein, This Onder shalt be applicable to documenta and discovery materials produced. Dated: Ocroter 2 #2009 -- CODDINOTON, HICKS & DANFORTH Br Richard 5. B: Esg. Attorneys Fire Exchange end: nak” 4, 2009 Dated; October Z4_, 2009 Se Rane Seek Bsa- So Oo Om IWR OH BR HN 28 CODDINGTON, HICKS. & DANFORT! Redwood City, CA. 94085 (650) 592-5400, IT IS SO ORDERED. DATED: Lb 3/p ORDER Stipulated Protective Order; Case Number: CGC-08-482411| 1 EXWIBIT A I, declare: 1, lam i [description of qualified person as defined by 2 3 4 || Paragraph 4 of the Stipulated Protective Order] for [name of 5] party] in the pending court action of MARSHA LEVINSON and LEON TAYLOR vs. FIRE 6 | INSURANCE EXCHANGE, JEFFREY LEE, INDIVIDUALLY AND DOING BUSINESS AS 7 8 9 0 JEFFREY LEE INSURANCE AGENCY and DAVID BARDIN, CHANGWIN. BARDIN, San Francisco County Superior Court, Case No. CGC-08-482411. } 2. Prior to viewing or receiving document and information designated as confidential in the above-captioned action, I was provided with a copy of the Protective Order which I have read i] || and fully understand. I agree to be bound by the terms of the Protective Order, and I consent to the 12} exercise of and submit to the personal and continuing jurisdiction of the above-named Court 13 | concerning the enforcement of the Order. 14 3. ] viewed or received the confidential information in my capacity as an attorney, legal 15 || assistant, secretary, independent accountant, party, expert witness, statistician, economist, consultant 16}) investigator, or other technical expert and/or consultant. 74 4. T received access to this confidential information from : 18} attorney of record for [name of party} on or about 19 {date]. 20 5. The confidential information I reviewed or received was limited to the documents 21 || with the following document identification Nos.: 22} I certify (or declare) under penalty of perjury under the laws of the State of California that 23 || the foregoing is true and correct and that this declaration was executed on day of 24 5200. 25 : Print Name — 26 27 Sign Name 28 : CODDINGTON, HICKS 8 & DANFORTH Stipulated Protective Order; SsTwabdps binges || Case Number: CGC-08-48241 |