STIPULATION AND ORDER REGARDING DISCOVERY OF DEFENDANTS' FINANCIAL CONDITION 1

ALLISON CLAIRE, Magistrate Judge.

Plaintiffs' motion for an order permitting discovery of defendant Sunrise Senior Living Management, Inc. and Sunrise of Rocklin's (hereinafter concurrently referred to as Sunrise) financial information is presently set for hearing on March 26, 2014 at 10:00 AM in Department 26 before the Honorable Allison Claire.

Upon the Court's execution of the Order, below, plaintiffs' counsel will take the subject motion off-calendar. To this end, the parties, by and through their respective counsel of record, hereby stipulate and agree to the following:

STIPULATION AND AGREEMENT RE: FINANCIAL DISCOVERY

IT IS HEREBY ORDERED AS FOLLOWS:

1. Sunrise will produce any and all financial statements, balance sheets and/or profit and loss statement from Sunrise Senior Living Management, Inc. and Sunrise of Rocklin for the years 2011 through 2013. Sunrise shall have 30 days from the date this Stipulation is executed by the parties to produce any such responsive documents in its possession, custody or control;

2. Also within 30 days of the date this Stipulation is executed, counsel for Sunrise will identify to counsel for plaintiffs the individual(s) who will serve as Person(s) Most Knowledgeable regarding Sunrise of Rocklin and Sunrise Senior Living Management, Inc.'s 2011through 2013 financial statements, balance statements and profit and loss statements.

3. Plaintiffs agree to postpone taking the deposition(s) of the Person(s) Most Knowledgeable until after they have reviewed and assessed the financial documents provided. However, plaintiffs are not waiving their right to take these depositions. Should plaintiffs still feel these depositions are necessary even after receipt of the financial documents, Sunrise agrees to produce said witnesses for deposition.

4. The parties agree that the PMK depositions may be taken at any time past the discovery cut-off date of April 1, 2014 up to 2 weeks before the deposition(s) / of any experts properly designated by either side to testify regarding the financial condition of defendants in this case.

ORDER RE: DISCOVERY OF DEFENDANTS' FINANCIAL CONDITION

IT IS HEREBY ORDERED AS FOLLOWS:

1. Sunrise shall produce any and all financial statements, balance sheets and/or profit and loss statement from Sunrise Senior Living Management, Inc. and Sunrise of Rocklin for the years 2011 through 2013. Sunrise shall have 30 days from the date this Stipulation is executed by the parties to produce any such responsive documents in its possession, custody or control;

2. Also within 30 days of the date this Stipulation is executed, counsel for Sunrise will identify to counsel for plaintiffs the individual(s) who will serve as Person(s) Most Knowledgeable regarding Sunrise of Rocklin and Sunrise Senior Living Management, Inc.'s 2011 through 2013 financial statements, balance statements and profit and loss statements.

3. While plaintiffs agree to postpone taking the deposition(s) of the Person(s) Most Knowledgeable until after they have reviewed and assessed the financial documents provided, plaintiffs are not waiving their right to take these depositions. Should plaintiffs still feel these depositions are necessary even after receipt of the financial documents, Sunrise is hereby ordered to produce the Person(s) Most Knowledgeable for deposition.

IT IS SO ORDERED.

EXHIBIT A

AGREEMENT CONCERNING INFORMATION COVERED BY CONFIDENTIALITY STIPULATION NO. 2

I have been designated by [PARTY NAME] as a person who may have access to Confidential Information as that term is defined in the Confidentiality Stipulation entered in the above-entitled case.

Having read the Confidentiality Stipulation, I agree to comply fully with it and to be bound by its terms with respect to all Confidential Information as defined therein. I agree not to copy or disclose to any nonqualified person or entity any Confidential Information that has been disclosed to me.

If I violate any terms of that Confidentiality Stipulation No. 1 with respect to the treatment of Confidential Information, I agree to submit myself to the jurisdiction of the Orange County Superior Court for the purpose of enforcement of the terms of the Confidentiality Stipulation No. 1.

I declare under penalty of perjury under the laws of California that the foregoing is true and correct.

Executed this _______ day of ___________________, 2014.