MITCHELL KAMIN (SBN 202788) 1 takamin(@icov .com AARON LEWIS (SBN 284244) 2 [email protected] BRITTANY BENJAMIN (SBN 323968) 3 bbenjamin@cov-com BENJAMIN SEGAL (SBN 330787) 4|| bse [email protected] COVI GTON & BURLING LLP 5 || 1999 Avenue of the Stars Los Angeles, CA 90067-4643 6 || Telephone: eu) 332-4800 Facsimile: (424) 332-4749 7 CASSANDRA STUBBS (SBN 218849) 8 cstubbs(@aclu ore AMERICAN CIVIL LIBERTIES UNION FOUNDATION 9 || 201 W. Main St., Suite 402 Durham, NC 27701 10 || Telephone: Oy 682-5659 Facsimile: (919) 682-5961 1] Attorneys for Plaintiffs _ 12 || [Additional Counsel continued on next page] 13 UNITED STATES DISTRICT COURT 14 CENTRAL DISTRICT OF CALIFORNIA 15 SOUTHERN DIVISION 16 17 MELISSA AHLMAN, DANIEL KAUWE, | Case No. — 8:20-cv-00835-JGB-SHK 18 || MICHAEL SEIF, JAVIER ESPARZA, PEDRO BONILLA, CYNTHIA Assigned to the Honorable Jesus G. Bernal 19 || CAMPBELL, MONIQUE CASTILLO, MARK TRACE, CECIBEL CARIDAD Referred to Magistrate Judge 20 || ORTIZ, and DON WAGNER, on behalf of Shashi H. Kewalramani themselves and all others similarly situated, etal., DISCOVERY MATTER - STIPULATE] 22 Plaintiffs/Petitioners, REVISED STIPULATION AND PROTECTIVE ORDER REGARDING 23 V. PRODUCTION OF CONFIDENTIAL DISCOVERY 24 || DON BARNES, in his official capacity as Sheriff of Orange County, California; and 25 |) ORANGE COUNTY, CALIFORNIA. Action Filed: April 30, 2020 26 Defendants/Respondents. 27 28

1 || [Additional Counsel continued from first page] ° STACEY GRIGSBY JOHN WASHINGTON (SBN 315991) 3 || [email protected] [email protected] 4 AMIA TRIGG (SBN 282890) SCHONBRUN, SEPLOW, HARRIS, [email protected] HOFFMAN & ZELDES LLP MARTA COOK 11543 W. Olympic Blvd. 6 || [email protected] Los Angeles, CA 90064 LAURA BETH COHEN Telephone: (310) 399-7040 7} [email protected] Facsimile: (310) 399-7040 g || COVINGTON & BURLING LLP One CityCenter PETER ELIASBERG (SBN 189110) 850 Tenth Street NW [email protected] 10 Washington, DC 20001 AMERICAN CIVIL LIBERTIES Telephone: (202) 662-6000 FUND OF SOUTHERN Il | Facsimile: (202) 778-5906 CALIFORNIA 1313 W 8th St OLIVIA ENSIGN Los Angeles, CA 90017 13) [email protected] Telephone: (213) 977-9500 CRISTINA BECKER [email protected] PAUL HOFFMAN (SBN 71244) 15 | AMERICAN CIVIL LIBERTIES UNION [email protected] 16 || FOUNDATION UNIVERSITY OF CALIFORNIA, 201 W. Main St., Suite 402 IRVINE SCHOOL OF LAW CIVIL Durham, NC 27701 RIGHTS LITIGATION CLINIC ig || Telephone: (919) 682-5659 401 E. Peltason Dr., Suite 1000 Facsimile: (919) 682-5961 Irvine, CA 92687 19 Telephone: (949) 824-0066 59 || CARL TAKEI (SBN 256229) [email protected] ZOE BRENNAN-KROHN (SBN SOMIL TRIVEDI 324912) 92 || [email protected] [email protected] CLARA SPERA AMERICAN CIVIL LIBERTIES 23 [email protected] UNION FOUNDATION 24 || AMERICAN CIVIL LIBERTIES UNION Disability Rights Program FOUNDATION 39 Drumm Street 2) | 125 Broad Street, 18th Floor San Francisco, CA 94111 26 || New York, NY 10004 Telephone: (415) 343-0769 Telephone: (212) 607-3300 Facsimile: (415) 255-1478 Facsimile: (212) 607-3318 28 OL

1] ATTORNEYS FOR PLAINTIFFS 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 _2L

1 [PROPOSED PROTECTIVE ORDER] 2 On or about October 2, 2020, Plaintiffs in the current case captioned as Ahlman v. 3 || Barnes, et al. Case No. 8:20-cv-835-JGB-SHK, by and through their counsel of record, 4|| and Plaintiffs in the parallel state action Castillo et al. v. Barnes, Case No. 30-2020- 5 || 01141117-CU-WM-CXC (Super. Ct. Calif.), (“all Plaintiffs”) by and through their 6 || counsel of record, and Defendants, Don Barnes, Sheriff of Orange County and the 7 || County of Orange, by and through their counsel of record, (“the parties”) stipulated to a 8 || protective order regarding confidential information produced pursuant to the Court’s June 9 || 26, 2020 Order granting expedited discovery (ECE No. 93) and seek to have a protective 10 || order entered by the Court based on that stipulation. The stipulation has been filed with 11 || the Court. Based on that Stipulation, the following Protective Order shall apply to all 12 || Discovery in this action: 13 l. Attorneys for all Plaintiffs shall secure and maintain the Discovery until the 14 || end of this litigation and any associated appeal. 15 2. Attorneys for all Plaintiffs shall agree that the Discovery shall be used only 16 || for the purposes set forth below and for no other purpose. 17 3. The Discovery shall be used solely in connection with Ah/man v. Barnes, et 18 || al. Case No. 8:20-cv-835-JGB-SHK and the parallel state action Castillo et al. v. Barnes, 19 || Case No. 30-2020-01141117-CU-WM-CXC (Super. Ct. Calif.) and any associated 20 || appellate proceedings and collateral review, and not for any other purpose except as 21 || specified in this Stipulation. The same stipulation for protective order and protective 22 || order will be filed in the parallel state case. 23 4. If necessary, in the judgment of Plaintiffs’ counsel, they may show or reveal 24 || the contents of the Discovery to certain individuals as set forth in paragraph 4 of the 25 || Stipulation. 26 5. Duration: Once a case proceeds to trial all of the information that is 27 || designated as confidential or maintained pursuant to this Protective Order becomes public 28 || unless compelling reasons supported by specific factual findings to proceed otherwise are AL

made to the trial judge in advance of the trial. Kamakana v. City and County of Honolulu (9th Cir. 2006)

, 1180-1181 (distinguishing “good cause” showing for ° sealing documents produced in discovery from “compelling reasons” standard when merits-related documents are part of court record). Accordingly, the terms of this protective order do not extend beyond the commencement of the trial. ° 6. Final Disposition: After the final disposition of this Action, Plaintiffs’ ° counsel shall return all Discovery to counsel for the Defendants or shall destroy such material, including all copies and extracts thereof, abstracts, compilations, summaries, and any other format reproducing or capturing any of the Discovery with the exception of ° those documents affected by the attorney work-product doctrine or attorney-client privilege. Notwithstanding this provision, Counsel are entitled to retain an archival copy of all pleadings, motion papers, trial, deposition and trial exhibits, expert reports, attorney work product, and consultant and expert work product, even if such materials contain Discovery produced subject to this Order. Any such archival copies that contain or " constitute Discovery remain subject to this Protective Order. To the extent any » Confidential Records remain in the possession of the Attorneys for Plaintiffs and they are not destroyed, Attorneys for the Plaintiffs shall keep such Records in their confidential case files. 7. Attorneys for all Plaintiffs shall cause the substance of this Order to be communicated to each person to whom the Discovery are revealed in accordance with this ° Order and prior to disclosure of the Discovery, have such person execute a written Understanding and Agreement to be bound by this Stipulation for Protective Order in the form attached hereto as Exhibit 1. 8. The attorneys for all Plaintiffs shall not cause or knowingly permit disclosure of the content of the Discovery beyond the disclosure permitted under the terms and conditions of this Order, including but not limited to any news media which is inclusive of film or video, television, radio or print.

28 5.

1 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. MW yee Dated: October 5 , 2020 Honorable Shashi H. Kewalramani 4 United States District Court 5 Central District of California 6 7 8 9 10 1] 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 _6_

EXHIBIT 1 ] UNDERSTANDING AND AGREEMENT PURSUANT TO PROTECTIVE 2 ORDER 3 I declare under penalty of perjury under the laws of the United Stated of America 4 that I have read in its entirety and understand the Stipulation and Protective Order that 5 was issued by the United Stated District Court for the Central District of California in the 6 case of AHLMAN v. BARNES, Case No. 8:20-cv-00835-JGB-SHK, now pending in the 7 District Court. I understand the Stipulation and Protective Order and agree to comply 8 with and be bound by all the terms of the Stipulation and Protective Order. I solemnly 9 promise that I will not disclose in any manner any information or items that is subject to 10 the Stipulation and Protective Order to any person or entity except in strict compliance 11 with the provisions of the Stipulation and Protective Order. 12 13 DATE: BY: SIGNATURE 15 16 _,__ PRINT NAME 17 18 ADDRESS 19 20 TNTS7)Y?SN[TT_WJT CITY, STATE, ZIP 21 22 23 24 25 26 27 28 _7_