Randy H. McMurray, Esq. (SBN 126888) 2 || [email protected] Yana G. Henriks, Esq. (SBN 250638) [email protected] 4 || Lauren I. Freidenberg, Esq. (SBN 312428) [email protected] > || McMURRAY HENRIKS, LLP 6 ||811 Wilshire Blvd., Suite 1640 Los Angeles, California 90017 7 |! Telephone: (323) 931-6200 g || Facsimile: (323) 931-9521 Attorneys for Plaintiffs Tavin Padilla and Edith Padilla

UNITED STATES DISTRICT COURT g 12 CENTRAL DISTRICT OF CALIFORNIA

x 14 | TAVIN PADILLA, an individual; and Case No.: 21-CV-03842-GW-MRW 15 || EDITH PADILLA, an individual, STIPULATED PROTECTIVE 4 Plaintiffs , ORDER 17 18 Vv. (MRW VERSION 4/19) 19 Check if submitted without material 20 || CITY OF LOS ANGELES, a California} ™0difications to MRW form 5 municipal entity; ERIC HERRERA, an individual: MARCOS RAMIREZ, an 22 || individual: and DOES 1- 100, inclusive, 23 24 Defendants. 25 26 27 28 STIPULATED PROTECTIVE ORDER —i—“‘(‘iwsws~s~s~—~S

1|/1. INTRODUCTION 2 1.1 PURPOSES AND LIMITATIONS 3 Discovery in this action is likely to involve production of confidential, 4 || proprietary, or private information for which special protection from public > || disclosure and from use for any purpose other than prosecuting this litigation may © Il be warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter the following Stipulated Protective Order. The parties acknowledge that this Order does not confer blanket protections on all disclosures or responses to ° discovery and that the protection it affords from public disclosure and use extends only to the limited information or items that are entitled to confidential treatment

under the applicable legal principles. The parties further acknowledge, as set forth : a in Section 12.3, below, that this Stipulated Protective Order does not entitle them to file confidential information under seal; Civil Local Rule 79-5 sets forth the 5 15 || Procedures that must be followed and the standards that will be applied when a party 5 16 || Seeks permission from the court to file material under seal. oy 1.2 GOOD CAUSE STATEMENT = 18 This action is likely to involve confidential and private information for which ° 19 || Special protection from public disclosure and from use for any purpose other than 30 || prosecution of this action is warranted. Such information may implicate the privacy 31 ||imterests of the parties and are properly protected through a Fed. R. Civ. P. 26(c) 39 || protective order. See Seattle Times Co. v. Rhinehart,

, 35 n.21 (1984) 93 ||(“Rule 26(c) includes among its express purposes the protection of a ‘party or |}person from annoyance, embarrassment, oppression or undue burden or expense.’ 5 || Although the Rule contains no specific reference to privacy or to other rights or 26 || mterests that may be implicated, such matters are implicit in the broad purpose and 97 || language of the Rule.”); Soto v. City of Concord,

(N.D. Cal. 9g || 1995) (a party’s privacy rights are to be protected through a “carefully crafted

Or STIPULATED PROTECTIVE ORDER

1 || protective order.”). 2 Such confidential materials and information consist of, among other things, 3 ||Los Angeles Police Department investigations, Plaintiffs’ medical records, 4 ||information implicating privacy rights of third parties, and information otherwise 5 || generally unavailable to the public, or which may be privileged or otherwise 6 || protected from disclosure under state or federal statutes, court rules, case decisions, 7 |jor common law. Accordingly, to expedite the flow of information, to facilitate the 8 ||/prompt resolution of disputes over confidentiality of discovery materials, to 9 || adequately protect information the parties are entitled to keep confidential, to ensure 10 ||that the parties are permitted reasonable necessary uses of such material in 11 || preparation for and in the conduct of trial, to address their handling at the end of the 12 || litigation, and serve the ends of justice, a protective order for such information is =, 13 ||justified in this matter. It is the intent of the parties that information will not be 14 || designated as confidential for tactical reasons and that nothing be so designated 15 || without a good faith belief that it has been maintained in a confidential, non-public g 16 ||manner, and there is good cause why it should not be part of the public record of & 17 || this case. = 18 19 ||2. DEFINITIONS 20 2.1 Action: This pending federal law suit, Case No. 21-CV-03842-GW- 21 |}MRW. 22 2.2. Challenging Party: a Party or Non-Party that challenges the 23 || designation of information or items under this Order. 24 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 25 ||how it is generated, stored or maintained) or tangible things that qualify for 26 || protection under Federal Rule of Civil Procedure 26(c), and as specified above in 27 || the Good Cause Statement—{Nete-any+request fora tered, attorney eyes— 28

Sr STIPULATED PROTECTIVE ORDER

2 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 3 || their support staff). 4 2.5 Designating Party: a Party or Non-Party that designates information 5 |J/or items that it produces in disclosures or in responses to discovery as 6 || “CONFIDENTIAL.” 7 2.6 Disclosure or Discovery Material: all items or information, regardless 8 || of the medium or manner in which it is generated, stored, or maintained (including, 9 ||among other things, testimony, transcripts, and tangible things), that are produced 10 || or generated in disclosures or responses to discovery in this matter. 11 2.7 Expert: a person with specialized knowledge or experience in a matter 12 || pertinent to the litigation who has been retained by a Party or its counsel to serve as |}/an expert witness or as a consultant in this Action. 14 2.8 House Counsel: attorneys who are employees of a party to this Action. 15 House Counsel does not include Outside Counsel of Record or any other outside g 16 || counsel. 8 17 2.9 Non-Party: any natural person, partnership, corporation, association, = 18 || or other legal entity not named as a Party to this action. 19 2.10 Outside Counsel of Record: attorneys who are not employees of a 20 || party to this Action but are retained to represent or advise a party to this Action and 21 || have appeared in this Action on behalf of that party or are affiliated with a law firm 22 || which has appeared on behalf of that party, and includes support staff. 23 2.11 Party: any party to this Action, including all of its officers, directors, 24 || employees, consultants, retained experts, and Outside Counsel of Record (and their 25 || support staffs). 26 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 27 || Discovery Material in this Action. 28

tt STIPULATED PROTECTIVE ORDER

1 2.13 Professional Vendors: persons or entities that provide litigation 2 || support services (e.g., photocopying, videotaping, translating, preparing exhibits or 3 || demonstrations, and organizing, storing, or retrieving data in any form or medium) 4 || and their employees and subcontractors. 5 2.14 Protected Material: any Disclosure or Discovery Material that is 6 || designated as “CONFIDENTIAL.” 7 2.15 Receiving Party: a Party that receives Disclosure or Discovery 8 || Material from a Producing Party. 10 ||/3. SCOPE 11 The protections conferred by this Stipulation and Order cover not only 12 || Protected Material (as defined above), but also (1) any information copied or 13 |/extracted from Protected Material; (2) all copies, excerpts, summaries, or 14 ||compilations of Protected Material; and (3) any testimony, conversations, or 15 || presentations by Parties or their Counsel that might reveal Protected Material. g 16 Any use of Protected Material at trial will be governed by the orders of the 17 || trial judge. This Order does not govern the use of Protected Material at trial. = 18 19 ||4. DURATION 20 {POSSIBLE-PARAGRAPH} Once a case proceeds to trial, all of the 21 ||information that was designated as confidential or maintained pursuant to this 22 || protective order becomes public and will be presumptively available to all members 23 || of the public, including the press, unless compelling reasons supported by specific 24 || factual findings to proceed otherwise are made to the trial judge in advance of the 25 || trial. See Kamakana v. City and County of Honolulu,

(9th 26 || Cir. 2006) (distinguishing “good cause” showing for sealing documents produced 27 ||in discovery from “compelling reasons” standard when merits-related documents 28 || are part of court record). Accordingly, the terms of this protective order do not

or STIPULATED PROTECTIVE ORDER

1 extend beyond the commencement of the trial. 3 ||5. DESIGNATING PROTECTED MATERIAL 4 5.1 Exercise of Restraint and Care in Designating Material for Protection. 5 ||Each Party or Non-Party that designates information or items for protection under 6 ||/this Order must take care to limit any such designation to specific material that 7 || qualifies under the appropriate standards. The Designating Party must designate 8 || for protection only those parts of material, documents, items, or oral or written 9 || communications that qualify so that other portions of the material, documents, 10 ||items, or communications for which protection is not warranted are not swept 11 |] unjustifiably within the ambit of this Order. 12 Mass, indiscriminate, or routinized designations are prohibited. Designations 13 |/that are shown to be clearly unjustified or that have been made for an improper 14 || purpose (e.g., to unnecessarily encumber the case development process or to impose 15 || unnecessary capensis and burdens on other parties) may expose the Designating Z 16 || Party to sanctions. 17 If it comes to a Designating Party’s attention that information or items that it = 18 || designated for protection do not qualify for protection, that Designating Party must 19 || promptly notify all other Parties that it is withdrawing the inapplicable designation. 20 5.2. Manner and Timing of Designations. Except as otherwise provided in 21 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 22 || stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 23 || under this Order must be clearly so designated before the material is disclosed or 24 || produced. 25 Designation in conformity with this Order requires: 26 (a) for information in documentary form (e.g., paper or electronic 27 ||documents, but excluding transcripts of depositions or other pretrial or trial 28 ||proceedings), that the Producing Party affix at a minimum, the legend

STIPULATED PROTECTIVE ORDER

1 || “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 2 || contains protected material. If only a portion or portions of the material on a page 3 || qualifies for protection, the Producing Party also must clearly identify the protected 4 || portion(s) (e.g., by making appropriate markings in the margins). 5 A Party or Non-Party that makes original documents available for 6 |/inspection need not designate them for protection until after the inspecting Party 7 ||has indicated which documents it would like copied and produced. During the 8 |/inspection and before the designation, all of the material made available for 9 ||inspection will be deemed “CONFIDENTIAL.” After the inspecting Party has 10 || identified the documents it wants copied and produced, the Producing Party must 11 || determine which documents, or portions thereof, qualify for protection under this 12 || Order. Then, before producing the specified documents, the Producing Party must 13 |{affix the “CONFIDENTIAL legend” to each page that contains Protected Material. 14 || If only a portion or portions of the material on a page qualifies for protection, the 2 15 || Producing Party also must clearly identify the protected portion(s) (e.g., by making g 16 || appropriate markings in the margins). 8 17 (b) for testimony given in depositions that the Designating Party identify the = 18 || Disclosure or Discovery Material on the record, before the close of the deposition 19 || all protected testimony. 20 (c) for information produced in some form other than documentary and for 21 || any other tangible items, that the Producing Party affix in a prominent place on the 22 || exterior of the container or containers in which the information is stored the legend 23 || “CONFIDENTIAL.” If only a portion or portions of the information warrants 24 || protection, the Producing Party, to the extent practicable, will identify the protected 25 || portion(s). 26 5.3. Inadvertent Failures to Designate. If timely corrected, an inadvertent 27 || failure to designate qualified information or items does not, standing alone, waive 28 || the Designating Party’s right to secure protection under this Order for such material. dr STIPULATED PROTECTIVE ORDER

1 || Upon timely correction of a designation, the Receiving Party must make reasonable 2 || efforts to assure that the material is treated in accordance with the provisions of this 3 || Order. 5 ||6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 6 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 7 ||designation of confidentiality at any time that is consistent with the Court’s 8 || Scheduling Order. 9 6.2 Meet and Confer. The Challenging Party will initiate the dispute 10 || resolution process (and, if necessary, file a discovery motion) under Local Rule 37.1 11 |] et seq. 12 6.3 The burden of persuasion in any such challenge proceeding will be on 13 ||the Designating Party. Frivolous challenges, and those made for an improper a8 14 || purpose (e.g., to harass or impose unnecessary expenses and burdens on other 2 15 || parties) may expose the Challenging Party to sanctions. Unless the Designating g 16 || Party has waived or withdrawn the confidentiality designation, all parties will & 17 ||continue to afford the material in question the level of protection to which it is = 18 |/entitled under the Producing Party’s designation until the Court rules on the 19 || challenge. 20 21}|7. ACCESS TO AND USE OF PROTECTED MATERIAL 22 7.1 Basic Principles. A Receiving Party may use Protected Material that is 23 || disclosed or produced by another Party or by a Non-Party in connection with this 24 || Action only for prosecuting, defending, or attempting to settle this Action. Such 25 || Protected Material may be disclosed only to the categories of persons and under the 26 ||conditions described in this Order. When the Action has been terminated, a 27 ||Receiving Party must comply with the provisions of section 13 below (FINAL 28 || DISPOSITION).

tr STIPULATED PROTECTIVE ORDER

1 Protected Material must be stored and maintained by a Receiving Party at a 2 || location and in a secure manner that ensures that access is limited to the persons 3 || authorized under this Order. 4 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 5 || otherwise ordered by the court or permitted in writing by the Designating Party, a 6 ||Recetving Party may disclose any information or item _ designated 7 || “CONFIDENTIAL” only to: 8 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 9 ||as employees of said Outside Counsel of Record to whom it is reasonably necessary 10 || to disclose the information for this Action; 11 (b) the officers, directors, and employees (including House Counsel) of the 12 || Receiving Party to whom disclosure is reasonably necessary for this Action; 13 (c) Experts (as defined in this Order) of the Receiving Party to whom 3 5 14 □□ disclosure is reasonably necessary for this Action and who have signed the 2 15 ||““Acknowledgment and Agreement to Be Bound” (Exhibit A); g 16 (d) the Court and its personnel: 8 17 (e) court reporters and their staff: = 18 (f) professional jury or trial consultants, mock jurors, and Professional 19 |] Vendors to whom disclosure is reasonably necessary for this Action and who have 20 || signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 21 (g) the author or recipient of a document containing the information or a 22 || custodian or other person who otherwise possessed or knew the information: 23 (h) during their depositions, witnesses ,and attorneys for witnesses, in the 24 || Action to whom disclosure is reasonably necessary provided: (1) the deposing party 25 requests that the witness sign the form attached as Exhibit A hereto; and (2) they 26 || will not be permitted to keep any confidential information unless they sign the 27 ||“Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 28 ||agreed by the Designating Party or ordered by the court. Pages of transcribed

———_——__ ._§_ _|<— STIPULATED PROTECTIVE ORDER

1 || deposition testimony or exhibits to depositions that reveal Protected Material may 2 || be separately bound by the court reporter and may not be disclosed to anyone except 3 || as permitted under this Stipulated Protective Order; and 4 (1) any mediator or settlement officer, and their supporting personnel, 5 || mutually agreed upon by any of the parties engaged in settlement discussions. 71/8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 8 || PRODUCED IN OTHER LITIGATION 9 If a Party is served with a subpoena or a court order issued in other litigation 10 ||that compels disclosure of any information or items designated in this Action as 11 || “CONFIDENTIAL,” that Party must: 12 (a) promptly notify in writing the Designating Party. Such notification will 13 ||include a copy of the subpoena or court order; 3 5 14 (b) promptly notify in writing the party who caused the subpoena or order to 2 15 || issue in the other litigation that some or all of the material covered by the subpoena g 16 || or order is subject to this Protective Order. Such notification will include a copy of & 17 ||this Stipulated Protective Order; and = 18 (c) cooperate with respect to all reasonable procedures sought to be pursued 19 || by the Designating Party whose Protected Material may be affected. 20 If the Designating Party timely seeks a protective order, the Party served with 21 ||the subpoena or court order will not produce any information designated in this 22 || action as “CONFIDENTIAL.” before a determination by the court from which the 23 ||subpoena or order issued, unless the Party has obtained the Designating Party’s 24 ||permission. The Designating Party will bear the burden and expense of seeking 25 || protection in that court of its confidential material and nothing in these provisions 26 ||should be construed as authorizing or encouraging a Receiving Party in this Action 27 || to disobey a lawful directive from another court. 28 —_ _§_<_— STIPULATED PROTECTIVE ORDER

1|)9. ANON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 2 || PRODUCED IN THIS LITIGATION 3 (a) The terms of this Order are applicable to information produced by a Non- 4 ||Party in this Action and designated as “CONFIDENTIAL.” Such information 5 ||produced by Non-Parties in connection with this litigation is protected by the 6 ||remedies and relief provided by this Order. Nothing in these provisions should be 7 || construed as prohibiting a Non-Party from seeking additional protections. 8 (b) In the event that a Party is required, by a valid discovery request, to 9 || produce a Non-Party’s confidential information in its possession, and the Party is 10 ||subject to an agreement with the Non-Party not to produce the Non-Party’s 11 || confidential information, then the Party will: 12 (1) promptly notify in writing the Requesting Party and the Non-Party 2 that some or all of the information requested is subject to a confidentiality 14 agreement with a Non-Party; 2 15 (2) promptly provide the Non-Party with a copy of the Stipulated g 16 Protective Order in this Action, the relevant discovery request(s), and a 8 17 reasonably specific description of the information requested: and = 18 (3) make the information requested available for inspection by the 19 Non-Party, if requested. 20 (c) If the Non-Party fails to seek a protective order from this court within 14 21 days of receiving the notice and accompanying information, the Receiving Party 22 ||may produce the Non-Party’s confidential information responsive to the discovery 23 ||request. If the Non-Party timely seeks a protective order, the Receiving Party will 24 ||not produce any information in its possession or control that is subject to the 25 || confidentiality agreement with the Non-Party before a determination by the court. 26 || Absent a court order to the contrary, the Non-Party will bear the burden and expense 27 || of seeking protection in this court of its Protected Material. 28

td STIPULATED PROTECTIVE ORDER

1|}10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 2 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 3 || Protected Material to any person or in any circumstance not authorized under this 4 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 5 || writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 6 || to retrieve all unauthorized copies of the Protected Material, (c) inform the person 7 |/or persons to whom unauthorized disclosures were made of all the terms of this 8 || Order, and (d) request such person or persons to execute the “Acknowledgment and 9 || Agreement to Be Bound” that is attached hereto as Exhibit A. 10 11 {]/11. INADVERTENT PRODUCTION OF PRIVILEGED OR 12 | OTHERWISE PROTECTED MATERIAL 13 When a Producing Party gives notice to Receiving Parties that certain 3 5 14 || inadvertently produced material is subject to a claim of privilege or other protection, 2 15 || the obligations of the Receiving Parties are those set forth in Federal Rule of Civil : g 16 |! Procedure 26(b)(5)(B). This provision is not intended to modify whatever 17 procedure may be established in an e-discovery order that provides for production 18 Il without prior privilege review. 12 12. MISCELLANEOUS 12.1 Right to Further Relief. Nothing in this Order abridges the night of any person to seek its modification by the Court in the future.

12.2 Right to Assert Other Objections. By stipulating to the entry of this Protective Order no Party waives any right it otherwise would have to object to aK disclosing or producing any information or item on any ground not addressed in this 37 || Stipulated Protective Order. Similarly, no Party waives any right to object on any || ground to use in evidence of any of the material covered by this Protective Order.

—_—_§__§_.— __§_|§_— STIPULATED PROTECTIVE ORDER

1 12.3 Filing Protected Material. A Party that seeks to file under seal any Protected 2 || Material must comply with Civil Local Rule 79-5. Protected Material may only be 3 || filed under seal pursuant to a court order authorizing the sealing of the specific 4 |) Protected Material at issue. If a Party's request to file Protected Material under seal > |lis denied by the court, then the Receiving Party may file the information in the public record unless otherwise instructed by the court. * 1113. FINAL DISPOSITION After the final disposition of this Action, as defined in paragraph 4, within 60 = days of a written request by the Designating Party, each Receiving Party must return all Protected Material to the Producing Party or destroy such material. As used in 12 this subdivision, “all Protected Material” includes all copies, abstracts, E = compilations, summaries, and any other format reproducing or capturing any of the < Protected Material. Whether the Protected Material is returned or destroyed, the Receiving Party must submit a written certification to the Producing Party (and, if not the same person or entity, to the Designating Party) by the 60 day deadline that 4.7 (1) identifies (by category, where appropriate) all the Protected Material that was is returned or destroyed and (2) affirms that the Receiving Party has not retained any 9 copies, abstracts, compilations, summaries or any other format reproducing or an capturing any of the Protected Material. Notwithstanding this provision, Counsel 2 are entitled to retain an archival copy of all pleadings, motion papers, trial, 22 deposition, and hearing transcripts, legal memoranda, correspondence, deposition == and trial exhibits, expert reports, attorney work product, and consultant and expert work product, even if such materials contain Protected Material. Any such archival = copies that contain or constitute Protected Material remain subject to this Protective 70 Order as set forth in Section 4 (DURATION). a 14. Any willful violation of this Order may be punished by civil or criminal 28

—_——_§__ —__§— STIPULATED PROTECTIVE ORDER

1 ||contempt proceedings, financial or evidentiary sanctions, reference to disciplinary 2 || authorities, or other appropriate action at the discretion of the Court. 4 || IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 6 || DATED: August 25, 2021 MCMURRAY HENRIKS, LLP 7 By: /s/ Lauren I. Freidenberg 8 Randy H. McMurray, Esq. Yana G. Henriks, Esq. ? Lauren I. Freidenberg, Esq. 10 Attorneys for Plaintiffs TAVIN PADILLA ul and EDITH PADILLA

g 12 13 || DATED: August 25, 2021 MICHAEL N. FEUER, CITY ATTORNEY 2 KATHLEEN A. KENEALY, Chief Deputy City g < Attorney 2 15 SCOTT MARCUS, Senior Assistant City Attorney 7 CORY M. BRENTE, Senior Assistant City Attorney By: /s/ Matthew W. McAleer 18 Matthew W. McAleer, Esq. 19 Attorneys for Defendants CITY OF LOS ANGELES, ef ai. 20 21

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

24 25 76 || DATED: August 25, 2021 HON. MICHAEL R. WILNER 27 United States Magistrate Judge 28

14 STIPULATED PROTECTIVE ORDER

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND L [full name], of 5 [full address], declare under penalty of perjury that I have read in its entirety and 6 understand the Stipulated Protective Order that was issued by the United States District Court for the Central District of California on [date] in the case of Padilla, et al. v. City of Los Angeles, et al., Case No. 21-CV-03842-GW-MRW. . I agree to comply with and to be bound by all the terms of this Stipulated Protective Order

and I understand and acknowledge that failure to so comply could expose me to sanctions and punishment in the nature of contempt. I solemnly promise that I will

: 2B not disclose in any manner any information or item that is subject to this 14 || Stipulated Protective Order to any person or entity except in strict compliance 2 15 || With the provisions of this Order. S16 I further agree to submit to the jurisdiction of the United States District g 17 || Court for the Central District of California for the purpose of enforcing the terms = 18 || of this Stipulated Protective Order, even if such enforcement proceedings occur 19 || after termination of this action. I hereby appoint 20 || [full name] of [full address and 21 |! telephone number] as my California agent for service of process in connection 22 || with this action or any proceedings related to enforcement of this Stipulated 23 |! Protective Order. 24 |! Date: = City and State where signed: Printed name: = Signature: 28

tr STIPULATED PROTECTIVE ORDER

JOINT MOTION SIGNATURE CERTIFICATION 2 Pursuant to Local Rule 5-4.3.4(a)(2) of the United States District Court for 3 || the Central District of California, I certify that the content of this document, and the 4 | accompanying proposed order, is acceptable to named counsel above and that I have > obtained authorization from counsel to affix his electronic signature to this © Hl document. 8 R tfully submitted Dated: August 25, 2021 □□□ crew earner 10 MCMURRAY HENRIKS LLP ll By: _/s/ Lauren I. Freidenberg Yana G. Henriks, Esq. 12 Lauren I. Pnqulcnin ke iva Somers for __PlaintiffS TAVIN 13 an PADILLA and EDITH PADILLA 14 << 15

(16

17

= 618 12 20 21

23 24 25 26 27 28

16 STIPULATED PROTECTIVE ORDER

2 4 6 8 10 11 g 12 13 14 >

7 18

19 20 21 22 23 24 25 26 27 28