1 GREG L. KIRAKOSIAN (SBN 294580) KIRAKOSIAN LAW, APC 2 HISTORIC ENGINE CO NO. 28 3 644 SOUTH FIGUEROA STREET 4 LOS ANGELES, CALIFORNIA 90017-3411 TELEPHONE: (213) 417-9790 5 FACSIMILE: (213) 477-2355 6 [[email protected]] Attorneys for Plaintiff, FATHER ARMEN BAGRAMYAN 7

8 MICHAEL N. FEUER, City Attorney KATHLEEN A. KENEALY, Chief Deputy City Attorney (SBN 212289) 9 SCOTT MARCUS, Senior Assistant City Attorney (SBN 184980) 10 CORY M. BRENTE, Senior Assistant City Attorney (SBN 115453) J. EDWIN RATHBUN, JR., Deputy City Attorney (SBN 221804) 11 200 North Main Street, 6th Floor, City Hall East 12 Los Angeles, CA 90012 E-mail: [email protected] 13 Phone No.: (213) 978-7041 Fax No.: (213) 978-8785 14 Attorneys for Defendant, CITY OF LOS ANGELES

15 16 UNITED STATES DISTRICT COURT 17 FOR THE CENTRAL DISTRICT OF CALIFORNIA 18 FATHER ARMEN BAGRAMYAN, ) CASE NO. CV20-11060 CAS (AFMx) 19 an individual, ) Hon. Christina A. Snyder, Ctrm. 8D, 8th Fl., 1st Street Mag. Alexander F. MacKinnon, Ctrm 780, 7th Fl., 20 ) Roybal ) 21 Plaintiff, ) STIPULATED [PROPOSED] 22 vs. ) PROTECTIVE ORDER 23 ) CITY OF LOS ANGELES, a public ) 24 Entity; OMAR RUIZ, an individual; ) 25 and DOES 2 through 10, inclusive, ) ) 26

27 Defendants. 28 1 Plaintiff and Defendants, through their respective attorneys of record, 2 stipulate to the following protective order: 3 1. PURPOSES AND LIMITATIONS 4 1.1 Disclosure and discovery activity in this action are likely to 5 involve the production of confidential, proprietary, or private information for which 6 special protection from public disclosure and from use for any purpose other than 7 prosecuting this litigation would be warranted. Accordingly, the parties hereby 8 stipulate to and petition the court to enter the following Stipulated Protective Order. 9 The parties acknowledge that this Stipulated Protective Order (“Order”) does not 10 confer blanket protections on all disclosures or responses to discovery and that the 11 protection it affords extends only to the limited information or items that are entitled 12 under the applicable legal principles to treatment as confidential. The parties further 13 acknowledge, as set forth in Section 10, below, that this Order creates no 14 entitlement to file confidential information under seal; Civil Local Rule 79-5 sets 15 forth the procedures that must be followed and reflects the standards that will be 16 applied when a party seeks permission from the court to file material under seal. 17 1.2 Good Cause Statement: The City asserts that the confidentiality of the 18 materials and information sought by Plaintiff is recognized by California and 19 federal law, as evidenced inter alia by California Penal Code section 832.7 and Kerr 20 v. United States Dist. Ct. for N.D. Cal.,

(9th Cir. 1975), aff'd, 21

(1976). The City does not publicly release materials and information 22 from an officer’s personnel file or from internal investigations about officers’ 23 actions except under protective order or pursuant to a court order, if at all. These 24 materials and information are of the type that has been used to initiate disciplinary 25 action against Los Angeles Police Department (“LAPD”) officers, and has been 26 used as evidence in disciplinary proceedings where the officers’ conduct was 27 considered to be contrary to LAPD policy. The City also maintains that these 28 materials and information are protected by the involved-officers’ rights to privacy. 1 The Plaintiff’s medical and psychological records are also protected by his right to 2 privacy. 3 The City respectfully contends that absent a protective order delineating the 4 responsibilities of nondisclosure on the part of the parties hereto, there is a specific 5 risk of unnecessary and undue disclosure by one or more of the many attorneys, 6 secretaries, law clerks, paralegals and expert witnesses involved in this case, as well 7 as the corollary risk of embarrassment, harassment and professional and legal harm 8 on the part of the LAPD officers referenced in the materials and information. 9 The City also respectfully contends that the unfettered disclosure of the 10 materials and information, absent a protective order, would allow the media to share 11 this information with potential jurors in the area, impacting the rights of the City 12 herein to receive a fair trial. 13 Accordingly, to expedite the flow of information, to facilitate the prompt 14 resolution of disputes over confidentiality of discovery materials, to adequately 15 protect information the parties are entitled to keep confidential, to ensure that the 16 parties are permitted reasonable necessary uses of such material in preparation for 17 and in the conduct of trial, to address their handling at the end of the litigation and 18 serve the ends of justice, a protective order for such information is justified in this 19 matter. It is the intent of the parties that nothing will be designated for tactical 20 reasons and that nothing will be designated as confidential without a good faith 21 belief that it has been maintained in a confidential, non-public manner, and there is 22 good cause why it should not be part of the public record of this case. 23 2. DEFINITIONS 24 2.1 Party: any party to this action, including all of its officers, 25 directors, employees, consultants, retained experts, and outside counsel (and their 26 support staff). 27 2.2 Disclosure or Discovery Material: all items or information, 28 regardless of the medium or manner generated, stored or maintained (including, 1 among other things, testimony, transcripts, or tangible things) that are produced or 2 generated in disclosures or responses to discovery in this matter. 3 2.3 “Confidential” Information or Items: information (regardless of 4 how generated, stored or maintained) or tangible things that qualify for protection 5 under standards developed under F.R.Civ.P. 26 (c). This material includes, but is 6 not limited to, Los Angeles Police Department internal administrative investigative 7 reports and materials, Plaintiff’s medical and psychological records (if any), and 8 other similar confidential records designated as such, including the existence of 9 such records and/or information. 10 2.4 “Highly Confidential – Attorneys’ Eyes Only” Information or 11 Items: extremely sensitive “Confidential Information or Items” whose disclosure 12 to another Party or non-party would create a substantial risk of serious injury that 13 could not be avoided by less restrictive means. 14 2.5 Receiving Party: a Party that receives Disclosure or Discovery 15 Material from a Producing Party. 16 2.6 Producing Party: a Party or non-party that produces Disclosure 17 or Discovery Material in this action. 18 2.7 Designating Party: a Party or non-party that designates 19 information or items that it produces in disclosures or in responses to discovery as 20 “Confidential” or “Highly Confidential – Attorneys’ Eyes Only.” 21 2.8 Protected Material: any Disclosure or Discovery Material that 22 is designated as “Confidential” or as “Highly Confidential – Attorneys’ Eyes Only.” 23 2.9 Outside Counsel: attorneys who are not employees of a Party 24 but who are retained to represent or advise a Party in this action. 25 2.10 House Counsel: attorneys who are employees of a Party. 26 2.11 Counsel (without qualifier): Outside Counsel and House 27 Counsel (as well as their support staffs). 28 2.12 Expert: a person with specialized knowledge or experience in a 1 matter pertinent to the litigation who has been retained by a Party or its counsel to 2 serve as an expert witness or as a consultant in this action and who is not a past or 3 a current employee of a Party or a Party’s competitor and who, at the time of 4 retention, is not anticipated to become an employee of a Party or a Party’s 5 competitor. 6 2.13 Professional Vendors: persons or entities that provide litigation 7 support services (e.g., photocopying; videotaping; translating; preparing exhibits or 8 demonstrations; organizing, storing, retrieving data in any form or medium; etc.) 9 and their employees and subcontractors. 10 3. SCOPE 11 The protections conferred by this Stipulation and Order cover not only 12 Protected Material (as defined above), but also any information copied or extracted 13 therefrom, as well as all copies, excerpts, summaries, or compilations thereof, plus 14 testimony, conversations, or presentations by parties or counsel to or in court or in 15 other settings that might reveal Protected Material. 16 4. DURATION 17 Even after the termination of this litigation, the confidentiality obligations 18 imposed by this Order shall remain in effect until a Designating Party agrees 19 otherwise in writing or a court order otherwise directs. 20 5. DESIGNATING PROTECTED MATERIAL 21 5.1 Exercise of Restraint and Care in Designating Material for 22 Protection. Each Party or non-party that designates information or items for 23 protection under this Order must take care to limit any such designation to specific 24 material that qualifies under the appropriate standards. A Designating Party must 25 take care to designate for protection only those parts of material, documents, items, 26 or oral or written communications that qualify – so that other portions of the 27 material, documents, items or communications for which protection is not 28 warranted are not swept unjustifiably within the ambit of this Order. 1 Mass, indiscriminate, or routinized designations are prohibited. 2 Designations that are shown to be clearly unjustified, or that have been made for an 3 improper purpose (e.g., to unnecessarily encumber or retard the case development 4 process, or to impose unnecessary expenses and burdens on other parties), expose 5 the Designating Party to sanctions. 6 If it comes to a Party’s or a non-party’s attention that information or 7 items that it designated for protection do not qualify for protection at all, or do not 8 qualify for the level of protection initially asserted, that Party or non-party must 9 promptly notify all other parties that it is withdrawing the mistaken designation. 10 5.2 Manner and Timing of Designations. Except as otherwise 11 provided in this Order (see, e.g., second paragraph of section 5.2(a), below), or as 12 otherwise stipulated or ordered, material that qualifies for protection under this 13 Order must be clearly so designated before the material is disclosed or produced. 14 Designation in conformity with this Order requires: 15 (a) for information in documentary form (apart from 16 transcripts of depositions or other pretrial or trial proceedings), that the Producing 17 Party affix the legend “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – 18 ATTORNEYS’ EYES ONLY” at the top of each page that contains protected 19 material. If only a portion or portions of the material on a page qualifies for 20 protection, the Producing Party also must clearly identify the protected portion(s) 21 (e.g., by making appropriate markings in the margins) and must specify, for each 22 portion, the level of protection being asserted (either “CONFIDENTIAL” or 23 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY”). 24 A Party or non-party that makes original documents or materials 25 available for inspection need not designate them for protection until after the 26 inspecting Party has indicated which material it would like copied and produced. 27 During the inspection and before the designation, all of the material made available 28 for inspection shall be deemed “HIGHLY CONFIDENTIAL – ATTORNEYS’ 1 EYES ONLY.” After the inspecting Party has identified the documents it wants 2 copied and produced, the Producing Party must determine which documents, or 3 portions thereof, qualify for protection under this Order, then, before producing the 4 specified documents, the Producing Party must affix the appropriate legend 5 (“CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 6 ONLY”) at the top of each page that contains Protected Material. If only a portion 7 or portions of the material on a page qualifies for protection, the Producing Party 8 must clearly identify the protected portion(s) (e.g., by making appropriate markings 9 in the margins) and must specify, for each portion, the level of protection being 10 asserted (either “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – 11 ATTORNEYS’ EYES ONLY”). 12 (b) for testimony given in deposition or in other pretrial or 13 trial proceedings, that the Party or non-party offering or sponsoring the testimony 14 identify on the record, before the close of the deposition, hearing, or other 15 proceeding, all protected testimony, and further specify any portions of the 16 testimony that qualify as “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 17 ONLY.” When it is impractical to identify separately each portion of testimony 18 that is entitled to protection, and when it appears that substantial portions of the 19 testimony may qualify for protection, the Party or non-party that sponsors, offers, 20 or gives the testimony may invoke on the record (before the deposition or 21 proceeding is concluded) a right to have up to twenty (20) days to identify the 22 specific portions of the testimony as to which protection is sought and to specify 23 the level of protection being asserted (“CONFIDENTIAL” or “HIGHLY 24 CONFIDENTIAL – ATTORNEYS’ EYES ONLY”). Only those portions of the 25 testimony that are appropriately designated for protection within the 20 days shall 26 be covered by the provisions of this Stipulated Protective Order. 27 Transcript pages containing Protected Material must be 28 separately bound by the court reporter, who must affix to the top of each such page 1 the legend “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ 2 EYES ONLY,” as instructed by the Party or non-party offering or sponsoring the 3 witness or presenting the testimony. 4 (c) for information produced in some form other than 5 documentary, and for any other tangible items, that the Producing Party affix in a 6 prominent place on the exterior of the container or containers in which the 7 information or item is stored the legend “CONFIDENTIAL” or “HIGHLY 8 CONFIDENTIAL – ATTORNEYS’ EYES ONLY.” If only portions of the 9 information or item warrant protection, the Producing Party, to the extent 10 practicable, shall identify the protected portions, specifying whether they qualify as 11 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 12 ONLY.” 13 5.3 Inadvertent Failures to Designate. If timely corrected, an 14 inadvertent failure to designate qualified information or items as 15 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 16 ONLY” does not, standing alone, waive the Designating Party’s right to secure 17 protection under this Order for such material. If material is appropriately designated 18 as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 19 ONLY” after the material was initially produced, the Receiving Party, on timely 20 notification of the designation, must make reasonable efforts to assure that the 21 material is treated in accordance with this Order. 22 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 23 6.1 Timing of Challenges. Unless a prompt challenge to a 24 Designating Party’s confidentiality designation is necessary to avoid foreseeable 25 substantial unfairness, unnecessary economic burdens, or a later significant 26 disruption or delay of the litigation, a Party does not waive its right to challenge a 27 confidentiality designation by electing not to mount a challenge promptly after the 28 original designation is disclosed. 1 6.2 Meet and Confer. A Party that elects to initiate a challenge to a 2 Designating Party’s confidentiality designation must do so in good faith and must 3 begin the process by conferring directly (in voice-to-voice dialogue; other forms of 4 communication are not sufficient) with counsel for the Designating Party. In 5 conferring, the challenging Party must explain the basis for its belief that the 6 confidentiality designation was not proper and must give the Designating Party an 7 opportunity to review the designated material, to reconsider the circumstances, and, 8 if no change in designation is offered, to explain the basis for the chosen 9 designation. A challenging Party may proceed to the next stage of the challenge 10 process only if it has engaged in this meet and confer process first. 11 6.3 Judicial Intervention. A Party that elects to press a challenge to 12 a confidentiality designation after considering the justification offered by the 13 Designating Party may file and serve a motion under Civil Local Rule 7 (and in 14 compliance with Civil Local Rule 79-5, if applicable) that identifies the challenged 15 material and sets forth in detail the basis for the challenge. Each such motion must 16 be accompanied by a competent declaration that affirms that the movant has 17 complied with the meet and confer requirements imposed in the preceding 18 paragraph and that sets forth with specificity the justification for the confidentiality 19 designation that was given by the Designating Party in the meet and confer 20 dialogue. 21 The burden of persuasion in any such challenge proceeding shall be on 22 the Designating Party. Until the court rules on the challenge, all parties shall 23 continue to afford the material in question the level of protection to which it is 24 entitled under the Producing Party’s designation. 25 7. ACCESS TO AND USE OF PROTECTED MATERIAL 26 7.1 Basic Principles. A Receiving Party may use Protected Material 27 that is disclosed or produced by another Party or by a non-party in connection with 28 this case only for prosecuting, defending, or attempting to settle this litigation. Such 1 Protected Material may be disclosed only to the categories of persons and under the 2 conditions described in this Order. When the litigation has been terminated, a 3 Receiving Party must comply with the provisions of section 11, below (FINAL 4 DISPOSITION). 5 Protected Material must be stored and maintained by a Receiving Party 6 at a location and in a secure manner that ensures that access is limited to the persons 7 authorized under this Order. 8 7.2 Disclosure of “CONFIDENTIAL” Information or Items. 9 Unless otherwise ordered by the court or permitted in writing by the Designating 10 Party, a Receiving Party may disclose any information or item designated 11 CONFIDENTIAL only to: 12 (a) the Receiving Party’s Outside Counsel of record in this 13 action, as well as employees of said Counsel to whom it is reasonably necessary to 14 disclose the information for this litigation and who have signed the “Agreement to 15 Be Bound by Protective Order” that is attached hereto as Exhibit A; 16 (b) the officers, directors, and employees (including House 17 Counsel) of the Receiving Party to whom disclosure is reasonably necessary for this 18 litigation and who have signed the “Agreement to Be Bound by Protective Order” 19 (Exhibit A); 20 (c) experts (as defined in this Order) of the Receiving Party 21 to whom disclosure is reasonably necessary for this litigation and who have signed 22 the “Agreement to Be Bound by Protective Order” (Exhibit A); 23 (d) the Court and its personnel; 24 (e) court reporters, their staffs, and professional vendors to 25 whom disclosure is reasonably necessary for this litigation and who have signed the 26 “Agreement to Be Bound by Protective Order” (Exhibit A); 27 (f) during their depositions, witnesses in the action to whom 28 disclosure is reasonably necessary and who have signed the “Agreement to Be 1 Bound by Protective Order” (Exhibit A). Pages of transcribed deposition testimony 2 or exhibits to depositions that reveal Protected Material must be separately bound 3 by the court reporter and may not be disclosed to anyone except as permitted under 4 this Stipulated Protective Order. 5 (g) the author of the document or the original source of the 6 information; 7 (h) any mediator or settlement officer, and their supporting 8 personnel, mutually agreed upon by any of the parties engaged in settlement 9 discussions. 10 7.3 Disclosure of “HIGHLY CONFIDENTIAL – ATTORNEYS’ 11 EYES ONLY” Information or Items. Unless otherwise ordered by the court or 12 permitted in writing by the Designating Party, a Receiving Party may disclose any 13 information or item designated “HIGHLY CONFIDENTIAL – ATTORNEYS’ 14 EYES ONLY” only to: 15 (a) the Receiving Party’s Outside Counsel of record in this 16 action, as well as employees of said Counsel to whom it is reasonably necessary to 17 disclose the information for this litigation and who have signed the “Agreement to 18 Be Bound by Protective Order” that is attached hereto as Exhibit A; 19 (b) House Counsel of a Receiving Party (1) to whom 20 disclosure is reasonably necessary for this litigation, and (2) who has signed the 21 “Agreement to Be Bound by Protective Order” (Exhibit A); 22 (c) Experts (as defined in this Order) (1) to whom disclosure 23 is reasonably necessary for this litigation, and (2) who have signed the “Agreement 24 to Be Bound by Protective Order” (Exhibit A); 25 (d) the Court and its personnel; 26 (e) court reporters, their staffs, and professional vendors to 27 whom disclosure is reasonably necessary for this litigation and who have signed the 28 “Agreement to Be Bound by Protective Order” (Exhibit A); 1 (f) during their depositions, witnesses in the action to whom 2 disclosure is reasonably necessary and who have signed the “Agreement to be 3 Bound by Protective Order.” Pages of transcribed deposition testimony or exhibits 4 to depositions that reveal Protected Material must be separately bound by the court 5 reporter and may not be disclosed to anyone except as permitted under this 6 Stipulated Protective Order. In the event the parties cannot agree upon whether 7 disclosure is “reasonably necessary” said parties shall meet and confer on the matter 8 and if there is no resolution may seek relief from the Court. 9 (g) the author of the document or the original source of 10 information. 11 (h) any mediator or settlement officer, and their supporting 12 personnel, mutually agreed upon by any of the parties engaged in settlement 13 discussions. 14 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 15 IN OTHER LITIGATION 16 If a Receiving Party is served with a subpoena or an order issued in other 17 litigation that would compel disclosure of any information or items designated in 18 this action as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – 19 ATTORNEYS’ EYES ONLY,” the Receiving Party must so notify the Designating 20 Party, in writing (by fax, if possible) immediately and in no event more than three 21 court days after receiving the subpoena or order. Such notification must include a 22 copy of the subpoena or court order. 23 The Receiving Party also must immediately inform in writing the Party who 24 caused the subpoena or order to issue in the other litigation that some or all of the 25 material covered by the subpoena or order is the subject of this Protective Order. 26 In addition, the Receiving Party must deliver a copy of this Stipulated Protective 27 Order promptly to the Party in the other action that caused the subpoena or order to 28 issue. 1 The purpose of imposing these duties is to alert the interested parties to the 2 existence of this Protective Order and to afford the Designating Party in this case 3 an opportunity to try to protect its confidentiality interests in the court from which 4 the subpoena or order issued. If the Designating Party timely seeks a protective 5 order, the Party served with the subpoena or court order shall not produce any 6 information designated in this action as “CONFIDENTIAL” or “HIGHLY 7 CONFIDENTIAL” before a determination by the court from which the subpoena 8 or order issued, unless the Party has obtained the Designating Party’s permission. 9 The Designating Party shall bear the burdens and the expenses of seeking protection 10 in that court of its confidential material – and nothing in these provisions should be 11 construed as authorizing or encouraging a Receiving Party in this action to disobey 12 a lawful directive from another court. 13 9. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 14 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 15 Protected Material to any person or in any circumstance not authorized under this 16 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 17 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 18 to retrieve all copies of the Protected Material, (c) inform the person or persons to 19 whom unauthorized disclosures were made of all the terms of this Order, and (d) 20 request such person or persons to execute the “Acknowledgment and Agreement to 21 Be Bound” that is attached hereto as Exhibit A. 22 10. FILING PROTECTED MATERIAL 23 Without written permission from the Designating Party or a court order 24 secured after appropriate notice to all interested persons, a Party may not file in the 25 public record in this action any Protected Material. A Party that seeks to file under 26 seal any Protected Material must comply with Civil Local Rule 79-5. 27 11. FINAL DISPOSITION 28 Unless otherwise ordered or agreed in writing by the Producing Party, within 1 sixty (60) days after the final termination of this action, defined as the dismissal or 2 entry of judgment by the district court, or if an appeal is filed, the disposition of the 3 appeal, each Receiving Party must return all Protected Material to the Producing 4 Party. As used in this subdivision, “all Protected Material” includes all copies, 5 abstracts, compilations, summaries, or any other form of reproducing or capturing 6 any of the Protected Material. With permission in writing from the Designating 7 Party, the Receiving Party may destroy some or all of the Protected Material instead 8 of returning it. Whether the Protected Material is returned or destroyed, the 9 Receiving Party must submit a written certification to the Producing Party (and, if 10 not the same person or entity, to the Designating Party) by the sixty day deadline 11 that identifies (by category, where appropriate) all the Protected Material that was 12 returned or destroyed and that affirms that the Receiving Party has not retained any 13 copies, abstracts, compilations, summaries, or other forms of reproducing or 14 capturing any of the Protected Material. Notwithstanding this provision, Counsel 15 are entitled to retain an archival copy of all pleadings, motion papers, transcripts, 16 legal memoranda, correspondence or attorney work product, even if such materials 17 contain Protected Material. Any such archival copies that contain or constitute 18 Protected Material remain subject to this Protective Order as set forth in Section 4 19 (DURATION), above. 20 12. MISCELLANEOUS 21 12.1 Right to Further Relief. Nothing in this Order abridges the right 22 of any person to seek its modification by the Court in the future. 23 /// 24 /// 25 /// 26 /// 27 /// 28 /// 1 12.2 Right to Assert Other Objections. By stipulating to the entry of 2 Protective Order no Party waives any right it otherwise would have to object to 3 || disclosing or producing any information or item on any ground not addressed in this 4 || Stipulated Protective Order. Similarly, no Party waives any right to object on any 5 || ground to use in evidence any of the material covered by this Protective Order. 6 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 7 8 KIRAKOSIAN LAW, APC 9 || Dated: June 24, 2021 10 By: /S/Greg L. Kwakosiaw 11 GREG L. KIRAKOSIAN, ESQ. Attorneys for Plaintiff FATHER ARMEN 12 BAGRAMYAN 13 14 || Dated: June 24, 2021 LOS ANGELES CITY ATTORNEY’S OFFICE 15 16 By:: S/T. Edwin Rathbun, Ir. 17 J. EDWIN RATHBUN, JR., ESQ. Attorney for Defendant, CITY OF LOS 18 ANGELES 19 20 21 ORDER 33 PURSUANT TO STIPULATION, IT IS SO ORDERED. *4 DATED: 6/24/2021 ( 40 A Nor 25 26 Hon. Alexander F. MacKinnon 7 United States Magistrate Judge 28

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, __________________________________________[print or type full 4 name] of ________________________________________________ [print or type 5 full address], declare under penalty of perjury that I have read in its entirety and 6 understood the Stipulated Protective Order that was issued by the United States 7 District Court for the Central District of California on ______________ [date] in 8 the case of Father Armen Bagramyan vs. City of Los Angeles, et al., Case No. 9 CV20-11060-CAS (AFMx). I agree to comply with and to be bound by all the terms 10 of this Stipulated Protective Order and I understand and acknowledge that failure 11 to so comply could expose me to sanctions and punishment in the nature of 12 contempt. I solemnly promise that I will not disclose in any manner any information 13 or item that is subject to this Stipulated Protective Order to any person or entity 14 except in strict compliance with the provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District Court 16 for the Central District of California for the purpose of enforcing the terms of this 17 Stipulated Protective Order, even if such enforcement proceedings occur after 18 termination of this action. 19 I hereby appoint _____________________________________ [print or type 20 full name] of ____________________________________________________ 21 [print or type full address and telephone number] as my California agent for service 22 of process in connection with this action or any proceedings related to enforcement 23 of this Stipulated Protective Order. 24 Date: _________________________________ 25 City and State where sworn and signed: _________________________________ 26 Printed name: ____________________________________________________ 27 Signature: _______________________________________________________

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