MICHAEL N. FEUER, City Attorney - SBN 111529 1 KATHLEEN A. KENEALY, Chief Deputy City Attorney – SBN 212289 SCOTT MARCUS, Senior Assistant City Attorney - SBN 184980 2 CORY M. BRENTE, Senior Assistant City Attorney – SBN 115453 COLLEEN R. SMITH, Deputy City Attorney – SBN 209719 3 200 North Main Street, 6th Floor, City Hall East 4 Los Angeles, CA 90012 Phone No.: (213) 978-7027 5 Fax No.: (213) 978-8785 Email: [email protected] 6 Attorneys for Defendants CITY OF LOS ANGELES, SERGEANT DAN WIDMAN, 7 OFFICER SCOTT, OFFICER JUAN GALVAN, OFFICER SIERRA and OFFICER KELLY 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10

11 YVONNE MENDOZA, RAYMUND CASE NO.: CV21-04614-KS 12 MENDOZ, and MARJORIE MARINO, Hon. Mag. Karen L. Stevenson, CTRM 580 as Administrators of the Estate of 13 Rommel Mendoza, (Roybal)

14 Plaintiffs, STIPULATED PROTECTIVE v. ORDER AND [PROPOSED] ORDER 15

CITY OF LOS ANGELES; a public 16 entity, OFFICER DANIEL HARTY, 17 SERGEANT J. HARDACKER, SERGEANT DAN WIDMAN, 18 OFFICER SCOTT, OFFICER JUAN GALVAN, OFFICER SIERRA, 19 OFFICER KELLY, and DOES 1-30,

20 Defendants.

21 22 23 1. PURPOSES AND LIMITATIONS 24 Discovery in this action is likely to involve production of confidential, 25 proprietary, or private information for which special protection from public disclosure 26 and from use for any purpose other than prosecuting this litigation may be warranted. 27 Accordingly, the parties hereby stipulate to and petition the Court to enter the following 28 1 1 Stipulated Protective Order. The parties acknowledge that this Stipulated Protective 2 Order does not confer blanket protections on all disclosures or responses to discovery 3 and that the protection it affords from public disclosure and use extends only to the 4 limited information or items that are entitled to confidential treatment under the 5 applicable legal principles. The parties further acknowledge, as set forth in Section 6 13.3 below, that this Stipulated Protective Order does not entitle them to file 7 confidential information under seal; Civil Local Rule 79-5 sets forth the procedures that 8 must be followed and the standards that will be applied when a party seeks permission 9 from the Court to file material under seal. 10 11 2. GOOD CAUSE STATEMENT 12 This action involves the City of Los Angeles and members of the Los Angeles 13 Police Department. Plaintiffs are seeking materials and information that Defendants 14 the City of Los Angeles et al. (“City”) maintain as confidential, such as personnel files 15 of the police officers involved in this incident, Internal Affairs materials and 16 information, video recordings, audio recordings, photographs, Force Investigation 17 Division materials and information and other administrative materials and information 18 currently in the possession of the City and which the City believes need special 19 protection from public disclosure and from use for any purpose other than prosecuting 20 this litigation. Plaintiffs are also seeking official information contained in the personnel 21 files of the police officers involved in the subject incident, which the City maintains as 22 strictly confidential and which the City believes need special protection from public 23 disclosure and from use for any purpose other than prosecuting this litigation. 24 The City asserts that the confidentiality of the materials and information sought 25 by Plaintiffs is recognized by California and federal law, as evidenced inter alia by 26 California Penal Code section 832.7 and Kerr v. United States Dist. Ct. for N.D. Cal., 27

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

(1976). The City has not publicly 28 2 1 released the materials and information referenced above except under protective order 2 or pursuant to a court order, if at all. These materials and information are of the type 3 that has been used to initiate disciplinary action against Los Angeles Police Department 4 (“LAPD”) officers, and has been used as evidence in disciplinary proceedings, where 5 the officers’ conduct was considered to be contrary to LAPD policy. 6 The City contends that absent a protective order delineating the responsibilities 7 of nondisclosure on the part of the parties hereto, there is a specific risk of unnecessary 8 and undue disclosure by one or more of the many attorneys, secretaries, law clerks, 9 paralegals and expert witnesses involved in this case, as well as the corollary risk of 10 embarrassment, harassment and professional and legal harm to the LAPD officers 11 referenced in the materials and information. 12 The City also contends that the unfettered disclosure of the materials and 13 information, absent a protective order, would allow the media to share this information 14 with potential jurors in the area, impacting the rights of the City and the individual 15 Defendant LAPD officers herein to receive a fair trial. 16 Accordingly, to expedite the flow of information, to facilitate the prompt 17 resolution of disputes over confidentiality of discovery materials, to adequately protect 18 information the parties are entitled to keep confidential, to ensure that the parties are 19 permitted reasonable necessary uses of such material in preparation for and in the 20 conduct of trial, to address their handling at the end of the litigation, and serve the ends 21 of justice, a protective order for such information is justified in this matter. It is the 22 intent of the parties that information will not be designated as confidential for tactical 23 reasons and that nothing be so designated without a good faith belief that it has been 24 maintained in a confidential, non-public manner, and there is good cause why it should 25 not be part of the public record of this case. 26 27 28 3 1 Plaintiffs agree that there is Good Cause for a Protective Order so as to preserve 2 the respective interests of the parties while streamlining the process of resolving any 3 disagreements. 4 The parties stipulate that there is Good Cause for, and hereby jointly request that 5 the honorable Court issue a Protective Order regarding confidential documents 6 consistent with the terms and provisions of this Stipulation. However, the entry of a 7 Protective Order by the Court pursuant to this Stipulation shall not be construed as any 8 ruling by the Court on the aforementioned legal statements or privilege claims in this 9 section, nor shall this section be construed as part of any such Court Order. 10 11 3. DEFINITIONS 12 3.1 Action: This pending federal lawsuit, Yvonne Mendoza, et al., v. City of 13 Los Angeles, et al. CV21-04614 KS. 14 3.2 Challenging Party: a Party or Non-Party that challenges the designation 15 of information or items under this Order. 16 3.3 “CONFIDENTIAL” Information or Items: Information (regardless of 17 how it is generated, stored or maintained) or tangible things that qualify for protection 18 under Federal Rule of Civil Procedure 26(c), and/or applicable federal privileges, and 19 as specified above in the Good Cause Statement. This also includes (1) any information 20 copied or extracted from the Confidential information; (2) all copies, excerpts, 21 summaries, abstracts or compilations of Confidential information; and (3) any 22 testimony, conversations, or presentations that might reveal Confidential information. 23 Confidential Information does not include information that was publicly 24 available and not protected previously from disclosure prior to the date of production in 25 this Action of Confidential Information, such as testimony at a trial or a deposition in 26 another matter. The party asserting the non-confidentiality of such documents and 27 28 4 1 information has the burden of establishing the non-confidentiality of such documents 2 and information and also that they were previously publicly available. 3 4 3.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 5 support staff), including counsel of record for the parties to this civil litigation and their 6 support staff. 7 3.5 Designating Party: A Party or Nonparty that designates information or 8 items that it produces in disclosures or in responses to discovery as 9 “CONFIDENTIAL.” 10 3.6 Disclosure or Discovery Material: All items or information, regardless 11 of the medium or manner in which it is generated, stored, or maintained (including, 12 among other things, testimony, transcripts, and tangible things), that are produced or 13 generated in disclosures or responses to discovery by any Party in this matter. 14 3.7 Expert: A person with specialized knowledge or experience in a matter 15 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 16 expert witness or as a consultant in this Action. 17 3.8 Final Disposition: when this Action has been fully and completely 18 terminated by way of settlement, dismissal, trial, appeal and/or remand to state court. 19 3.9 House Counsel: Attorneys who are employees of a party to this Action. 20 House Counsel does not include Outside Counsel of Record or any other outside 21 counsel. 22 3.10 Non-party: Any natural person, partnership, corporation, association or 23 other legal entity not named as a Party to this action. 24 3.11 Outside Counsel of Record: Attorneys who are not employees of a party 25 to this Action but are retained to represent or advise a party to this Action and have 26 appeared in this Action on behalf of that party or are affiliated with a law firm that has 27 appeared on behalf of that party, and includes support staff. 28 5 1 3.12 Party: Any party to this Action, including all of its officers, directors, 2 boards, departments, divisions, employees, consultants, retained experts, House 3 Counsel, and Outside Counsel of Record (and their support staffs). 4 3.13 Producing Party: A Party or Nonparty that produces Disclosure or 5 Discovery Material in this Action, including a Party that is defending a deposition 6 noticed or subpoenaed by another Party.3.14 Professional Vendors: Persons or 7 entities that provide litigation support services (e.g., photocopying, videotaping, 8 translating, preparing exhibits or demonstrations, and organizing, storing, or retrieving 9 data in any form or medium) and their employees and subcontractors. 10 3.15 Protected Material: Any Disclosure or Discovery Material that is 11 designated as “CONFIDENTIAL.” (The term "Confidential Document" shall be 12 synonymous with the term "Protected Material" for the purposes of this Stipulation and 13 any associated Protective Order.) 14 3.16 Receiving Party: A Party that receives Disclosure or Discovery Material 15 from a Producing Party, including a Party that has noticed or subpoenaed and is taking 16 a deposition or comparable testimony. 17 18 4. SCOPE 19 The protections conferred by this Stipulated and Order cover not only Protected 20 Material (as defined above), but also (1) any information copied or extracted from 21 Protected Material; (2) all copies, excerpts, abstracts, summaries, or compilations of 22 Protected Material; and (3) any testimony, conversations, or presentations by Parties or 23 their Counsel that might reveal Protected Material. 24 Any use of Protected Material at trial shall be governed by the orders of the trial 25 judge. This Order does not govern the use of Protected Material at trial. 26 27 5. DURATION 28 6 1 Even after Final Disposition, as set forth in Section 3.8 above, of this litigation, 2 the confidentiality obligations imposed by this Order shall remain in effect until a 3 Designating Party agrees otherwise in writing or a court order otherwise directs. Final 4 disposition of this pending federal Action shall be deemed to be the later of (1) 5 dismissal of all claims and defenses in this Action, with or without prejudice; and (2) 6 final judgment herein after the completion and exhaustion of all appeals, rehearings, 7 remands (as it relates to appeals of this federal Action), trials, or reviews of this Action, 8 including the time limits for filing any motions or applications for extension of time 9 pursuant to applicable law. 10 11 6. DESIGNATING PROTECTED MATERIAL 12 6.1 Exercise of Restraint and Care in Designating Material for Protection. 13 Each Party or Nonparty that designates information or items for protection under 14 this Order must take care to limit any such designation to specific material that qualifies 15 under the appropriate standards. The Designating Party must designate for protection 16 only those parts of material, documents, items or oral or written communications that 17 qualify so that other portions of the material, documents, items or communications for 18 which protection is not warranted are not swept unjustifiably within the ambit of this 19 Order. 20 Mass, indiscriminate or routinized designations are prohibited. Designations that 21 are shown to be clearly unjustified or that have been made for an improper purpose 22 (e.g., to unnecessarily encumber the case development process or to impose 23 unnecessary expenses and burdens on other parties) may expose the Designating Party 24 to sanctions. 25 If it comes to a Designating Party’s attention that information or items that it 26 designated for protection do not qualify for protection, that Designating Party must 27 promptly notify all other Parties that it is withdrawing the inapplicable designation. 28 7 1 6.2 Manner and Timing of Designations. Except as otherwise provided in 2 this Order(see, e.g., second paragraph of section 6.2(a) below), or as otherwise 3 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 4 under this Order must be clearly so designated before the material is disclosed or 5 produced. 6 Designation in conformity with this Order requires: 7 (a) for information in documentary form (e.g., paper or electronic documents, 8 but excluding transcripts of depositions or other pretrial or trial proceedings), that the 9 Producing Party affix at a minimum, the legend “CONFIDENTIAL” or words of a 10 similar effect, and that includes the case name and case number (hereinafter 11 “CONFIDENTIAL legend”), to each page that contains protected material. If only a 12 portion of the material on a page qualifies for protection, the Producing Party also must 13 clearly identify the protected portion(s) (e.g., by making appropriate markings in the 14 margins). 15 A Party or Nonparty that makes original documents available for inspection need 16 not designate them for protection until after the inspecting Party has indicated which 17 documents it would like copied and produced. During the inspection and before the 18 designation, all of the material made available for inspection shall be deemed 19 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 20 copied and produced, the Producing Party must determine which documents, or 21 portions thereof, qualify for protection under this Order. Then, before producing the 22 specified documents, the Producing Party must affix the “CONFIDENTIAL legend” to 23 each page that contains Protected Material. If only a portion of the material on a page 24 qualifies for protection, the Producing Party also must clearly identify the protected 25 portion(s) (e.g., by making appropriate markings in the margins). 26 27 28 8 1 (b) for testimony given in depositions that the Designating Party identifies the 2 Disclosure or Discovery Material on the record, before the close of the deposition all 3 protected testimony. 4 (c) for information produced in some form other than documentary and for any 5 other tangible items, that the Producing Party affix in a prominent place on the exterior 6 of the container or containers in which the information is stored the legend 7 “CONFIDENTIAL.” If only a portion or portions of the information warrants 8 protection, the Producing Party, to the extent practicable, shall identify the protected 9 portion(s). 10 6.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 11 failure to designate qualified information or items does not, standing alone, waive the 12 Designating Party’s right to secure protection under this Order for such material. Upon 13 timely correction of a designation, the Receiving Party must make reasonable efforts to 14 assure that the material is treated in accordance with the provisions of this Order. 15 6.4 Alteration of Confidentiality Stamp Prohibited. A Receiving Party 16 shall not alter, edit, or modify any Protected Material so as to conceal, obscure, or 17 remove a “CONFIDENTIAL” stamp or legend thereon; nor shall a Receiving Party take 18 any other action so as to make it appear that Protected Material is not subject to the 19 terms and provisions of this Stipulation and its associated Order. However, nothing in 20 this section shall be construed so as to prevent a Receiving Party from challenging a 21 confidentiality designation subject to the provisions of section 7, infra. 22 23 7. CHALLENGING CONFIDENTIALITY DESIGNATIONS 24 7.1 Timing of Challenges. Any Party or Nonparty may challenge a 25 designation of confidentiality at any time that is consistent with the Court’s Scheduling 26 Order. 27 28 9 1 7.2 Meet and Confer. The Challenging Party shall initiate the dispute 2 resolution process under Local Rule 37.1 et seq. 3 7.3 Burden of Persuasion. The burden of persuasion in any such challenge 4 proceeding shall be on the Designating Party. Frivolous challenges, and those made for 5 an improper purpose (e.g., to harass or impose unnecessary expenses and burdens on 6 other parties) may expose the Challenging Party to sanctions. Unless the Designating 7 Party has waived or withdrawn the confidentiality designation, all parties shall continue 8 to afford the material in question the level of protection to which it is entitled under the 9 Producing Party’s designation until the Court rules on the challenge. 10 11 8. ACCESS TO AND USE OF PROTECTED MATERIAL 12 8.1 Basic Principles. A Receiving Party may use Protected Material that is 13 disclosed or produced by another Party or by a Nonparty in connection with this Action 14 only for prosecuting, defending or attempting to settle this Action. Such Protected 15 Material may be disclosed only to the categories of persons and under the conditions 16 described in this Order. When the Action has been terminated, a Receiving Party must 17 comply with the provisions of section 14 below (FINAL DISPOSITION). 18 Protected Material must be stored and maintained by a Receiving Party at a 19 location and in a secure manner that ensures that access is limited to the persons 20 authorized under this Order. 21 8.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 22 otherwise ordered by the court or permitted in writing by the Designating Party, a 23 Receiving Party may disclose any information or item designated “CONFIDENTIAL” 24 only to: 25 (a) The Receiving Party’s Outside Counsel of Record in this Action, as well as 26 employees of said Outside Counsel of Record to whom it is reasonably necessary to 27 disclose the information for this Action; 28 10 1 (b) The officers, directors, and employees (including House Counsel) of the 2 Receiving Party to whom disclosure is reasonably necessary for this Action; 3 (c) Experts of the Receiving Party to whom disclosure is reasonably necessary 4 for this Action and who have signed the “Acknowledgment and Agreement to Be 5 Bound” (Exhibit A); 6 (d) The Court and its personnel; 7 (e) Court reporters and their staff; 8 (f) Professional jury or trial consultants, mock jurors, and Professional Vendors 9 to whom disclosure is reasonably necessary for this Action and who have signed the 10 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 11 (g) The author or recipient of a document containing the information or a 12 custodian or other person who otherwise possessed or knew the information; 13 (h) During their depositions, witnesses, and attorneys for witnesses, in the Action 14 to whom disclosure is reasonably necessary provided: (1) the deposing party requests 15 that the witness sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 16 and (2) they will not be permitted to keep any confidential information unless they sign 17 the “Acknowledgment and Agreement to Be Bound,” unless otherwise agreed by the 18 Designating Party or ordered by the Court. Pages of transcribed deposition testimony 19 or exhibits to depositions that reveal Protected Material may be separately bound by the 20 court reporter and may not be disclosed to anyone except as permitted under this 21 Stipulated Protective Order; and 22 (i) Any mediator or settlement officer, and their supporting personnel, mutually 23 agreed upon by any of the parties engaged in settlement discussions and who have 24 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A). 25 8.3. Counsel making the disclosure to any qualified person described herein 26 shall retain the original executed copy of the Nondisclosure Agreement until sixty (60) 27 days after this litigation has become final, including any appellate review, and 28 11 1 monitoring of an injunction. Counsel for the Receiving Party shall maintain all signed 2 Nondisclosure Agreements and shall produce the original signature page upon 3 reasonable written notice from opposing counsel. If an issue arises regarding a 4 purported unauthorized disclosure of Confidential Information, upon noticed motion of 5 contempt filed by the Designating Party, counsel for the Receiving Party may be 6 required to file the signed Nondisclosure Agreements, as well as a list of the disclosed 7 materials, in camera with the Court having jurisdiction of the Stipulation. 8 9 9. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 10 IN OTHER LITIGATION 11 If a Party is served with a subpoena or a court order issued in other litigation that 12 compels disclosure of any information or items designated in this Action as 13 “CONFIDENTIAL,” that Party must: 14 (a) Promptly notify in writing the Designating Party. Such notification shall 15 include a copy of the subpoena or court order; 16 (b) Promptly notify in writing the party who caused the subpoena or order to 17 issue in the other litigation that some or all of the material covered by the subpoena or 18 order is subject to this Stipulated Protective Order. Such notification shall include a 19 copy of this Stipulated Protective Order; and 20 (c) Cooperate with respect to all reasonable procedures sought to be pursued by 21 the Designating Party whose Protected Material may be affected. 22 If the Designating Party timely seeks a protective order, the Party served with the 23 subpoena or court order shall not produce any information designated in this action as 24 “CONFIDENTIAL” before a determination by the court from which the subpoena or 25 order issued, unless the Party has obtained the Designating Party’s permission. The 26 Designating Party shall bear the burden and expense of seeking protection in that court 27 of its confidential material and nothing in these provisions should be construed as 28 12 1 authorizing or encouraging a Receiving Party in this Action to disobey a lawful 2 directive from another court. 3 4 10. A NONPARTY’S PROTECTED MATERIAL SOUGHT TO BE 5 PRODUCED IN THIS LITIGATION 6 10.1 Application. The terms of this Stipulated Protective Order are applicable 7 to information produced by a Non-Party in this Action and designated as 8 “CONFIDENTIAL.” Such information produced by Non-parties in connection with 9 this litigation is protected by the remedies and relief provided by this Stipulated 10 Protective Order. Nothing in these provisions should be construed as prohibiting a Non- 11 party from seeking additional protections. 12 10.2 Notification. In the event that a Party is required, by a valid discovery 13 request, to produce a Non-party’s confidential information in its possession, and the 14 Party is subject to an agreement with the Non-party not to produce the Non-party’s 15 confidential information, then the Party shall: 16 (1) Promptly notify in writing the Requesting Party and the Non-party that some 17 or all of the information requested is subject to a confidentiality agreement with a Non- 18 party; 19 (2) Promptly provide the Non-party with a copy of the Stipulated Protective 20 Order in this Action, the relevant discovery request(s), and a reasonably specific 21 description of the information requested; and 22 (3) Make the information requested available for inspection by the Non-party, if 23 requested. 24 10.3 Conditions of Production. If the Non-party fails to seek a protective order 25 from this Court within fourteen (14) days of receiving the notice and accompanying 26 information, the Receiving Party may produce the Non-party’s confidential information 27 responsive to the discovery request. If the Non-party timely seeks a protective order, 28 13 1 the Receiving Party shall not produce any information in its possession or control that 2 is subject to the confidentiality agreement with the Non-party before a determination 3 by the Court. Absent a court order to the contrary, the Non-party shall bear the burden 4 and expense of seeking protection in this court of its Protected Material. 5 6 11. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 7 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 8 Protected Material to any person or in any circumstance not authorized under this 9 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 10 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 11 all unauthorized copies of the Protected Material, (c) inform the person or persons to 12 whom unauthorized disclosures were made of all the terms of this Stipulated Protective 13 Order, and (d) request such person or persons to execute the “Acknowledgment and 14 Agreement to Be Bound” (Exhibit A). 15 16 12. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 17 PROTECTED MATERIAL 18 When a Producing Party gives notice to Receiving Parties that certain 19 inadvertently produced material is subject to a claim of privilege or other protection, 20 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 21 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 22 may be established in an e-discovery order that provides for production without prior 23 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 24 parties reach an agreement on the effect of disclosure of a communication or 25 information covered by the attorney-client privilege or work product protection, the 26 parties may incorporate their agreement in the Stipulated Protective Order submitted to 27 the Court. 28 14 1 13. MISCELLANEOUS 2 13.1 Right to Further Relief. Nothing in this Stipulated Protective Order 3 abridges the right of any person to seek its modification by the Court in the future. 4 13.2 Right to Assert Other Objections. By stipulating to the entry of this 5 Stipulated Protective Order, no Party waives any right it otherwise would have to object 6 to disclosing or producing any information or item on any ground not addressed in this 7 Stipulated Protective Order. Similarly, no Party waives any right to object on any 8 ground to use in evidence of any of the material covered by this Stipulated Protective 9 Order. 10 13.3 Filing Protected Material. A Party that seeks to file under seal any 11 Protected Material must comply with Local Civil Rule 79-5. Protected Material may 12 only be filed under seal pursuant to a court order authorizing the sealing of the specific 13 Protected Material at issue. If a Party’s request to file Protected Material under seal is 14 denied by the court, then the Receiving Party may file the information in the public 15 record unless otherwise instructed by the Court. 16 17 14. FINAL DISPOSITION 18 After the FINAL DISPOSITION of this Action, as defined in paragraph 3.8, 19 within sixty (60) days of a written request by the Designating Party, each Receiving 20 Party must return all Protected Material to the Producing Party. As used in this 21 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 22 summaries, and any other format reproducing or capturing any of the Protected 23 Material. The Receiving Party must submit a written certification to the Producing 24 Party (and, if not the same person or entity, to the Designating Party) by the 60-day 25 deadline that (1) identifies (by category, where appropriate) all the Protected Material 26 that was returned and (2) affirms that the Receiving Party has not retained any copies, 27 abstracts, compilations, summaries or any other format reproducing or capturing any of 28 15 1 the Protected Material. Notwithstanding this provision, Counsel is entitled to retain an 2 archival copy of all pleadings; motion papers; trial, deposition, and hearing transcripts; 3 legal memoranda; correspondence; deposition and trial exhibits; expert reports; 4 attorney work product; and consultant and expert work product, even if such materials 5 contain Protected Material. Any such archival copies that contain or constitute 6 Protected Material remain subject to this Stipulated Protective Order as set forth in 7 Section 5 (DURATION). 8 9 15. VIOLATION 10 Any violation of this Stipulated Protective Order may be punished by any and all 11 appropriate measures including, without limitation, contempt proceedings and/or 12 monetary sanctions. 13 14 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD: 15 Dated: November 22, 2021 CBS LAW, INC. 16

17 By: /s/Christopher Bou Saeed 18 CHRISTOPHER BOU SAEED, ESQ. Attorneys for Plaintiffs, YVONNE MENDOZA, et 19 al.

20

Dated: November 22, 2021 CARTER LAW FIRM APC 21

22 By: /s/ Corey Carter COREY ALAN CARTER, ESQ. 23 Attorneys for Plaintiffs, YVONNE MENDOZA, et al. 24 / / / 25 / / / 26 / / / 27 28 16 1 4 || Dated: November 22, 2021 MICHAEL N. FEUER, City Attorney KATHLEEN A. KENEALY, Chief Dep. City Atty. 3 SCOTT MARCUS, Senior Assistant City Attorney 4 CORY M. BRENTE, Senior Assistant City Attorney By: /s/ Colleen R. Smith 5 COLLEEN R. SMITH, Deputy City Attorney 6 Attorneys for Defendants CITY OF LOS ANGELES, SERGEANT DAN WIDMAN, 7 OFFICER SCOTT, OFFICER JUAN GALVAN, OFFICER SIERRA and OFFICER KELLY 8 Dated: November 22, 2021 MANNING AND KASS ELLROD RAMIRE 10 TRESTER LLP 1 By: /s/Eugene Ramirez EUGENE RAMIREZ, ESQ. 12 DEANN RIVARD, ESQ. Attorneys for Defendant, OFFICER DANIEL 13 HARTY 14 15 Dated: November 22, 2021 ORBACH HUFF SUAREZ AND HENDERSO LLP 16 By: /s/ Kevin Gilbert 17 KEVIN E. GILBERT, ESQ. Attorneys for Defendant, SERGEANT J. 18 HARDACKER 19 20|| FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 21 | 22 Kh, 33 || Dated: November 23, 2021 en SAK__ HONORABLE KAREN L. STEVENSON 24 UNITED STATES MAGISTRATE JUDGE 25 26 27 28 Mendoza et al., v. City of LA etal. [PROPOSED] STIPULATED PROTECTIVE ORDER CV21-04614 KS

1 ATTACHMENT “A” 2 ACKNOWLEDGEMENT AND AGREEMENT TO BE BOUND 3 4 I, [full name], of 5 [address], declare under penalty of perjury that I have read in its 6 entirety and understand the Stipulated Protective Order that was issued by the United 7 States District Court for the Central District of California on [date] in 8 the case of Yvonne Mendoza, et al. v. City of Los Angeles, et al , United States District 9 Court for the Central District of California, Central Division, Case No. CV21-04614 10 KS. I agree to comply with and to be bound by all the terms of this Stipulated Protective 11 Order, and I understand and acknowledge that failure to so comply could expose me to 12 sanctions and punishment in the nature of contempt. I solemnly promise that I will not 13 disclose in any manner any information or item that is subject to this Stipulated 14 Protective Order to any person or entity except in strict compliance with the provisions 15 of this Stipulated Protective Order. 16 I further agree to submit to the jurisdiction of the United States District Court for 17 the Central District of California for the purpose of enforcing the terms of this Stipulated 18 Protective Order, even if such enforcement proceedings occur after termination of this 19 action. I hereby appoint [full name] of 20 [address and telephone number] as my California 21 agent for service of process in connection with this action or any proceedings related to 22 enforcement of this Stipulated Protective Order. 23 24 Signature: 25 Printed Name: 26 Date: 27 City and State Where Sworn and Signed: 28