Dominque Anderson v. County of Los Angeles

1 | ANDREW BAUM - State Bar No. 190397 abaum @ elaserweil.com

2 | MICHAEL L. SMITH - State Bar No. 298917 msmith@ glaserweil-com

3 | GLASER WEIL FINK HOWARD

AVCHEN & SHAPIRO LLP

4 | 10250 Constellation Boulevard, 19th Floor

Los Angeles, California 90067

5 | Telephone: (310) 553-3000

Facsimile: (310) 556-2920

Attorneys for Defendants

7 | County of Los Angeles, Los Angeles County Probation Department; Deputy Probation Officer Ernest Walker; Deputy Probation Officer || David Glasby: Deputy Probation Officer Jeffrey Eckler; and Deputy Probation Officer/Deputy Services Officer Erin Walton

0 UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA | DOMINQUE ANDERSON; LELA CASE NO.: 2:21-cv-05966-MCS-JEM ‘oO DENNIS; DEBRRA CARR; EIONA

13 | FORD. aka ETONA BULLARD; Hon. Mark C. Scarsi Ss FALLON RICHIE; CRYSTAL CHAVIS; oO 14 | and SHAYPREA MOORE JEFFERSON, n aka SHAYPREA MOORE, STIPULATED PROTECTIVE 15 Plaintiff ORDER aintuT,

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V. TRIAL DATE: — January 24, 2023 COUNTY OF LOS ANGELES, LOS

18 | ANGELES COUNTY PROBATION

DEPARTMENT; LOS ANGELES

19 | COUNTY CHIEF PROBATION

OFFICER ROBERT TAYLOR;

20 | CRITTENTON SERVICES FOR

CHILDREN AND FAMILIES GROUP

21 | HOME; DEPUTY PROBATION

OFFICER ERNEST WALKER;

22 | DEPUTY PROBATION OFFICER

JEFFREY ECKLER; DEPUTY

23 | PROBATION OFFICER DAVID

GLASBY; DEPUTY PROBATION

24 | OFFICER/DEPUTY SERVICES

OFFICER SERRINA HART; DEPUTY

25 | PROBATION OFFICER/DEPUTY

SERVICES OFFICER ERIN WALTON;

26 | DEPUTY PROBATION

OFFICER/DEPUTY SERVICES

27 | OFFICER FNU NEWBELL; DEPUTY

PROBATION OFFICER FNU GOOD;

28 | DEPUTY PROBATION OFFICER FNU

1 | TUCKER; JOHN EVANS; OFFICER

FNU ISKANDER; OFFICER FNU

2 aR TINEZ: and DOES I through 100,

Defendants.

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Bos

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1 PURPOSES AND LIMITATIONS

2 Discovery in this action is likely to involve production of confidential, | proprietary, or private information for which special protection from public disclosut land from use for any purpose other than prosecuting this litigation may 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 th || 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 in Section XII(C), | below, that this Stipulated Protective Order does not entitle them to file confidential information under seal; Civil Local Rule 79-5 sets forth the procedures that must be | followed and the standards that will be applied when a party seeks permission from | the Court to file material under seal. © 15 A. GOOD CAUSE STATEMENT

U 16 This action involves a lawsuit by former detainees and probationers who were |juveniles at the time they were detained and/or on probation, and is therefore likely t {involve issues and discovery regarding sensitive juvenile records for which special | protection from public disclosure and from use for any purpose other than prosecutio □□ this action is warranted. Additionally, this action involves claims against several individual probation officers and will likely seek confidential personnel records for |these employees. Such confidential and proprietary materials and information consis of, among other things, medical records, psychological treatment records, criminal records, including records that include sensitive third-party information, and |/personnel records. Accordingly, to expedite the flow of information, to facilitate the 26 prompt resolution of disputes over confidentiality of discovery materials, to 27 adequately protect information the parties are entitled to keep confidential, to ensure |that the parties are permitted reasonable necessary uses of such material in | preparation for and in the conduct of trial, to address their handling at the end of the |litigation, and serve the ends of justice, a protective order for such information is ||justified in this matter. It is the intent of the parties that information will not be |designated as confidential for tactical reasons and that nothing be so designated || without a good faith belief that it has been maintained in a confidential, non-public ||manner, and there is good cause why it should not be part of the public record of this ||case.

8 B. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER 9 SEAL

10 The parties further acknowledge, as set forth in Section 12.C, below, that this | Stipulated Protective Order does not entitle them to file confidential information Junder seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and 13 standards that will be applied when a party seeks permission from the court to file | material under seal.

6 15 There is a strong presumption that the public has a right of access to judicial U 16 | proceedings and records in civil cases. In connection with non-dispositive motions, | good cause must be shown to support a filing under seal. See Kamakana v. City and | County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors | Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc 1187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require gooc cause showing), and a specific showing of good cause or compelling reasons with 22 proper evidentiary support and legal justification, must be made with respect to 23 Protected Material that a party seeks to file under seal. The parties’ mere designation lof Disclosure or Discovery Material as CONFIDENTIAL does not— without the |submission of competent evidence by declaration, establishing that the material |sought to be filed under seal qualifies as confidential, privileged, or otherwise | protectable—constitute good cause.

28 Further, if a party requests sealing related to a dispositive motion or trial, then |compelling reasons, not only good cause, for the sealing must be shown, and the reli |sought shall be narrowly tailored to serve the specific interest to be protected. See || Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 2010). For each litem or type of information, document, or thing sought to be filed or introduced unde seal in connection with a dispositive motion or trial, the party seeking protection mus |articulate compelling reasons, supported by specific facts and legal justification, for |the requested sealing order. Again, competent evidence supporting the application to ||file documents under seal must be provided by declaration.

9 Any document that is not confidential, privileged, or otherwise protectable in its entirety will not be filed under seal if the confidential portions can be redacted. If | documents can be redacted, then a redacted version for public viewing, omitting only |the confidential, privileged, or otherwise protectable portions of the document, shall |be filed. Any application that seeks to file documents under seal in their entirety | should include an explanation of why redaction is not feasible. © 15 {IL DEFINITIONS

UO 16 A. Action: The pending action, Dominique Anderson v. County of Los | Angeles, et al. (Central District of California Case No. 2:21-cv-05966-MCS-JEM). 18 B. Challenging Party: A Party or Non-Party that challenges the designatio: {of information or items under this Order.

20 C. “CONFIDENTIAL” Information or Items: Information (regardless of | how it is generated, stored or maintained) or tangible things that qualify for protectio Junder Federal Rule of Civil Procedure 26(c), and as specified above in the Good | Cause Statement.

24 D. Counsel: Outside Counsel of Record, House Counsel (as well as their support staff).

26 E. Designating Party: A Party or Non-Party that designates information or |/items that it produces in disclosures or in responses to discovery as | “CONFIDENTIAL.”

1 F. Disclosure or Discovery Material: All items or information, regardless |of the medium or manner in which it is generated, stored, or maintained (including, among other things, testimony, transcripts, and tangible things), that are produced or | generated in disclosures or responses to discovery in this matter.

5 G. Expert: A person with specialized knowledge or experience in a matter || 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.

8 H. House Counsel: Attorneys who are employees of a party to this Action. 9 |For Defendants, this includes Los Angeles County Counsel. House Counsel does no 10 include Outside Counsel of Record or any other outside counsel.

11 I. Non-Party: Any natural person, partnership, corporation, association, 01 Jother legal entity not named as a Party to this action.

13 J. Outside Counsel of Record: Attorneys who are not employees of a part |'to this Action but are retained to represent or advise a party to this Action and have 15 | appeared in this Action on behalf of that party or are affiliated with a law firm which UO 16 |has appeared on behalf of that party, and includes support staff.

17 K. Party: Any party to this Action, including all of its officers, directors, |employees, consultants, retained experts, and Outside Counsel of Record (and their |support staffs).

20 L. Producing Party: A Party or Non-Party that produces Disclosure or | Discovery Material in this Action.

22 M. Professional Vendors: Persons or entities that provide litigation support |services (e.g., photocopying, videotaping, translating, preparing exhibits or |demonstrations, and organizing, storing, or retrieving data in any form or medium) □□□ their employees and subcontractors.

26 N. — Protected Material: Any Disclosure or Discovery Material that is | designated as “CONFIDENTIAL.”

28 O. Receiving Party: A Party that receives Disclosure or Discovery Materia from a Producing Party.

2/1. SCOPE

3 A. — The protections conferred by this Stipulation and Order cover not only |Protected Material (as defined above), but also (1) any information copied or extracted from Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected Material; and (3) any testimony, conversations, or || presentations by Parties or their Counsel that might reveal Protected Material. 8 B. — Any use of Protected Material at trial shall be governed by the lorders of the trial judge. This Order does not govern the use of Protected Material at |{trial.

11 |IV. DURATION

2 Even after final disposition of this litigation, the confidentiality obligations imposed by this Order shall remain in effect until a Designating Party agrees | otherwise in writing or a court order otherwise directs. Final disposition shall be 15 |deemed to be the later of (1) dismissal of all claims and defenses in this Action, with UO 16 |or without prejudice; and (2) final judgment herein after the completion and | exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 18 including the time limits for filing any motions or applications for extension of time | pursuant to applicable law.

VV. DESIGNATING PROTECTED MATERIAL

21 A. Exercise of Restraint and Care in Designating Material for Protection 22 1. Each Party or Non-Party that designates information or items for □ protection under this Order must take care to limit any such designation to specific {material that qualifies under the appropriate standards. The Designating Party must designate for protection only those parts of material, documents, items, or oral or | written communications that qualify so that other portions of the material, document: items, or communications for which protection is not warranted are not swept Junjustifiably within the ambit of this Order. l 2. Mass, indiscriminate, or routinized designations are prohibited. 2 |Designations that are shown to be clearly unjustified or that have been made for an || improper purpose (e.g., to unnecessarily encumber the case development process or t impose unnecessary expenses and burdens on other parties) may expose the | Designating Party to sanctions.

6 3. If it comes to a Designating Party’s attention that information or |items that it designated for protection do not qualify for protection, that Designating |Party must promptly notify all other Parties that it is withdrawing the inapplicable | designation.

10 B. Manner and Timing of Designations

11 1. Except as otherwise provided in this Order (see, e.g., Section | V.B(2)(b) below), or as otherwise stipulated or ordered, Disclosure or Discovery | Material that qualifies for protection under this Order must be clearly so designated | before the material is disclosed or produced.

6 15 2. Designation in conformity with this Order requires the following: U 16 a. For information in documentary form (e.g., paper or |electronic documents, but excluding transcripts of depositions or other pretrial or tria | proceedings), that the Producing Party affix at a minimum, the legend |“CONFIDENTIAL?” (hereinafter “CONFIDENTIAL legend”), to each page that |contains protected material. If only a portion or portions of the material on a page | qualifies for protection, the Producing Party also must clearly identify the protected |portion(s) (e.g., by making appropriate markings in the margins).

23 b. A Party or Non-Party that makes original documents available for inspection need not designate them for protection until after the inspecting Party has indicated which documents it would like copied and produced. 26 | During the inspection and before the designation, all of the material made available 27 for inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants copied and produced, the Producing Party must | determine which documents, or portions thereof, qualify for protection under this |Order. Then, before producing the specified documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page that contains Protected Material. ] lonly a portion or portions of the material on a page qualifies for protection, the |Producing Party also must clearly identify the protected portion(s) (e.g., by making | appropriate markings in the margins).

7 C. For testimony given in depositions, that the Designating |Party identify the Disclosure or Discovery Material on the record, before the close of ||the deposition all protected testimony.

10 d. For information produced in form other than document and □ □□□ any other tangible items, that the Producing Party affix in a prominent place on tk |exterior of the container or containers in which the information is stored the legend “CONFIDENTIAL.” If only a portion or portions of the information warrants | protection, the Producing Party, to the extent practicable, shall identify the protected 15 | portion(s).

U 16 C. Inadvertent Failure to Designate

17 1. If timely corrected, an inadvertent failure to designate qualified {information or items does not, standing alone, waive the Designating Party’s right to |secure protection under this Order for such material. Upon timely correction of a 20 designation, the Receiving Party must make reasonable efforts to assure that the |material is treated in accordance with the provisions of this Order.

22 |VI. CHALLENGING CONFIDENTIALITY DESIGNATIONS

23 A. — Timing of Challenges

24 1. Any party or Non-Party may challenge a designation of {confidentiality at any time that is consistent with the Court’s Scheduling Order. 26 B. Meet and Confer

27 1. The Challenging Party shall initiate the dispute resolution process |under Local Rule 37.1 et seq. l C. — Any challenge submitted to the Court shall be via a joint stipulation pursuant to Local Rule 37-2.

3 D. The burden of persuasion in any such challenge proceeding shall be on |the Designating Party. Frivolous challenges, and those made for an improper purpos |(e.g., to harass or impose unnecessary expenses and burdens on other parties) may |/expose the Challenging Party to sanctions. Unless the Designating Party has waived jor withdrawn the confidentiality designation, all parties shall continue to afford the ||material in question the level of protection to which it is entitled under the Producing |Party’s designation until the Court rules on the challenge.

10 | VII. ACCESS TO AND USE OF PROTECTED MATERIAL

11 A. — Basic Principles

2 1. A Receiving Party may use Protected Material that is disclosed o1 | produced by another Party or by a Non-Party in connection with this Action only for | prosecuting, defending, or attempting to settle this Action. Such Protected Material 15 |may be disclosed only to the categories of persons and under the conditions describe: U 16 in this Order. When the Action has been terminated, a Receiving Party must comply | with the provisions of Section XIII below (FINAL DISPOSITION).

18 2. Protected Material must be stored and maintained by a Receiving |Party at a location and in a secure manner that ensures that access is limited to the | persons authorized under this Order.

21 B. Disclosure of “CONFIDENTIAL” Information or Items 22 1. Unless otherwise ordered by the Court or permitted in writing by the Designating Party, a Receiving Party may disclose any information or item designated “CONFIDENTIAL” only to:

25 a. The Receiving Party’s Outside Counsel of Record in this | Action, as well as employees of said Outside Counsel of Record to whom it is |reasonably necessary to disclose the information for this Action; 28 b. | The officers, directors, and employees (including House |Counsel) of the Receiving Party to whom disclosure is reasonably necessary for this | Action;

3 c. Experts (as defined in this Order) of the Receiving Party to |whom disclosure is reasonably necessary for this Action and who have signed the |“Acknowledgment and Agreement to Be 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 to whom disclosure is reasonably necessary or this Action and | who have signed the “Acknowledgment and Agreement to be Bound” attached as | Exhibit A hereto;

2 g. The author or recipient of a document containing the |information or a custodian or other person who otherwise possessed or knew the 14 information; © 15 h. During their depositions, witnesses, and attorneys for U 16 | witnesses, in the Action to whom disclosure is reasonably necessary provided: (1) the |deposing party requests that the witness sign the “Acknowledgment and Agreement 1 |Be Bound;” and (ii) they will not be permitted to keep any confidential information | unless they sign the “Acknowledgment and Agreement to Be Bound,” unless otherwise agreed by the Designating Party or ordered by the Court. Pages of |transcribed deposition testimony or exhibits to depositions that reveal Protected | Material may be separately bound by the court reporter and may not be disclosed to anyone except as permitted under this Stipulated Protective Order; and 24 i. Any mediator or settlement officer, and their supporting |personnel, mutually agreed upon by any of the parties engaged in settlement || discussions.

28 ||///

1 | VOI. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCE 2 IN OTHER LITIGATION

3 A. — Ifa Party is served with a subpoena or a court order issued in other litigation that compels disclosure of any information or items designated in this | Action as “CONFIDENTIAL,” that Party must:

6 1. Promptly notify in writing the Designating Party. Such |notification shall include a copy of the subpoena or court order; 8 2. Promptly notify in writing the party who caused the subpoena or lorder to issue in the other litigation that some or all of the material covered by the 10 subpoena or order is subject to this Protective Order. Such notification shall include 11 copy of this Stipulated Protective Order; and

2 3. Cooperate with respect to all reasonable procedures sought to be | pursued by the Designating Party whose Protected Material may be affected.

14 B. If the Designating Party timely seeks a protective order, the Party servec 15 | with the subpoena or court order shall not produce any information designated in this U 16 action as “CONFIDENTIAL” before a determination by the Court from which the |subpoena or order issued, unless the Party has obtained the Designating Party’s |permission. The Designating Party shall bear the burden and expense of seeking | protection in that court of its confidential material and nothing in these provisions should be construed as authorizing or encouraging a Receiving Party in this Action tc |disobey a lawful directive from another court.

22 □ □□□ A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

23 PRODUCED IN THIS LITIGATION

24 A. — The terms of this Order are applicable to information produced by a |Non-Party in this Action and designated as “CONFIDENTIAL.” Such information | produced by Non-Parties in connection with this litigation is protected by the |remedies and relief provided by this Order. Nothing in these provisions should be |construed as prohibiting a Non-Party from seeking additional protections. l B. — In the event that a Party is required, by a valid discovery request, to □ produce a Non-Party’s confidential information in its possession, and the Party is ||subject to an agreement with the Non-Party not to produce the Non-Party’s |confidential information, then the Party shall:

5 1. Promptly notify in writing the Requesting Party and the Non-Part that some or all of the information requested is subject to a confidentiality agreement | with a Non-Party;

8 2. Promptly provide the Non-Party with a copy of the Stipulated |Protective Order in this Action, the relevant discovery request(s), and a reasonably ||specific description of the information requested; and 11 3. Make the information requested available for inspection by the | Non-Party, if requested.

13 C. — Ifthe Non-Party fails to seek a protective order from this court within 1- 14 days of receiving the notice and accompanying information, the Receiving Party may 15 | produce the Non-Party’s confidential information responsive to the discovery reques U 16 If the Non-Party timely seeks a protective order, the Receiving Party shall not | produce any information in its possession or control that is subject to the {confidentiality agreement with the Non-Party before a determination by the court. 19 | Absent a court order to the contrary, the Non-Party shall bear the burden and expens« |of seeking protection in this court of its Protected Material.

21 |X. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

22 A. — Ifa Receiving Party learns that, by inadvertence or otherwise, it has |disclosed Protected Material to any person or in any circumstance not authorized |under this Stipulated Protective Order, the Receiving Party must immediately (1) |notify in writing the Designating Party of the unauthorized disclosures, (2) use its be: efforts to retrieve all unauthorized copies of the Protected Material, (3) inform the 27 person or persons to whom unauthorized disclosures were made of all the terms of this Order, and (4) request such person or persons to execute the “Acknowledgment |and Agreement to be Bound” that is attached hereto as Exhibit A.

2 |XI. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 3 PROTECTED MATERIAL

4 A. | When a Producing Party gives notice to Receiving Parties that certain inadvertently produced material is subject to a claim of privilege or other protection, ||the obligations of the Receiving Parties are those set forth in Federal Rule of Civil |Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure ||may be established in an e-discovery order that provides for production without prio privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the | parties reach an agreement on the effect of disclosure of a communication or |information covered by the attorney-client privilege or work product protection, the |parties may incorporate their agreement in the Stipulated Protective Order submitted 13 the Court.

5 14 MISCELLANEOUS

6 15 A. Right to Further Relief

U 16 1. Nothing in this Order abridges the right of any person to | seek its modification by the Court in the future.

18 B. Right to Assert Other Objections

19 1. By stipulating to the entry of this Protective Order, no Party | waives any right it otherwise would have to object to disclosing or producing any |information or item on any ground not addressed in this Stipulated Protective Order. 22 |Similarly, no Party waives any right to object on any ground to use in evidence of an {of the material covered by this Protective Order.

24 C. Filing Protected Material

25 1. A Party that seeks to file any Protected Material must comply wit |Civil Local Rule 79-5. Protected Material may only be filed under seal pursuant to a |court order authorizing the sealing of the specific Protected Material at issue. Ifa || Party's request to file Protected Material under seal is denied by the Court, then the Receiving Party may file the information in the public record unless otherwise |instructed by the Court.

3 | FINAL DISPOSITION

4 A. After the final disposition of this Action, as defined in Section V, within |s1xty (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. A used in this subdivision, “all Protected Material” includes all copies, abstracts, |;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 no ||the same person or entity, to the Designating Party) by the 60 day deadline that (1) |identifies (by category, where appropriate) all the Protected Material that was | returned or destroyed and (2) affirms that the Receiving Party has not retained any | copies, abstracts, compilations, summaries or any other format reproducing or 15 capturing any of the Protected Material. Notwithstanding this provision, Counsel are UO 16 entitled to retain an archival copy of all pleadings, motion papers, trial, 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 Order a |set forth in Section TV (DURATION).

22 B. — Any violation of this Order may be punished by any and all appropriate |measures including, without limitation, contempt proceedings and/or monetary sanctions.

25 IT IS SO STIPULATED

DATED: November 23, 2021 LAW OFFICES OF JUSTIN H. KING By:_/s/ Justin H. King 4 JUSTIN H. KING

Attorneys for Plaintiffs 5 Dominique Anderson, Lela Dennis, Debr: Carr, Eiona Ford, aka Eiona Bullard, Fall 6 Richie, Crystal Chavis, and Shayprea Moore Jefferson, aka Shayprea Moore . GLASER WEIL FINK HOWARD DATED: November 23, 2021 AVCHEN & SHAPIRO Lip 11 By:_/s/ Andrew Baum ANDREW BAUM

12 MICHAEL L. SMITH

Attorneys for Defendants OV 13 County of Los Angeles, Los Angeles = County Probation Department; eputy 14 Probation Officer Ernest Walker; Deputy Probation Officer David Glasby; Deputy co 15 Probation Officer Jeffrey Eckler; an rh Deputy Probation Officer/Deputy Service UO 16 Officer Erin Walton | DATED: November 23, 2021 LYNBERG & WATKINS

18 By:_/s/ Michael J. Larin 19 MICHAEL J. LARIN

PHILLIP M. HAYES

50 Attorneys for Defendant __ Crittenton Services for Children and Families Group Home | DATED: November 23, 2021 HUPRICH | VEGA, ATTORNEYS AT LAW 24 By:_/s/ Joseph Huprich 35 JOSEPH HUPRICH

Attorneys for Defendant 26 John Evans ' [FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

3 |IDated: 11/24/2021 ; [HONORABLE JOHN E. MCDERMOTT , United States Magistrate Judge

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I EXHIBIT A > ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3 I, , of , declare unde penalty of perjury that I have read in its entirety and understand the Stipulated | Protective Order that was issued by the United States District Court for the Central {District of California on in the case Dominique Anderson v. County o Los Angeles, et al. (Case No. 2:21-cv-05966-MCS-JEM). I agree to comply with anc | 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 not disclose in any manner any information or item that is subject to this Stipulated Protective Order to any VY)

1S person or entity except in strict compliance with the provisions of this Order. 4 I agree to submit to the jurisdiction of the United States District Court for the ig |Central District of California for the purpose of enforcing the terms of this Stipulated '? Protective Order, even if such enforcement proceedings occur after termination of thi action. I hereby appoint of é 22 California agent for service of process in connection with this action or any proceedings related to enforcement of this Stipulated Protective Order.

Date:

26 ||City and State where sworn and signed:

27 |:

Printed Name: Signature: