Case 2:21-cv-07607-RGK-JEM Document 22 Filed 02/01/22 Page 1 of 17 Page ID #:134

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17 18 UNITED STATES DISTRICT COURT 19 CENTRAL DISTRICT OF CALIFORNIA

20 KIMBERLY MARROQUIN, Case No. 2:21-cv-07607-RGK-JEM 21 Plaintiff, vs. STIPULATED PROTECTIVE ORDER 22

23 UNIDENTIFIED LAPD OFFICER; Referred for Discovery Purposes to the CAPTAIN RICHARD PAUL STABILE; CITY OF LOS Honorable John E. McDermott 24 ANGELES,

25 Defendants. 26 27 28 1 STIPULATED PROTECTIVE ORDER Case 2:21-cv-07607-RGK-JEM Document 22 Filed 02/01/22 Page 2 of 17 Page ID #:135

1 Plaintiff Kimberly Marrouqin (“Plaintiff”) and Defendants City of Los Angeles 2 and Captain Richard Paul Stabile (“Defendants”) (collectively, “the parties”) jointly 3 present this Stipulated Protective Order for the Court’s approval. 4 1. INTRODUCTION 5 1.1 PURPOSES AND LIMITATIONS 6 Discovery in this action is likely to involve production of confidential, 7 proprietary, or private information for which special protection from public disclosure 8 and from use for any purpose other than prosecuting this litigation may be warranted. 9 Accordingly, the parties hereby stipulate to and petition the Court to enter the following 10 Stipulated Protective Order. The parties acknowledge that this Order does not confer 11 blanket protections on all disclosures or responses to discovery and that the protection 12 it affords from public disclosure and use extends only to the limited information or 13 items that are entitled to confidential treatment under the applicable legal principles. 14 The parties further acknowledge, as set forth in Section 12.3, below, that this Stipulated 15 Protective Order does not entitle them to file confidential information under seal; Civil 16 Local Rule 79-5 sets forth the procedures that must be followed and the standards that 17 will be applied when a party seeks permission from the court to file material under seal. 18 1.2 GOOD CAUSE STATEMENT 19 This action involves the City of Los Angeles and members of the Los Angeles 20 Police Department on the one side and on the other side, Plaintiff Kimberly Marroquin 21 (“Plaintiff”), who is claiming damages from the City and its officers for past and future 22 medical expenses, loss of earnings, emotional distress, mental suffering, and other 23 unspecified general damages allegedly caused by Defendants. Defendants will seek in 24 this action discovery of various information relating to Plaintiff's damages claims, 25 including employment and medical information that may be very personal, private, and 26 potentially embarrassing to her if it were to be unnecessarily disseminated. Plaintiffs 27 are seeking materials and information that Defendant the City of Los Angeles 28 (including its Police Department) maintains as confidential, such as personnel files of 2 STIPULATED PROTECTIVE ORDER Case 2:21-cv-07607-RGK-JEM Document 22 Filed 02/01/22 Page 3 of 17 Page ID #:136

1 police officers, Internal Affairs materials and information, Force Investigation Division 2 materials and information and other administrative materials and information currently 3 in the possession of the City and which the City believes need special protection from 4 public disclosure and from use for any purpose other than prosecuting this litigation. 5 Some of this information may also implicate the privacy rights of persons not a party 6 to this lawsuit. Plaintiff is also seeking official information contained in the personnel 7 files of the police officers involved in the subject incident, which the City maintains as 8 strictly confidential and which the City believes needs special protection from public 9 disclosure and from use for any purpose other than prosecuting this litigation. 10 The parties, therefore, stipulate that some of the information into which 11 discovery will be sought in this case is protected by various parties' and (third parties) 12 privacy rights under state and federal law. In addition, the confidentiality of the 13 materials and information sought by Plaintiff is recognized by California and federal 14 law. The City has not publicly released such materials except under protective order or 15 pursuant to a court order, if at all. These materials and information are of the type that 16 has been used to initiate disciplinary action against Los Angeles Police Department 17 ("LAPD") officers and has been used as evidence in disciplinary proceedings, where 18 the officers' conduct was considered to be contrary to LAPD policy. 19 THIS STIPULATED PROTECTIVE ORDER EXPRESSLY EXCLUDES 20 RECORDINGS FROM OFFICERS' BODY-WORN CAMERAS UNLESS 21 OTHERWISE SPECIFICALLY AGREED BY THE PARTIES IN A SEPARATE 22 WRITING, OR AS OTHERWISE ORDERED BY THE COURT. 23 Absent a protective order delineating the responsibilities of nondisclosure on the 24 part of the parties hereto, there is a specific risk of unnecessary and undue disclosure 25 by one or more of the many attorneys, secretaries, law clerks, paralegals and expert 26 witnesses involved in this case, as well as the corollary risk of embarrassment, 27 harassment and professional and legal harm on the part of Plaintiffs, Defendants, other 28 3 STIPULATED PROTECTIVE ORDER Case 2:21-cv-07607-RGK-JEM Document 22 Filed 02/01/22 Page 4 of 17 Page ID #:137

1 LAPD officers, and non-party civilians who may be referenced in the materials and 2 information. 3 Accordingly, to expedite the flow of information, to facilitate the prompt 4 resolution of disputes over the confidentiality of discovery materials, to adequately 5 protect information the parties are entitled to keep confidential, to ensure that the 6 parties are permitted reasonable necessary uses of such material in preparation for and 7 in the conduct of trial, to address their handling at the end of the litigation, and serve 8 the ends of justice, a protective order for such information is justified in this matter. It 9 is the intent of the parties that information will not be designated as confidential for 10 tactical reasons and that nothing be so designated without a good faith belief that it has 11 been maintained in a confidential, non-public manner, and there is good cause why it 12 should not be part of the public record of this case. 13 2. DEFINITIONS 14 2.1 Action: Kimberly Marrouqin v. City of Los Angeles, et al., USDC Case 15 No. 2:21-cv-07607-RGK-JEM. 16 2.2 Challenging Party: a Party or Non-Party that challenges the designation 17 of information or items under this Order. 18 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 19 how it is generated, stored or maintained) or tangible things that qualify for protection 20 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 21 Statement. 22 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 23 support staff). 24 2.5 Designating Party: a Party or Non-Party that designates information or 25 items that it produces in disclosures or in responses to discovery as 26 “CONFIDENTIAL.” 27 28 4 STIPULATED PROTECTIVE ORDER Case 2:21-cv-07607-RGK-JEM Document 22 Filed 02/01/22 Page 5 of 17 Page ID #:138

1 2.6 Disclosure or Discovery Material: all items or information, regardless 2 of the medium or manner in which it is generated, stored, or maintained (including, 3 among other things, testimony, transcripts, and tangible things), that are produced or 4 generated in disclosures or responses to discovery in this matter. 5 2.7 Expert: a person with specialized knowledge or experience in a matter 6 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 7 expert witness or as a consultant in this Action. 8 2.8 House Counsel: attorneys who are employees of a party to this Action. 9 House Counsel does not include Outside Counsel of Record or any other outside 10 counsel. 11 2.9 Non-Party: any natural person, partnership, corporation, association, or 12 other legal entity not named as a Party to this action. 13 2.10 Outside Counsel of Record: attorneys who are not employees of a party 14 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 that has 16 appeared on behalf of that party, and includes support staff. 17 2.11 Party: any party to this Action, including all of its officers, directors, 18 employees, consultants, retained experts, and Outside Counsel of Record (and their 19 support staffs). 20 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 21 Discovery Material in this Action. 22 2.13 Professional Vendors: persons or entities that provide litigation support 23 services (e.g., photocopying, videotaping, translating, preparing exhibits or 24 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 25 their employees and subcontractors. 26 2.14 Protected Material: any Disclosure or Discovery Material that is 27 designated as “CONFIDENTIAL.” 28 5 STIPULATED PROTECTIVE ORDER Case 2:21-cv-07607-RGK-JEM Document 22 Filed 02/01/22 Page 6 of 17 Page ID #:139

1 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 2 from a Producing Party. 3 3. SCOPE 4 The protections conferred by this Stipulation and Order cover not only Protected 5 Material (as defined above), but also (1) any information copied or extracted from 6 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 7 Material; and (3) any testimony, conversations, or presentations by Parties or their 8 Counsel that might reveal Protected Material. 9 Any use of Protected Material at trial will be governed by the orders of the trial 10 judge. This Order does not govern the use of Protected Material at trial. 11 4. DURATION 12 Even after final disposition of this litigation, the confidentiality obligations 13 imposed by this Order will remain in effect until a Designating Party agrees otherwise 14 in writing or a court order otherwise directs. Final disposition will be deemed to be the 15 later of (1) dismissal of all claims and defenses in this Action, with or without 16 prejudice; and (2) final judgment hereinafter the completion and exhaustion of all 17 appeals, rehearings, remands, trials, or reviews of this Action, including the time limits 18 for filing any motions or applications for extension of time pursuant to applicable law. 19 However, once a case proceeds to trial, information that was designated as 20 CONFIDENTIAL or maintained pursuant to this protective order used or introduced 21 as an exhibit at trial becomes public and will be presumptively available to all members 22 of the public, including the press, unless compelling reasons supported by specific 23 factual findings to proceed otherwise are made to the trial judge in advance of the trial. 24 See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” showing for sealing 25 documents produced in discovery from “compelling reasons” standard when merits- 26 related documents are part of court record). Accordingly, the terms of this protective 27 order do not extend beyond the commencement of the trial as to the CONFIDENTIAL 28 information and materials introduced or admitted as an exhibit at trial. 6 STIPULATED PROTECTIVE ORDER Case 2:21-cv-07607-RGK-JEM Document 22 Filed 02/01/22 Page 7 of 17 Page ID #:140

1 5. DESIGNATING PROTECTED MATERIAL 2 5.1 Exercise of Restraint and Care in Designating Material for 3 Protection. Each Party or Non-Party that designates information or items for 4 protection under this Order must take care to limit any such designation to specific 5 material that qualifies under the appropriate standards. The Designating Party must 6 designate for protection only those parts of material, documents, items, or oral or 7 written communications that qualify so that other portions of the material, documents, 8 items, or communications for which protection is not warranted are not swept 9 unjustifiably within the ambit of this Order. 10 Mass, indiscriminate, or routinized designations are prohibited. Designations 11 that are shown to be clearly unjustified or that have been made for an improper purpose 12 (e.g., to unnecessarily encumber the case development process or to impose 13 unnecessary expenses and burdens on other parties) may expose the Designating Party 14 to sanctions. 15 If it comes to a Designating Party’s attention that information or items that it 16 designated for protection do not qualify for protection, that Designating Party must 17 promptly notify all other Parties that it is withdrawing the inapplicable designation. 18 5.2 Manner and Timing of Designations. Except as otherwise provided in 19 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 20 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 21 under this Order must be clearly so designated before the material is disclosed or 22 produced. 23 Designation in conformity with this Order requires: 24 (a) for information in documentary form (e.g., paper or electronic documents, 25 but excluding transcripts of depositions or other pretrial or trial proceedings), that the 26 Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 27 “CONFIDENTIAL legend”), to each page that contains protected material. If only a 28 portion or portions of the material on a page qualifies for protection, the Producing 7 STIPULATED PROTECTIVE ORDER Case 2:21-cv-07607-RGK-JEM Document 22 Filed 02/01/22 Page 8 of 17 Page ID #:141

1 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 2 markings in the margins). 3 A Party or Non-Party that makes original documents available for 4 inspection need not designate them for protection until after the inspecting Party has 5 indicated which documents it would like copied and produced. During the inspection 6 and before the designation, all of the material made available for inspection will be 7 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents 8 it wants copied and produced, the Producing Party must determine which documents, 9 or portions thereof, qualify for protection under this Order. Then, before producing the 10 specified documents, the Producing Party must affix the “CONFIDENTIAL legend” 11 to each page that contains Protected Material. If only a portion or portions of the 12 material on a page qualifies for protection, the Producing Party also must clearly 13 identify the protected portion(s) (e.g., by making appropriate markings in the margins). 14 (b) for testimony given in depositions that the Designating Party identify the 15 Disclosure or Discovery Material on the record, before the close of the deposition all 16 protected testimony. 17 (c) for information produced in some form other than documentary and for any 18 other tangible items, that the Producing Party affix in a prominent place on the exterior 19 of the container or containers in which the information is stored the legend 20 “CONFIDENTIAL.” If only a portion or portions of the information warrants 21 protection, the Producing Party, to the extent practicable, will identify the protected 22 portion(s). 23 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 24 failure to designate qualified information or items does not, standing alone, waive the 25 Designating Party’s right to secure protection under this Order for such material. Upon 26 timely correction of a designation, the Receiving Party must make reasonable efforts 27 to assure that the material is treated in accordance with the provisions of this Order. 28 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 8 STIPULATED PROTECTIVE ORDER Case 2:21-cv-07607-RGK-JEM Document 22 Filed 02/01/22 Page 9 of 17 Page ID #:142

1 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 2 designation of confidentiality at any time that is consistent with the Court’s Scheduling 3 Order. 4 6.2 Meet and Confer. The Challenging Party will initiate the dispute 5 resolution process (and, if necessary, file a discovery motion) under Local Rule 37.1 et 6 seq. 7 6.3 The burden of persuasion in any such challenge proceeding will be on the 8 Designating Party. Frivolous challenges and those made for an improper purpose (e.g., 9 to harass or impose unnecessary expenses and burdens on other parties) may expose 10 the Challenging Party to sanctions. Unless the Designating Party has waived or 11 withdrawn the confidentiality designation, all parties will continue to afford the 12 material in question the level of protection to which it is entitled under the Producing 13 Party’s designation until the Court rules on the challenge. 14 7. ACCESS TO AND USE OF PROTECTED MATERIAL 15 7.1 Basic Principles. A Receiving Party may use Protected Material that is 16 disclosed or produced by another Party or by a Non-Party in connection with this 17 Action only for prosecuting, defending, or attempting to settle this Action. Such 18 Protected Material may be disclosed only to the categories of persons and under the 19 conditions described in this Order. When the Action has been terminated, a Receiving 20 Party must comply with the provisions of section 13 below (FINAL DISPOSITION). 21 Protected Material must be stored and maintained by a Receiving Party at a 22 location and in a secure manner that ensures that access is limited to the persons 23 authorized under this Order. 24 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 25 otherwise ordered by the court or permitted in writing by the Designating Party, a 26 Receiving Party may disclose any information or item designated “CONFIDENTIAL” 27 only to: 28 9 STIPULATED PROTECTIVE ORDER Case 2:21-cv-07607-RGK-JEM Document 22 Filed 02/01/22 Page 10 of 17 Page ID #:143

1 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 2 as employees of said Outside Counsel of Record to whom it is reasonably necessary to 3 disclose the information for this Action; 4 (b) the officers, directors, and employees (including House Counsel) of the 5 Receiving Party to whom disclosure is reasonably necessary for this Action; 6 (c) Experts (as defined in this Order) of the Receiving Party to whom 7 disclosure is reasonably necessary for this Action and who have signed the 8 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 9 (d) the Court and its personnel; 10 (e) court reporters and their staff; 11 (f) professional jury or trial consultants, mock jurors, and Professional 12 Vendors to whom disclosure is reasonably necessary for this Action and who have 13 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 14 (g) the author or recipient of a document containing the information or a 15 custodian or other person who otherwise possessed or knew the information; 16 (h) during their depositions, witnesses, and attorneys for witnesses, in the 17 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 18 requests that the witness signs the form attached as Exhibit A hereto; and (2) they will 19 not be permitted to keep any confidential information unless they sign the 20 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed 21 by the Designating Party or ordered by the court. Pages of transcribed deposition 22 testimony or exhibits to depositions that reveal Protected Material may be separately 23 bound by the court reporter and may not be disclosed to anyone except as permitted 24 under this Stipulated Protective Order; and 25 (i) any mediator or settlement officer, and their supporting personnel, 26 mutually agreed upon by any of the parties engaged in settlement discussions. 27 /// 28 /// 10 STIPULATED PROTECTIVE ORDER Case 2:21-cv-07607-RGK-JEM Document 22 Filed 02/01/22 Page 11 of 17 Page ID #:144

1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 2 IN OTHER LITIGATION 3 If a Party is served with a subpoena or a court order issued in other litigation that 4 compels disclosure of any information or items designated in this Action as 5 “CONFIDENTIAL,” that Party must: 6 (a) promptly notify in writing the Designating Party. Such notification will 7 include a copy of the subpoena or court order; 8 (b) promptly notify in writing the party who caused the subpoena or order to 9 issue in the other litigation that some or all of the material covered by the subpoena or 10 order is subject to this Protective Order. Such notification will include a copy of this 11 Stipulated Protective Order; and 12 (c) cooperate with respect to all reasonable procedures sought to be pursued 13 by the Designating Party whose Protected Material may be affected. 14 If the Designating Party timely seeks a protective order, the Party served with 15 the subpoena or court order will not produce any information designated in this action 16 as “CONFIDENTIAL” before a determination by the court from which the subpoena 17 or order issued, unless the Party has obtained the Designating Party’s permission. The 18 Designating Party will bear the burden and expense of seeking protection in that court 19 of its confidential material and nothing in these provisions should be construed as 20 authorizing or encouraging a Receiving Party in this Action to disobey a lawful 21 directive from another court. 22 9. 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- 25 Party in this Action and designated as “CONFIDENTIAL.” Such information 26 produced by Non-Parties in connection with this litigation is protected by the remedies 27 and relief provided by this Order. Nothing in these provisions should be construed as 28 prohibiting a Non-Party from seeking additional protections. 11 STIPULATED PROTECTIVE ORDER Case 2:21-cv-07607-RGK-JEM Document 22 Filed 02/01/22 Page 12 of 17 Page ID #:145

1 (b) In the event that a Party is required, by a valid discovery request, to 2 produce a Non-Party’s confidential information in its possession, and the Party is 3 subject to an agreement with the Non-Party not to produce the Non-Party’s confidential 4 information, then the Party will: 5 (1) promptly notify in writing the Requesting Party and the Non-Party 6 that some or all of the information requested is subject to a confidentiality agreement 7 with a Non-Party; 8 (2) promptly provide the Non-Party with a copy of the Stipulated 9 Protective Order in this Action, the relevant discovery request(s), and a reasonably 10 specific description of the information requested; and 11 (3) make the information requested available for inspection by the Non- 12 Party, if requested. 13 (c) If the Non-Party fails to seek a protective order from this court within 14 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 request. 16 If the Non-Party timely seeks a protective order, the Receiving Party will not produce 17 any information in its possession or control that is subject to the confidentiality 18 agreement with the Non-Party before a determination by the court. Absent a court 19 order to the contrary, the Non-Party will bear the burden and expense of seeking 20 protection in this court of its Protected Material. 21 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 22 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 23 Protected Material to any person or in any circumstance not authorized under this 24 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 25 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 26 all unauthorized copies of the Protected Material, (c) inform the person or persons to 27 whom unauthorized disclosures were made of all the terms of this Order, and (d) 28 12 STIPULATED PROTECTIVE ORDER Case 2:21-cv-07607-RGK-JEM Document 22 Filed 02/01/22 Page 13 of 17 Page ID #:146

1 request such person or persons to execute the “Acknowledgment and Agreement to Be 2 Bound” that is attached hereto as Exhibit A. 3 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 4 PROTECTED MATERIAL 5 When a Producing Party gives notice to Receiving Parties that certain 6 inadvertently produced material is subject to a claim of privilege or other protection, 7 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 8 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 9 may be established in an e-discovery order that provides for production without prior 10 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 11 parties reach an agreement on the effect of disclosure of a communication or 12 information covered by the attorney-client privilege or work-product protection, the 13 parties may incorporate their agreement in the stipulated protective order submitted to 14 the court. 15 12. MISCELLANEOUS 16 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 17 person to seek its modification by the Court in the future. 18 12.2 Right to Assert Other Objections. By stipulating to the entry of this 19 Protective Order no Party waives any right it otherwise would have to object to 20 disclosing or producing any information or item on any ground not addressed in this 21 Stipulated Protective Order. Similarly, no Party waives any right to object on any 22 ground to use in evidence of any of the material covered by this Protective Order. 23 12.3 Filing Protected Material. A Party that seeks to file under seal any 24 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 25 only be filed under seal pursuant to a court order authorizing the sealing of the specific 26 Protected Material at issue. If a Party's request to file Protected Material under seal is 27 denied by the court, then the Receiving Party may file the information in the public 28 record unless otherwise instructed by the court. 13 STIPULATED PROTECTIVE ORDER Case 2:21-cv-07607-RGK-JEM Document 22 Filed 02/01/22 Page 14 of 17 Page ID #:147

1 13. FINAL DISPOSITION 2 After the final disposition of this Action, as defined in paragraph 4, within 60 3 days of a written request by the Designating Party, each Receiving Party must return 4 all Protected Material to the Producing Party or destroy such material. As used in this 5 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 6 summaries, and any other format reproducing or capturing any of the Protected 7 Material. Whether the Protected Material is returned or destroyed, the Receiving Party 8 must submit a written certification to the Producing Party (and, if not the same person 9 or entity, to the Designating Party) by the 60-day deadline that (1) identifies (by 10 category, where appropriate) all the Protected Material that was returned or destroyed 11 and (2) affirms that the Receiving Party has not retained any copies, abstracts, 12 compilations, summaries or any other format reproducing or capturing any of the 13 Protected Material. Notwithstanding this provision, Counsel are entitled to retain an 14 archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, 15 legal memoranda, correspondence, deposition and trial exhibits, expert reports, 16 attorney work product, and consultant and expert 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).

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1 14. Any willful violation of this Order may be punished by civil or criminal 2 contempt proceedings, financial or evidentiary sanctions, reference to disciplinary 3 authorities or other appropriate action at the discretion of the Court. 4 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 5

6 DATED: January 31, 2022 THE LAW OFFICE OF KEVIN S. 7 CONLOGUE HINMAN LAW GROUP, P.C. 8 9 10 By: /s/ Kevin S. Conlogue 11 Ashley M. Conlogue John S. Hinman 12 Seth E. Workman Attorney for Plaintiff Kimberly Marrouqin 13

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15 DATED: January 31, 2022 STONE BUSAILAH, LLP 16 17 18 By: /s/ Muna Busailah 19 Attorney for Defendants City of Los Angeles and Richard Paul Stabile 20

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1 ATTESTATION 2 Pursuant to Local Rule 5-4.3.4(a)(2)(), I attest that all other signatories listed, 3 |/and on whose behalf the filing is submitted, concur in the filing’s content and have 4 | authorized the filing. 6 | DATED: January 31, 2022 STONE BUSAILAH, LLP By: /s/ 7 Muna Busailah 8 Attorney for Defendants City of Los __ Angeles and Captain Richard Paul Stabile 10 | FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 11 = : 12. | Dated: 2/1/2022 & Mio 3 NORABLE John E. McDermott United States Magistrate Judge 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

STIPULATED PROTECTIVE ORDER

Case 2:21-cv-07607-RGK-JEM Document 22 Filed 02/01/22 Page 17 of 17 Page ID #:150

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, _____________________________ [full name], of _________________ 4 [full address], declare under penalty of perjury that I have read in its entirety and 5 understand the Stipulated Protective Order that was issued by the United States District 6 Court for the Central District of California on [date] in the case of Kimberly Marrouqin 7 v. City of Los Angeles, et al., USDC Case No. 2:21-cv-07607-RGK-JEM. I agree to 8 comply with and to be bound by all the terms of this Stipulated Protective Order and I 9 understand and acknowledge that failure to so comply could expose me to sanctions 10 and punishment in the nature of contempt. I solemnly promise that I will not disclose 11 in any manner any information or item that is subject to this Stipulated Protective Order 12 to any person or entity except in strict compliance with the provisions of this Order. 13 I further agree to submit to the jurisdiction of the United States District Court 14 for the Central District of California for the purpose of enforcing the terms of this 15 Stipulated Protective Order, even if such enforcement proceedings occur after 16 termination of this action. I hereby appoint __________________________ [full 17 name] of _______________________________________ [full address and 18 telephone number] as my California agent for service of process in connection with 19 this action or any proceedings related to enforcement of this Stipulated Protective 20 Order. 21 Date: ______________________________________ 22 City and State where signed: _________________________________ 23 24 Printed name: _______________________________ 25 26 Signature: ________

27 28 17 STIPULATED PROTECTIVE ORDER