Case 2:21-cv-02115-DSF-JC Document 41 Filed 03/09/22 Page1of18 Page ID #:263 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 || ERICA MORA, an individual, Case No. 2:21-CV-02115 DSF (JCx) 12 Plaintiff, [Assigned to Judge Dale S. Fisher, 3 ourtroom 7D] V. MODIFIED STIPULATED 14 | CITY OF LOS ANGELES, a PROTECTIVE ORDER RE: municipal entity, COUNTY OF LOS DISCLOSURE OF CONFIDENTIAL 15 || ANGELES, a municipal entity; DOES | INFORMATION 1-20, inclusive, individually and in 16 || their official capacities as police [Discovery Document: Referred to _ officers for the Los Angeles Police agistrate Judge Jacqueline Chooljian] 17 Department, and DOES 21-40, inclusive, individually and in their | [CHANGE MADE TO § 6.1] 18 || Official capacities as sheriffs deputies for the Los Angeles County Sheriff's 19 || Department, 20 Defendants. 21 22] 1. GENERAL 23 1.1. Purposes and Limitations. 24 Discovery in this action is likely to involve production of confidential, 25 || proprietary, and/or private information for which special protection from public 26 || disclosure and/or from use for any purpose other than prosecuting this litigation 27 || may be warranted. Accordingly, the parties to this action (hereinafter, the “Parties” 28 || collectively and a “Party” individually) hereby stipulate to and petition the Court to BURKE, WILLIAMS & Anions artaw #4886-1002-6514 v1 STIPULATED PROTECTIVE ORDER

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1 || enter the following Stipulated Protective Order. The Parties acknowledge that this 2 || Order does not confer blanket protections on all disclosures or responses to 3 || discovery, and that the protections it affords from public disclosure and use extends 4 || only to the limited information or items that are entitled to confidential treatment 5 || under the applicable legal principles and/or under this Stipulated Protective Order. 6 The Parties agree that any disclosures pursuant to the instant Stipulated 7 || Protective Order shall not be construed as a waiver of applicable privilege with 8 || regard to any subsequent third-party litigants. The Parties further agree that the 9 || production of documents pursuant to the instant Stipulated Protective Order has no 10 || bearing on their admissibility. Thus, documents otherwise admissible remain 11 || admissible, and documents otherwise inadmissible remain inadmissible. 12 1.2 Good Cause Statement. 13 This action involves the City of Los Angeles and members of the Los 14 || Angeles Police Department, as well as the County of Los Angeles and members of 15 || the Los Angeles County Sheriff’s Department. Plaintiff is seeking materials and 16 || information that Defendants City of Los Angeles and County of Los Angeles 17 || (collectively, “Defendants’’) maintain as confidential, such as personnel files of the 18 || law enforcement officers involved in the subject incident, Internal Affairs materials 19 || and information, video recordings (including Body-Worn Video recordings and 20 || Digital In-Car Video recordings), audio recordings, and information and other 21 || administrative materials and information currently in the possession of the 22 || Defendants and that the Defendants believe needs special protection from public 23 || disclosure and from use for any purpose other than prosecuting this litigation. 24 || Plaintiff may also seek official information contained in the personnel files of the 25 || law enforcement officers involved in the subject incident, which the Defendants 26 || maintain as strictly confidential and which the Defendants believe needs special 27 || protection from public disclosure and from use for any purpose other than 28 || prosecuting this litigation. “Sorin LLP . LA #4886-1002-6514 v1 STIPULATED PROTECTIVE ORDER

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l Defendants assert that the confidentiality of the materials and information 2 || sought by Plaintiff is recognized by California and federal law, as evidenced by, 3 || inter alia, California Penal Code section 832.7 and Kerr v. United States Dist. Ct. 4 || for N.D. Cal.,

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

(1976). 5 || Defendants have not publicly released the materials and information referenced 6 || above except under protective order or pursuant to a court order, if at all. These 7 || materials and information are of the type that has been used to initiate disciplinary 8 || action against Defendants’ officers, and has been used as evidence in disciplinary 9 || proceedings, where the officers’ conduct was considered to be contrary to policy. 10 Defendants contend that, absent a protective order delineating the 11 || responsibilities of nondisclosure on the part of the Parties hereto, there is a specific 12 || risk of unnecessary and undue disclosure by one or more of the many attorneys, 13 || secretaries, law clerks, paralegals, and/or expert witnesses involved in this case, as 14 || well as the corollary risk of embarrassment, harassment, and/or professional and/or 15 || legal harm on the part of the officers referenced in the materials and information. 16 Accordingly, to expedite the flow of information, to facilitate the prompt 17 || resolution of disputes over confidentiality of discovery materials, to adequately 18 || protect information the Parties are entitled to keep confidential, to ensure that the 19 || Parties are permitted reasonably necessary uses of such material in preparation for 20 || and in the conduct of trial, to address their handling at the end of the litigation, and 21 || to serve the ends of justice, a protective order for such information 1s justified in 22 || this matter. It is the intent of the Parties that information will not be designated as 23 || confidential for tactical reasons and that nothing be so designated without a good- 24 || faith belief that the information and/or documents in question have been maintained 25 || ina confidential, non-public manner, and that there is good cause why it should not 26 || be part of the public record of this case. 27 | /// 28 | /// “Sorin LLP . LA #4886-1002-6514 v1 STIPULATED PROTECTIVE ORDER

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1 || 2. DEFINITIONS 2 2.1. Action: Erica Mora v. City of Los Angeles, et al., Case No. 2:21-CV- 3 || 02115 DSF (JCx). 4 2.2 Challenging Party: A Party or Non-Party that challenges the 5 || designation of information or items under this Order. 6 2.33 “CONFIDENTIAL” Information or Items: Information (regardless 7 || of how it is generated, stored, or maintained) or tangible things that qualify for 8 || protection under Fed.R.Civ.P. Rule 26(c), and/or as specified above in the Good 9 || Cause Statement. This also includes (1) any information copied or extracted from 10 || the Confidential information; (2) all copies, excerpts, summaries, abstracts, or 11 || compilations of Confidential information; and (3) any testimony, conversations, or 12 || presentations that might reveal Confidential information. 13 2.4 Counsel: Counsel of record for the Parties to this civil litigation and 14 || their support staff. 15 2.5 Designating Party: A Party or Non-Party that designates information 16 || or items that it produces in disclosures or in responses to discovery as 17 || “CONFIDENTIAL.” 18 2.6 Disclosure or Discovery Material: All items or information, 19 || regardless of the medium or manner in which it is generated, stored, or maintained 20 || (including, among other things, testimony, transcripts, and tangible things), that are 21 || produced or generated in disclosures or responses to discovery in this matter. 22 2.7 Expert: A person with specialized knowledge or experience in a 23 || matter pertinent to the litigation who has been retained by a Party or its counsel to 24 || serve as an expert witness or as a consultant in this Action. 25 2.8 House Counsel: Attorneys other than Counsel (as defined in 26 || paragraph 2.4) and who are employees of a Party to this Action. 27 2.9 Non-Party: Any natural person, partnership, corporation, association, 28 || or other legal entity not named as a Party to this action. “Sorin LLP . LA #4886-1002-6514 v1 □□□ STIPULATED PROTECTIVE ORDER

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1 2.10 Outside Counsel of Record: Attorneys who are not employees of a 2 || Party to this Action but are retained to represent or advise a Party to this Action and 3 || have appeared in this Action on behalf of that Party or are affiliated with a law firm 4 || that has appeared on behalf of that Party, and includes support staff. 5 2.11 Party: Any Party to this Action, including all of its officers, directors, 6 || boards, departments, divisions, employees, consultants, retained experts, and 7 || Outside Counsel of Record (and their support staffs). 8 2.12 Producing Party: A Party or Non-Party that produces Disclosure or 9 || Discovery Material in this Action. 10 2.13 Professional Vendors: Persons or entities that provide litigation 11 || support services (e.g., photocopying, videotaping, translating, preparing exhibits or 12 || demonstrations, and organizing, storing, or retrieving data in any form or medium) 13 || and their employees and subcontractors. 14 2.14 Protected Material: Any Disclosure or Discovery Material that is 15 || designated as “CONFIDENTIAL.” 16 2.15 Receiving Party: A Party that receives Disclosure or Discovery 17 || Material from a Producing Party. 18 || 3. SCOPE 19 The protections conferred by this Stipulation and Order cover not only 20 || Protected Material (as defined above), but also (1) any information copied or 21 || extracted from Protected Material; (2) all copies, excerpts, abstracts, summaries, or 22 || compilations of Protected Material; and (3) any testimony, conversations, or 23 || presentations by Parties or their Counsel that might reveal Protected Material, other 24 || than during a court hearing or at trial. 25 Any use of Protected Material during a court hearing or at trial shall be 26 || governed by the orders of the presiding judge. This Order does not govern the use 27 || of Protected Material during a court hearing or at trial. 28 || /// “Sorin LLP . LA #4886-1002-6514 vI STIPULATED PROTECTIVE ORDER

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1 || 4. DURATION 2 Even after final disposition of this litigation, the confidentiality obligations 3 || imposed by this Order shall remain in effect until a Designating Party agrees 4 || otherwise in writing or a court order otherwise directs. Final disposition shall be 5 || deemed to be the later of (1) dismissal of all claims and defenses in this Action, 6 || with or without prejudice; or (2) final judgment herein after the completion and 7 || exhaustion of all appeals, re-hearings, remands, 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 || 5. DESIGNATING PROTECTED MATERIAL 11 5.1 Exercise of Restraint and Care in Designating Material for 12 || Protection. 13 Each Party or Non-Party that designates information or items for protection 14 || under this Order must take care to limit any such designation to specific material 15 || that qualifies under the appropriate standards. The Designating Party must 16 || designate for protection only those parts of material, documents, items, or oral or 17 || written communications that qualify, so that other portions of the material, 18 || documents, items, or communications for which protection is not warranted are not 19 || swept unjustifiably within the ambit of this Order. 20 Mass, indiscriminate, and/or routinized designations are prohibited. 21 || Designations that are shown to be clearly unjustified or that have been made for an 22 || improper purpose (e.g., to unnecessarily encumber the case-development process or 23 || to impose unnecessary expenses and burdens on other Parties) may expose the 24 || Designating Party 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, the Designating Party must 27 || promptly notify all other Parties that it is withdrawing the inapplicable designation. 28 /// “Sorin LLP . LA #4886-1002-6514 v1 STIPULATED PROTECTIVE ORDER

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1 5.2. Manner and Timing of Designations. Except as otherwise provided 2 || in this Order (see, e.g., second paragraph of section 5.2(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 8 || documents, but excluding transcripts of depositions or other pretrial or trial 9 || proceedings), that the Producing Party affix, at a minimum, the legend 10 || “CONFIDENTIAL” or words of a similar effect, and the case name and case 11 || number (hereinafter “CONFIDENTIAL legend”), to each page that contains 12 || protected material. If only a portion of the material on a page qualifies for 13 || protection, the Producing Party also must clearly identify the protected portion(s) 14 || (e.g., by making appropriate markings in the margins). 15 (b) For testimony given in depositions, that the Designating Party 16 || identifies the Disclosure or Discovery Material on the record, before the close of 17 || the deposition. 18 (c) For information produced in some form other than documentary 19 || and for any other tangible items, that the Producing Party affix in a prominent place 20 || on the exterior of the container or containers in which the information is stored the 21 || legend “CONFIDENTIAL.” If only a portion or portions of the information 22 || warrants protection, the Producing Party, to the extent practicable, shall identify the 23 || protected portion(s). 24 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 25 || failure to designate qualified information or items does not, standing alone, waive 26 || the Designating Party’s right to secure protection under this Order for such 27 || material. Upon timely correction of a designation, the Receiving Party must make 28 |) /// “Sorin LLP . LA #4886-1002-6514 v1 STIPULATED PROTECTIVE ORDER

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1 || reasonable efforts to assure that the material is treated in accordance with the 2 || provisions of this Order. 3 || 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 4 6.1. Challenges. This Order shall be without prejudice to the right of the 5 || Parties, to the extent consistent with the Court’s Scheduling Order (1) to bring 6 || before the Court the question of whether any particular document or information is 7 || confidential or whether its use should be restricted or (11) to present a motion to the 8 || Court under Fed.R.Civ.P. Rule 26(c) for a separate protective order as to any 9 || particular document or information, including restrictions differing from those as 10 || specified herein. This Order shall not be deemed to prejudice the Parties in any 11 || way in any future application or modification of this Order. 12 6.2 Timing of Challenges. Any Party or Non-Party may challenge a 13 || designation of confidentiality at any time that is consistent with the Court’s 14 || Scheduling Order. 15 6.3 Meet and Confer. The Challenging Party shall initiate the dispute 16 || resolution process under Local Rule 37.1 et seg. To avoid ambiguity as to whether 17 || a challenge has been made, the written notice pursuant to Local Rule 37.1 must 18 || recite that the challenge to confidentiality is being made in accordance with this 19 || specific paragraph of the Protective Order. The Parties shall attempt to resolve 20 || each challenge in good faith and must begin the process by conferring directly 21 || within 14 days of the date of service of notice. In conferring, the Challenging Party 22 || must explain the basis for its belief that the confidentiality designation was not 23 || proper and must give the Designating Party an opportunity to review the designated 24 || material, to reconsider the circumstances, and, if no change in designation is 25 || offered, to explain the basis for the chosen designation. A Challenging Party may 26 || seek judicial intervention only if it has engaged in this meet-and-confer process first 27 || or establishes that the Designating Party is unwilling to participate in the meet-and- 28 || confer process in a timely matter. “Sorin LLP . LA #4886-1002-6514 vI STIPULATED PROTECTIVE ORDER

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1 6.4 Burden. The burden of persuasion in any such challenge proceeding 2 || shall be on the Designating Party. Frivolous challenges, and those made for an 3 || improper purpose (e.g., to harass or impose unnecessary expenses and burdens on 4 || other Parties) may expose the Challenging Party to sanctions. Unless the 5 || Designating Party has waived or withdrawn the confidentiality designation, all 6 || Parties shall continue to afford the material in question the level of protection to 7 || which it is entitled under the Producing Party’s designation until the Court rules on 8 || the challenge. 9 || 7. ACCESS TO AND USE OF PROTECTED MATERIAL 10 7.1. Basic Principles. A Receiving Party may use Protected Material that 11 || is disclosed or produced by another Party or by a Non-Party in connection with this 12 || Action only for prosecuting, defending, or attempting to settle this Action. Such 13 || Protected Material may be disclosed only to the categories of persons and under the 14 || conditions described in this Order. When the Action has been terminated, a 15 || Receiving Party must comply with the provisions of section 13 below (FINAL 16 || DISPOSITION). 17 Protected Material must be stored and maintained by a Receiving Party at a 18 || location and in a secure manner that ensures that access is limited to the persons 19 || authorized under this Order. Receiving Parties shall take reasonable steps to 20 || prevent disclosure of Protected Material to any third party not authorized to receive 21 || the Protected Material pursuant to the terms of this Order. 22 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 23 || otherwise ordered by the court or permitted in writing by the Designating Party, a 24 || Receiving Party may disclose any information or item designated 25 || “CONFIDENTIAL” only to: 26 (a) The Receiving Party’s Counsel of Record in this Action, as well 27 || as their respective associates, clerks, legal assistants, support personnel, and 28 “Sorin LLP . LA #4886-1002-6514 vI “9 - STIPULATED PROTECTIVE ORDER

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1 || investigators and litigation support services (photocopy services or transcription 2 || services) who have signed the “Nondisclosure Agreement” (Exhibit A); 3 (b) Any designated or retained Experts (as defined in this Order) 4 || and their employees, hired by any Party who has signed the “Nondisclosure 5 || Agreement” (Exhibit A); 6 (c) The Court and its personnel; 7 (d) Court reporters and their staff; 8 (e) Professional jury or trial consultants, mock jurors, and 9 || Professional Vendors to whom disclosure is reasonably necessary for this Action 10 || and who have signed the “Nondisclosure Agreement” (Exhibit A); 11 (f) The author or recipient of a document containing the 12 || information or a custodian or other person who otherwise possessed or knew the 13 || information before it was disclosed in this Action; 14 (g) During their depositions, witnesses, and attorneys for witnesses, 15 || in the Action to whom disclosure is reasonably necessary, provided (1) the 16 || deposing party requests that the witness sign the form attached as Exhibit “A” 17 || hereto; and (2) they will not be permitted to keep any confidential information 18 || unless they sign the “Nondisclosure Agreement” (Exhibit “A’’), unless otherwise 19 || agreed by the Designating Party or ordered by the Court. Pages of transcribed 20 || deposition testimony or exhibits to depositions that reveal Protected Material may 21 || be separately bound by the court reporter and may not be disclosed to anyone 22 || except as permitted under this Stipulated Protective Order; and 23 (h) Any mediator or settlement officer, and their supporting 24 || personnel, mutually agreed upon by any of the Parties engaged in settlement 25 || discussions and who have signed the “Nondisclosure Agreement” (Exhibit A). 26 7.3 Counsel making the disclosure to any qualified person described 27 || herein shall retain the original executed copy of the Nondisclosure Agreement until 28 || sixty (60) days after this litigation has become final, including any appellate review, “Sorin LLP . LA #4886-1002-6514 vI 10 - STIPULATED PROTECTIVE ORDER

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1 || and any monitoring of an injunction. Counsel for the Receiving Party shall maintain 2 || all signed Nondisclosure Agreements and shall produce the original signature page 3 || upon reasonable written notice from opposing counsel. If an issue arises regarding a 4 || purported unauthorized disclosure of Confidential Information, upon noticed 5 || motion of contempt filed by the Designating Party, counsel for the Receiving Party 6 || may be required to file the signed Nondisclosure Agreements, as well as a list of the 7 || disclosed materials, in camera with the Court having jurisdiction of the Stipulation. 8 || 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 9 PRODUCED IN OTHER LITIGATION 10 If a Party is served with a subpoena or a court order issued in other litigation 11 || that compels disclosure of any information or items designated in this Action as 12 || “CONFIDENTIAL,” that Party must: 13 (a) Promptly notify in writing the Designating Party, including with 14 || such notice a copy of the subpoena or court order; 15 (b) Promptly notify in writing the Party who caused the subpoena or 16 || order to issue in the other litigation that some or all of the material covered by the 17 || subpoena or order is subject to this Protective Order, including with such notice a 18 || copy of this Stipulated Protective Order; and 19 (c) Cooperate with respect to all reasonable procedures sought to be 20 || pursued by the Designating Party whose Protected Material may be affected. 21 The Party served with the subpoena or court order shall not produce any 22 || information designated in this action as “CONFIDENTIAL” before a determination 23 || by the court from which the subpoena or order issued, unless the Party has obtained 24 || the Designating Party’s permission, or unless otherwise required by the law or court 25 || order. The Designating Party shall bear the burden and expense of seeking 26 || protection in that court of its confidential material and nothing in these provisions 27 || should be construed as authorizing or encouraging a Receiving Party in this Action 28 || to disobey a lawful directive from another court. “Sorin LLP . LA #4886-1002-6514 vI “ii- STIPULATED PROTECTIVE ORDER

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1 | 9 ANON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 2 PRODUCED IN THIS LITIGATION 3 (a) The terms of this Order are applicable to information produced 4 || by a Non-Party in this Action and designated as “CONFIDENTIAL.” Such 5 || information produced by Non-Parties in connection with this litigation is protected 6 || by the remedies and relief provided by this Order. Nothing in these provisions 7 || should be construed as prohibiting a Non-Party from seeking additional protections. 8 (b) Inthe event that a Party is required, by a valid discovery 9 || request, to produce a Non-Party’s confidential information in its possession, and the 10 || Party is subject to an agreement with the Non-Party not to produce the Non-Party’s 11 || confidential information, then the Party shall: 12 (1) Promptly notify in writing the Requesting Party and the 13 || Non-Party that some or all of the information requested is subject to a 14 || confidentiality agreement with a Non-Party; 15 (2) Promptly provide the Non-Party with a copy of the 16 || Stipulated Protective Order in this Action, the relevant discovery request(s), and a 17 || reasonably specific description of the information requested; and 18 (3) Make the information requested available for inspection 19 || by the Non-Party, if requested. 20 (c) Ifthe Non-Party fails to seek a protective order from this court 21 || within 14 days of receiving the notice and accompanying information, the 22 || Receiving Party may produce the Non-Party’s confidential information responsive 23 || to the discovery request. If the Non-Party timely seeks a protective order, the 24 || Receiving Party shall not produce any information in its possession or control that 25 || is subject to the confidentiality agreement with the Non-Party before a 26 || determination by the court unless otherwise required by the law or court order. 27 || Absent a court order to the contrary, the Non-Party shall bear the burden and 28 || expense of seeking protection in this court of its Protected Material. “Sorin LLP . LA #4886-1002-6514 vI “12- STIPULATED PROTECTIVE ORDER

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1 || 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 2 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 3 || Protected Material to any person or in any circumstance not authorized under this 4 || Stipulated Protective Order, the Receiving Party must immediately (a) notify in 5 || writing the Designating Party of the unauthorized disclosures, (b) use its best 6 || efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the 7 || person or persons to whom unauthorized disclosures were made of all the terms of 8 || this Order, and (d) request such person or persons to execute the “Nondisclosure 9 || Agreement” that is attached hereto as Exhibit A. 10 | 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 11 PROTECTED MATERIAL 12 When a Producing Party gives notice to Receiving Parties that certain 13 || inadvertently produced material is subject to a claim of privilege or other 14 || protection, the obligations of the Receiving Parties are those set forth in Federal 15 || Rule of Civil Procedure 26(b)(5)(B). After being notified, the Receiving Parties 16 || must (1) promptly return, sequester, or destroy the specified information and any 17 || copies it has; (i1) not use or disclose the information until the claim is resolved; and 18 || (411) take reasonable steps to retrieve the information if any Receiving Party 19 || disclosed it before being notified. This provision is not intended to modify 20 || whatever procedure may be established in an e-discovery order that provides for 21 || production without prior privilege review. Pursuant to Federal Rule of Evidence 22 || 502(d) and (e), insofar as the Parties reach an agreement on the effect of disclosure 23 || of acommunication or information covered by the attorney-client privilege or 24 || work-product protection, the Parties may incorporate their agreement in the 25 || stipulated protective order submitted to the court. 26 | 12. MISCELLANEOUS 27 12.1 Right to Further Relief. Nothing in this Order abridges the right of 28 || any person to seek its modification by the Court in the future. “Sorin LLP . LA #4886-1002-6514 vI -13- STIPULATED PROTECTIVE ORDER

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1 12.2. Non-Waiver. By stipulating to the entry of this Protective Order, no 2 || Party waives any right it otherwise would have to object to disclosing or producing 3 || any information or item on any ground not addressed in this Stipulated Protective 4 | Order. 5 12.3 Right to Assert Other Objections. By stipulating to the entry of this 6 || Protective Order, no Party waives any right it otherwise would have to object to 7 || disclosing or producing any information or item on any ground not addressed in 8 || this Stipulated Protective Order. Similarly, no Party waives any right to object on 9 || any ground to use in evidence of any of the material covered by this Protective 10 || Order. 11 12.4 Filing Protected Material. A Party may not file in the public record 12 || in this action or in any other action Protected Material without first seeking to file 13 || the Protected Material under seal pursuant to this Paragraph. A Party that seeks to 14 || file under seal any Protected Material must comply with Local Civil Rule 79-5 and 15 || this Court’s Standing Orders. Protected Material may only be filed under seal 16 || pursuant to a court order authorizing the sealing of the specific Protected Material 17 || at issue. Pursuant to Central District of California Local Rule 79-5, a sealing order 18 || will issue only upon a written application establishing that the Protected Material is 19 || entitled to protection under the law. However, only the portions of documents, 20 || including briefs, exhibits, or any other moving or opposing papers that contain 21 || Protected Material need to be filed under seal. If a Party’s request to file Protected 22 || Material under seal is denied by the court, then the Receiving Party may file the 23 || information in the public record unless otherwise instructed by the court. 24 12.5 Enforceability. The validity, construction, and performance of this 25 || Stipulated Protective Order shall be governed and construed in accordance with the 26 || laws of the State of California applicable to contracts made and to be wholly 27 || performed within such state, without giving effect to any conflict of laws provisions 28 || thereof. The federal and state courts located in California shall have sole and “Sorin LLP . LA #4886-1002-6514 v1 STIPULATED PROTECTIVE ORDER

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1 || exclusive jurisdiction over any disputes arising under, or in any way connected with 2 || or related to, the terms of this Agreement and Receiving Party: (1) consents to 3 || personal jurisdiction therein; and (11) waives the right to raise forum non conveniens 4 || or any similar objection. 5 || 13. FINAL DISPOSITION 6 After the FINAL DISPOSITION of this Action, as defined in Paragraph 4, 7 || within 30 days of a written request by the Designating Party, each Receiving Party 8 || must return all Protected Material to the Producing Party. As used in this 9 || subdivision, “all Protected Material” includes all copies, abstracts, compilations, 10 || summaries, and any other format reproducing or capturing any of the Protected 11 || Material. The Receiving Party must submit a written certification to the Producing 12 || Party (and, if not the same person or entity, to the Designating Party) by the 30 day 13 || deadline that (1) identifies (by category, where appropriate) all the Protected 14 || Material that was returned and (2) affirms that the Receiving Party has not retained 15 || any copies, abstracts, compilations, summaries or any other format reproducing or 16 || capturing any of the Protected Material. 17 | 14. VIOLATION 18 Any violation of this Order may be punished by appropriate measures, 19 || including, without limitation, contempt proceedings and/or monetary sanctions. 20 | /// 21 /// 22 | /// 23 |) /// 24 | /// 25 | /// 26 || /// 27 | /// 28 || /// “Sorin LLP . LA #4886-1002-6514 vI 71S - STIPULATED PROTECTIVE ORDER

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] IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 3 || Dated: March 2, 2022 LAW OFFICES OF JOHN L. BURRIS 5 By: /s/ DeWitt M. Lacey DeWitt M. Lacey _ 6 Attorneys for Plaintiff ERICA MORA 9 Dated: March 2, 2022 BURKE, WILLIAMS & SORENSEN, 10 I By: _/s/ Mark J. Austin 12 Mark J. Austin Attorneys for Defendant CITY OF 13 LOS ANGELES 14 15 || Dated: March 2, 2022 LAWRENCE BEACH ALLEN & CHOI, 16 17 By:_/s/ Michael D. Allen 18 Michael D. Allen Attorneys for Defendant COUNTY 19 OF LOS ANGELES 20 21 22 23 24 25 26 27 28 PGORANSEN, LLP 2:21-CV-02115 DSF (JCx) Rnomerearian EA #4886-1002-6514 v1 - 16 - STIPULATED PROTECTIVE ORDER

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l Having considered the papers, the finding that good cause exists, the Parties’ 2 || Stipulated Protective Order is granted. 3 IT IS SO ORDERED. /s/ 5 || Dated: March 9, 2022 “UN HON JACQUELINE CHOOLITAN 6 UNITED STATES MAGISTRATE JUDGE 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PSORENSEN, LLP 14 nagge-too2ces14 v1 □□ 2:21-CV-02115 DSF (JCx) Aone A La STIPULATED PROTECTIVE ORDER

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1 ATTACHMENT “A” 2 NONDISCLOSURE AGREEMENT 3 I, [print or type full name] of 4 [print or type full 5 || address] do solemnly swear that I have read in its entirety and understand the terms 6 || of the Protective Order entered in Erica Mora v. City of Los Angeles, et al., United 7 || States District Court for the Central District of California, Central Division, Case 8 || No. 2:21-CV-02115 DSF (JCx), and hereby agree to comply with and be bound by 9 || the terms and conditions of said Order. 10 I understand and acknowledge that failure to comply could expose me to 11 || sanctions and/or punishment in the nature of contempt. I promise that I will not 12 || disclose in any manner any information or item that is subject to the Protective 13 || Order to any person or entity except in compliance with the provisions of this 14 || Order. 15 I hereby consent to the jurisdiction of the United States District Court for the 16 || Central District of California for purposes of enforcing this Order, even if such 17 || enforcement proceedings occur after the termination of the Erica Mora case. 18 Dated: Signed: 19 20 21 22 23 24 25 26 27 28 “Sorin LLP . LA H4886-1002-

- STIPULATED PROTECTIVE ORDER