Case 2:20-cv-10553-PSG-KS Document 60 Filed 03/22/22 Page 1 of 19 Page ID #:570

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 TIRZAH J. FRANKLIN and JAMAR R. CASE NO. CV20-10553 VAP(KSx) FRANKLIN, individually and on behalf 12 of their minor children, M.L.F. and [Hon District Judge: Virginia A. Phillips] M.M.F., [Magistrate Judge: Karen L. Stevenson] 13 Plaintiffs, 14 vs. [P_R__O_P__O_S_E__D] PROTECTIVE ORDER 15 CITY OF LOS ANGELES, LOS ANGELES POLICE DEPARTMENT, 16 POLICE CHIEF MICHAEL MOORE, in his individual and official capacities, 17 OFFICER JENNIFER LEYVA, in her individual and official capacities, 18 OFFICER GREG SU, in his individual and official capacities, OFFICER 19 MARCO RODRIGUEZ. in his individual and official capacities, 20 OFFICER JUAN ESTRADA, in his individual and official capacities, 21 OFFICER CARLOS CASTELLON, in his individual and official capacities, 22 OFFICER JEFF DAY, in his individual and official capacities, OFFICER 23 MEGAN LIDDY, in her individual and official capacities, OFFICER 24 DE’ANTRAYE DANTZLER, in his individual and official capacities, 25 PRIME PARK LABREA INVESTMENT, LP., a California 26 Limited Partnership (previously sued as DOE 1), PRIME PARK LABREA LLC, 27 a California Limited Liability Company (previously sued as DOE 2), JCA 28 INVESTMENTS, INC., a California [PROPOSED] PROTECTIVE ORDER Case 2:20-cv-10553-PSG-KS Document 60 Filed 03/22/22 Page 2 of 19 Page ID #:571

1 corporation (previously sued as DOE 3), UNIVERSAL PROTECTION 2 SERVICE, L.P., a California Limited Partnership (previously sued as DOE 4), 3 UNIVERSAL PROTECTION SERVICE GP, LLC, a California Limited Liability 4 Company (previously sued as DOE 5), UNIVEARSAL PROTECTION GP, 5 INC, a California Corporation (previously sued as DOE 6) and DOES 7 6 through 10, inclusive, Defendants. 7 8 9 Pursuant to Rule 26(c) of the Federal Rules of Civil Procedure and based 10 on the parties’ Stipulated Protective Order (“Stipulation”) filed on March 21, 11 2022, the terms of the protective order to which the parties have agreed are 12 adopted as a protective order of this Court (which generally shall govern the 13 pretrial phase of this action) except to the extent, as set forth below, that those terms have been modified by the Court’s amendment of paragraph 14 of the 14 Stipulation. 15 16 AGREED TERMS OF THE PROTECTIVE ORDER AS ADOPTED AND 17 MODIFIED BY THE COURT1 18 19 20 1. INTRODUCTION 21 1.1 PURPOSES AND LIMITATIONS 22 Discovery in this action is likely to involve production of confidential, 23 proprietary, or private information for which special protection from public 24 disclosure and from use for any purpose other than prosecuting this litigation may 25 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 26 27 1 The Court’s deletions to the agreed terms of the Protective Order are indicated by lines through 28 the text being deleted. 2 PROPOSED PROTECTIVE ORDER Case 2:20-cv-10553-PSG-KS Document 60 Filed 03/22/22 Page 3 of 19 Page ID #:572

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 protection 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. The parties further acknowledge, as set forth 6 in Section 12.3, below, that this Stipulated Protective Order does not entitle them 7 to file confidential information under seal; Civil Local Rule 79-5 sets forth the 8 procedures that must be followed and the standards that will be applied when a 9 party seeks permission from the court to file material under seal. 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 PROPOSED PROTECTIVE ORDER Case 2:20-cv-10553-PSG-KS Document 60 Filed 03/22/22 Page 4 of 19 Page ID #:573

1 1.2 GOOD CAUSE STATEMENT 2 In this case, Plaintiffs claim Defendants violated their constitutional rights by 3 entering their home without a warrant. In connection with these claims, Plaintiffs are 4 seeking materials and information that Defendant City of Los Angeles (“City”) 5 maintain as confidential. These records may contain confidential files such as video 6 recordings, audio recordings, and information and other materials currently in the 7 possession of the City and which City believes need special protection from public 8 disclosure and from use for any purpose other than prosecuting this litigation. 9 City asserts that the confidentiality of the materials and information sought by 10 Plaintiff is recognized by California and federal law. The City has not publicly 11 released the materials and information referenced above except under protective order 12 or pursuant to a court order, if at all. 13 The City contends that absent a protective order delineating the responsibilities 14 of nondisclosure on the part of the parties hereto, there is a specific risk of 15 unnecessary and undue disclosure by one or more of the many attorneys, secretaries, 16 law clerks, paralegals and expert witnesses involved in this case. 17 The City also contends that the unfettered disclosure of the materials and 18 information, absent a protective order, may impact the rights of the City herein to 19 receive a fair trial. 20 Thus, good cause exists for the entry of this pretrial protective order in that the 21 action involves claims of constitutional rights violations by law enforcement officers 22 who acted while in the course of their employment. Accordingly, to expedite the flow 23 of information, to facilitate the prompt resolution of disputes over confidentiality of 24 discovery materials, to adequately protect information the parties are entitled to keep 25 confidential, to ensure that the parties are permitted reasonable necessary uses of such 26 material in preparation for and in the conduct of trial, to address their handling at the 27 end of the litigation, and serve the ends of justice, a protective order for such 28 1 PROPOSED PROTECTIVE ORDER Case 2:20-cv-10553-PSG-KS Document 60 Filed 03/22/22 Page 5 of 19 Page ID #:574

1 information is justified in this matter. 2 It is the intent of the parties that information will not be designated as 3 confidential for tactical reasons and that nothing be so designated without a good faith 4 belief that it has been maintained in a confidential, non-public manner, and there is 5 good cause why it should not be part of the public record of this case. In order to 6 enable the parties and the Court to more efficiently work through concerns raised 7 regarding the propriety of disclosing any such information, the parties wish the Court 8 to enter the following proposed order into the record. 9 1.3 ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER 10 SEAL 11 The parties further acknowledge, as set forth in Section 12.3, below, that this 12 Stipulated Protective Order does not entitle them to file confidential information 13 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and 14 the standards that will be applied when a party seeks permission from the court to file 15 material under seal. 16 There is a strong presumption that the public has a right of access to judicial 17 proceedings and records in civil cases. In connection with non-dispositive motions, 18 good cause must be shown to support a filing under seal. See Kamakana v. City and 19 County of Honolulu,

(9th Cir. 2006), Phillips v. Gen. Motors 20 Corp.,

, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, 21 Inc.,

(E.D. Wis. 1999) (even stipulated protective orders 22 require good cause showing), and a specific showing of good cause or compelling 23 reasons with proper evidentiary support and legal justification, must be made with 24 respect to Protected Material that a party seeks to file under seal. The parties’ mere 25 designation of Disclosure or Discovery Material as CONFIDENTIAL does not— 26 without the submission of competent evidence by declaration, establishing that the 27 28

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1 material sought to be filed under seal qualifies as confidential, privileged, or 2 otherwise protectable—constitute good cause. 3 Further, if a party requests sealing related to a dispositive motion or trial, then 4 compelling reasons, not only good cause, for the sealing must be shown, and the relief 5 sought shall be narrowly tailored to serve the specific interest to be protected. See 6 Pintos v. Pacific Creditors Ass’n.,

(9th Cir. 2010). For each 7 item or type of information, document, or thing sought to be filed or introduced under 8 seal in connection with a dispositive motion or trial, the party seeking protection must 9 articulate compelling reasons, supported by specific facts and legal justification, for 10 the requested sealing order. Again, competent evidence supporting the application to 11 file documents under seal must be provided by declaration. 12 Any document that is not confidential, privileged, or otherwise protectable in 13 its entirety will not be filed under seal if the confidential portions can be redacted. If 14 documents can be redacted, then a redacted version for public viewing, omitting only 15 the confidential, privileged, or otherwise protectable portions of the document, shall 16 be filed. Any application that seeks to file documents under seal in their entirety 17 should include an explanation of why redaction is not feasible. 18 2. DEFINITIONS 19 2.1 Action: Tirzah J. Franklin, et al. vs. City of Los Angeles, et. al. (Case 20 No. CV20-10553 VAP (KSx)). 21 2.2 Challenging Party: a Party or Non-Party that challenges the designation 22 of information or items under this Order. 23 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 24 how it is generated, stored or maintained) or tangible things that qualify for protection 25 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 26 Cause Statement. This also includes (1) any information copied or extracted from the 27 Confidential information; (2) all copies, excerpts, summaries or compilations of 28

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1 Confidential information; and (3) any testimony, conversations, or presentations that 2 might reveal Confidential information. 3 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 4 support staff). 5 2.5 Designating Party: a Party or Non-Party that designates information or 6 items that it produces in disclosures or in responses to discovery as 7 “CONFIDENTIAL.” 8 2.6 Disclosure or Discovery Material: all items or information, regardless of 9 the medium or manner in which it is generated, stored, or maintained (including, 10 among other things, testimony, transcripts, and tangible things), that are produced or 11 generated in disclosures or responses to discovery in this matter. 12 2.7 Expert: a person with specialized knowledge or experience in a matter 13 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 14 expert witness or as a consultant in this Action. 15 2.8 House Counsel: attorneys who are employees of a party to this Action. 16 House Counsel does not include Outside Counsel of Record or any other outside 17 counsel. 18 2.9 Non-Party: any natural person, partnership, corporation, association, or 19 other legal entity not named as a Party to this action. 20 2.10 Outside Counsel of Record: attorneys who are not employees of a party 21 to this Action but are retained to represent or advise a party to this Action and have 22 appeared in this Action on behalf of that party or are affiliated with a law firm which 23 has appeared on behalf of that party, and includes support staff. 24 2.11 Party: any party to this Action, including all of its officers, directors, 25 employees, consultants, retained experts, and Outside Counsel of Record (and their 26 support staffs). 27 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 28

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1 Discovery Material in this Action. 2 2.13 Professional Vendors: persons or entities that provide litigation support 3 services (e.g., photocopying, videotaping, translating, preparing exhibits or 4 demonstrations, and organizing, storing, or retrieving data in any form or medium) 5 and their employees and subcontractors. 6 2.14 Protected Material: any Disclosure or Discovery Material that is 7 designated as “CONFIDENTIAL.” 8 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 9 from a Producing Party. 10 3. SCOPE 11 The protections conferred by this Stipulation and Order cover not only 12 Protected Material (as defined above), but also (1) any information copied or extracted 13 from Protected Material; (2) all copies, excerpts, summaries, or compilations of 14 Protected Material; and (3) any testimony, conversations, or presentations by Parties 15 or their Counsel that might reveal Protected Material. 16 Any use of Protected Material at trial will be governed by the orders of the trial 17 judge. This Order does not govern the use of Protected Material at trial. 18 4. DURATION 19 Even after final disposition of this litigation, the confidentiality obligations 20 imposed by this Order shall remain in effect until a Designating Party agrees 21 otherwise in writing or a court order otherwise directs. Final disposition shall be 22 deemed to be the later of (1) dismissal of all claims and defenses in this Action, with 23 or without prejudice; and (2) final judgment herein after the completion and 24 exhaustion of all appeals, re-hearings, remands, trials, or reviews of this Action, 25 including the time limits for filing any motions or application for extension of time 26 pursuant to applicable law. 27

28

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1 5. DESIGNATING PROTECTED MATERIAL 2 5.1 Exercise of Restraint and Care in Designating Material for Protection. 3 Each Party or Non-Party that designates information or items for protection under this 4 Order must take care to limit any such designation to specific material that qualifies 5 under the appropriate standards. The Designating Party must designate for protection 6 only those parts of material, documents, items, or oral or written communications that 7 qualify so that other portions of the material, documents, items, or communications for 8 which protection is not warranted are not swept unjustifiably within the ambit of this 9 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 12 purpose (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 this 19 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated 20 or ordered, Disclosure or Discovery Material that qualifies for protection under this 21 Order must be clearly so designated before the material is disclosed or produced. 22 Designation in conformity with this Order requires: 23 (a) for information in documentary form (e.g., paper or electronic 24 documents, but excluding transcripts of depositions or other pretrial or trial 25 proceedings), that the Producing Party affix at a minimum, the legend 26 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 27 contains protected material. If only a portion or portions of the material on a page 28

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1 qualifies for protection, the Producing Party also must clearly identify the protected 2 portion(s) (e.g., by making appropriate markings in the margins). 3 A Party or Non-Party that makes original documents available for inspection 4 need not designate them for protection until after the inspecting Party has indicated 5 which documents it would like copied and produced. During the inspection and before 6 the designation, all of the material made available for inspection will be deemed 7 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 8 copied and produced, the Producing Party must determine which documents, or 9 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 14 margins). 15 (b) for testimony given in depositions that the Designating Party 16 identify the Disclosure or Discovery Material on the record, before the close of the 17 deposition all protected testimony. 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 on 20 the exterior of the container or containers in which the information is stored the legend 21 “CONFIDENTIAL.” If only a portion or portions of the information warrants 22 protection, the Producing Party, to the extent practicable, will identify the protected 23 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 the 26 Designating Party’s right to secure protection under this Order for such material. Upon 27 timely correction of a designation, the Receiving Party must make reasonable efforts 28

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1 to assure that the material is treated in accordance with the provisions of this Order. 2 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 3 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 4 designation of confidentiality at any time that is consistent with the Court’s 5 Scheduling Order. 6 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 7 resolution process (and, if necessary, file a discovery motion) under Local Rule 37.1 et 8 seq. 9 6.3 Joint Stipulation. Any challenge submitted to the Court shall be via a 10 joint stipulation pursuant to Local Rule 37-2. 11 6.4 The burden of persuasion in any such challenge proceeding will be on the 12 Designating Party. Frivolous challenges, and those made for an improper purpose 13 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 14 expose the Challenging Party to sanctions. Unless the Designating Party has waived or 15 withdrawn the confidentiality designation, all parties will continue to afford the 16 material in question the level of protection to which it is entitled under the Producing 17 Party’s designation until the Court rules on the challenge. 18 7. ACCESS TO AND USE OF PROTECTED MATERIAL 19 7.1 Basic Principles. A Receiving Party may use Protected Material that is 20 disclosed or produced by another Party or by a Non-Party in connection with this 21 Action only for prosecuting, defending, or attempting to settle this Action. Such 22 Protected Material may be disclosed only to the categories of persons and under the 23 conditions described in this Order. When the Action has been terminated, a Receiving 24 Party must comply with the provisions of section 13 below (FINAL DISPOSITION). 25 Protected Material must be stored and maintained by a Receiving Party at a 26 location and in a secure manner that ensures that access is limited to the persons 27 authorized under this Order. 28

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1 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 2 otherwise ordered by the court or permitted in writing by the Designating Party, a 3 Receiving Party may disclose any information or item designated “CONFIDENTIAL” 4 only to: 5 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 6 well as employees of said Outside Counsel of Record to whom it is reasonably 7 necessary to disclose the information for this Action; 8 (b) the officers, directors, and employees (including House Counsel) 9 of the Receiving Party to whom disclosure is reasonably necessary for this Action; 10 (c) Experts (as defined in this Order) of the Receiving Party to whom 11 disclosure is reasonably necessary for this Action and who have signed the 12 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 13 (d) the Court and its personnel; 14 (e) court reporters and their staff; 15 (f) professional jury or trial consultants, mock jurors, and Professional 16 Vendors to whom disclosure is reasonably necessary for this Action and who have 17 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 18 (g) the author or recipient of a document containing the information or 19 a custodian or other person who otherwise possessed or knew the information; 20 (h) during their depositions, witnesses, and attorneys for witnesses, in 21 the Action to whom disclosure is reasonably necessary provided: (1) the deposing 22 party requests that the witness sign the form attached as Exhibit A hereto; and (2) they 23 will not be permitted to keep any confidential information unless they sign the 24 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed 25 by the Designating Party or ordered by the court. Pages of transcribed deposition 26 testimony or exhibits to depositions that reveal Protected Material may be separately 27 bound by the court reporter and may not be disclosed to anyone except as permitted 28

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1 under this Stipulated Protective Order; and 2 (i) any mediator or settlement officer, and their supporting personnel, 3 mutually agreed upon by any of the parties engaged in settlement discussions. 4 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 5 IN OTHER LITIGATION 6 If a Party is served with a subpoena or a court order issued in other litigation 7 that compels disclosure of any information or items designated in this Action as 8 “CONFIDENTIAL,” that Party must: 9 (a) promptly notify in writing the Designating Party. Such notification 10 will include a copy of the subpoena or court order; 11 (b) promptly notify in writing the party who caused the subpoena or 12 order to issue in the other litigation that some or all of the material covered by the 13 subpoena or order is subject to this Protective Order. Such notification will include a 14 copy of this Stipulated Protective Order; and 15 (c) cooperate with respect to all reasonable procedures sought to be 16 pursued by the Designating Party whose Protected Material may be affected. 17 If the Designating Party timely seeks a protective order, the Party served with 18 the subpoena or court order will not produce any information designated in this action 19 as “CONFIDENTIAL” before a determination by the court from which the subpoena 20 or order issued, unless the Party has obtained the Designating Party’s permission. The 21 Designating Party will bear the burden and expense of seeking protection in that court 22 of its confidential material and nothing in these provisions should be construed as 23 authorizing or encouraging a Receiving Party in this Action to disobey a lawful 24 directive from another court. 25 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 26 PRODUCED IN THIS LITIGATION 27 (a) The terms of this Order are applicable to information produced by 28

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1 a Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 2 produced by Non-Parties in connection with this litigation is protected by the remedies 3 and relief provided by this Order. Nothing in these provisions should be construed as 4 prohibiting a Non-Party from seeking additional protections. 5 (b) In the event that a Party is required, by a valid discovery request, to 6 produce a Non-Party’s confidential information in its possession, and the Party is 7 subject to an agreement with the Non-Party not to produce the Non-Party’s 8 confidential information, then the Party will: 9 (1) promptly notify in writing the Requesting Party and the 10 Non-Party that some or all of the information requested is subject to a confidentiality 11 agreement with a Non-Party; 12 (2) promptly provide the Non-Party with a copy of the 13 Stipulated Protective Order in this Action, the relevant discovery request(s), and a 14 reasonably specific description of the information requested; and 15 (3) make the information requested available for inspection by 16 the Non-Party, if requested. 17 (c) If the Non-Party fails to seek a protective order from this court 18 within 14 days of receiving the notice and accompanying information, the Receiving 19 Party may produce the Non-Party’s confidential information responsive to the 20 discovery request. If the Non-Party timely seeks a protective order, the Receiving 21 Party will not produce any information in its possession or control that is subject to the 22 confidentiality agreement with the Non-Party before a determination by the court. 23 Absent a court order to the contrary, the Non-Party will bear the burden and expense 24 of seeking protection in this court of its Protected Material. 25 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 26 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 27 Protected Material to any person or in any circumstance not authorized under this 28

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1 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 2 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts to 3 retrieve all unauthorized copies of the Protected Material, (c) inform the person or 4 persons to whom unauthorized disclosures were made of all the terms of this Order, 5 and (d) request such person or persons to execute the “Acknowledgment and 6 Agreement to Be Bound” that is attached hereto as Exhibit A. 7 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 8 PROTECTED MATERIAL 9 When a Producing Party gives notice to Receiving Parties that certain 10 inadvertently produced material is subject to a claim of privilege or other protection, 11 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 12 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 13 may be established in an e-discovery order that provides for production without prior 14 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 15 parties reach an agreement on the effect of disclosure of a communication or 16 information covered by the attorney-client privilege or work product protection, the 17 parties may incorporate their agreement in the stipulated protective order submitted to 18 the court. 19 12. MISCELLANEOUS 20 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 21 person to seek its modification by the Court in the future. 22 12.2 Right to Assert Other Objections. By stipulating to the entry of this 23 Protective Order no Party waives any right it otherwise would have to object to 24 disclosing or producing any information or item on any ground not addressed in this 25 Stipulated Protective Order. Similarly, no Party waives any right to object on any 26 ground to use in evidence of any of the material covered by this Protective Order. 27 12.3 Filing Protected Material. A Party that seeks to file under seal any 28

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1 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 2 only be filed under seal pursuant to a court order authorizing the sealing of the specific 3 Protected Material at issue. If a Party's request to file Protected Material under seal is 4 denied by the court, then the Receiving Party may file the information in the public 5 record unless otherwise instructed by the court. 6 13. FINAL DISPOSITION 7 After the final disposition of this Action, as defined in paragraph 4, within 60 8 days of a written request by the Designating Party, each Receiving Party must return 9 all Protected Material to the Producing Party. As used in this subdivision, “all 10 Protected Material” includes all copies, abstracts, compilations, summaries, and any 11 other format reproducing or capturing any of the Protected Material. The Receiving 12 Party must submit a written certification to the Producing Party (and, if not the same 13 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 14 (by category, where appropriate) all the Protected Material that was returned and (2) 15 affirms that the Receiving Party has not retained any copies, abstracts, compilations, 16 summaries or any other format reproducing or capturing any of the Protected Material. 17 Notwithstanding this provision, Counsel are entitled to retain an archival copy of all 18 pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda, 19 correspondence, deposition and trial exhibits, expert reports, attorney work product, 20 and consultant and expert work product, even if such materials contain Protected 21 Material. Any such archival copies that contain or constitute Protected Material 22 remain subject to this Protective Order as set forth in Section 4 (DURATION). 23 / / / 24 / / / 25 / / / 26 / / / 27 / / / 28 13 PROPOSED PROTECTIVE ORDER Case 2:20-cv-10553-PSG-KS Document 60 Filed 03/22/22 Page 17 of 19 Page ID #:586

1 14. VIOLATION 2 Any willful violation of this Order may be punished by civil or criminal 3 contempt proceedings, financial or evidentiary sanctions, reference to disciplinary 4 authorities, or other appropriate action at the discretion of the Court. 5 6 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 7 8 9 Dated: March 21, 2022 THE COMMUNITY LAW FIRM 10 11 12 By: __/s/__________________________ Atyria S. Clark 13 Email: [email protected] 14 Attorneys for Plaintiffs 15 16 DATED: March 17, 2022 Respectfully submitted, 17 MICHAEL N. FEUER, City Attorney 18 SCOTT MARCUS, Chief Assistant City Attorney 19 CORY M. BRENTE, Senior Assistant City Attorney 20 /s/ Hasmik Badalian Collins By: 21 HASMIK BADALIAN COLLINS, Deputy City Attorney 22 Attorneys for Defendants CITY OF LOS ANGELES, LOS ANGELES 23 POLICE DEPARTMENT, CARLOS CASTELLON, JEFF DAY, DE’ANTRAYE DANTZLER, JUAN ESTRADA, JENNIFER 24 LEYVA, MEGAN LIDDY, MICHEL R. MOORE, MARCO RODRIGUEZ and GREG SU 25 26 27 28 14 PROPOSED PROTECTIVE ORDER Case 2:20-cv-10553-PSG-KS Document 60 Filed 03/22/22 Page 18o0f19 Page ID #:587

! | Dated: March 21, 2022 WILSON, ELSER, MOSKOWITZ, 2 EDELMAN & DICKER LLP 3 By: _/s/ 4 Gregory K. Lee, Esq. Shelby B. Crawford 5 Attorneys for Defendant, UNIVERSAL PROTECTION SERVICE, LP 6 d/b/a ALLIED UNIVERSAL SECURITY SERVICES, UNIVERSAL PROTECTION 7 SERVICE GP, LLC and UNIVERSAL 8 PROTECTION GP, INC. Dated: March 21, 2022 TYSON & MENDES, LLP 10

David J. Kahn 12 Attorneys for Defendants, PRIME PARK LABREA INVESTMENT, L.P. 13 PRIME PARK LABREA LLC 14 JCA INVESTMENTS, INC 15 16 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

17 . L L, UH DATED: _March 22, 2022 By: Ln . SPK__ 18 HON. KAREN L. STEVENSON 19 United States Magistrate Judge 20 21 22 23 24 25 26 27 28

15 PROPOSED PROTECTIVE ORDER

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1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 I, _____________________________ [print or type full name], of 5 ________________________________ [print or type full address], declare under 6 penalty of perjury that I have read in its entirety and understand the Stipulated 7 Protective Order that was issued by the United States District Court for the Central 8 District of California on [date] in the case of ___________ [insert formal name of 9 the case and the number and initials assigned to it by the Court]. I agree to 10 comply with and to be bound by all the terms of this Stipulated Protective Order and I 11 understand and acknowledge that failure to so comply could expose me to sanctions 12 and punishment in the nature of contempt. I solemnly promise that I will not disclose 13 in any manner any information or item that is subject to this Stipulated Protective 14 Order to any person or entity except in strict compliance with the provisions of this 15 Order. 16 I further agree to submit to the jurisdiction of the United States District Court 17 for the Central District of California for the purpose of enforcing the terms of this 18 Stipulated Protective Order, even if such enforcement proceedings occur after 19 termination of this action. I hereby appoint __________________________ [full 20 name] of _______________________________________ [full address and 21 telephone number] as my California agent for service of process in connection with 22 this action or any proceedings related to enforcement of this Stipulated Protective 23 Order. 24 Date: ______________________________________ 25 City and State where signed: _________________________________ 26 Printed name: _______________________________ 27 Signature: __________________________________ 28 16 PROPOSED PROTECTIVE ORDER