Case 8:21-cv-00839-JLS-DFM Document 41 Filed 04/18/22 Page 1 of 18 Page ID #:190

1 WOODRUFF, SPRADLIN & SMART, APC PATRICK M. DESMOND - State Bar No. 215029 2 [email protected] 555 Anton Boulevard, Suite 1200 3 Costa Mesa, California 92626-7670 Telephone: (714) 558-7000 4 Facsimile: (714) 835-7787 5 Attorneys for Defendants CITY OF TORRANCE, a public entity, OFFICER BRIAN KAWAMOTO, OFFICER CHRISTOPHER 6 ALLEN-YOUNG, OFFICER NELSON and OFFICER T. KNOX 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 SHEILA BATES, CASE NO.: 8:21-cv-00839-JLS-DFMx 12 Plaintiff, JUDGE: JOSEPHINE L. STATON MAGISTRATE JUDGE: DOUGLAS F. 13 v. McCORMICK 14 CITY OF TORRANCE; OFFICER KAWAMOTO and DOES 1 through 10 STIPULATED PROTECTIVE 15 inclusive, ORDER1 16 Defendants. 17 18 1. A. PURPOSES AND LIMITATIONS 19 Discovery in this action is likely to involve production of confidential, 20 proprietary or private information for which special protection from public disclosure 21 and from use for any purpose other than prosecuting this litigation may be warranted. 22 Accordingly, the parties hereby stipulate to and petition the Court to enter the 23 following Stipulated Protective Order. The parties acknowledge that this Order does 24 not confer blanket protections on all disclosures or responses to discovery and that 25 the protection it affords from public disclosure and use extends only to the limited 26 27 1 This Stipulated Protective Order is substantially based on the model protective 28 order utilized by judges within the Central District of California. 1 1648101.1 Case 8:21-cv-00839-JLS-DFM Document 41 Filed 04/18/22 Page 2 of 18 Page ID #:191

1 information or items that are entitled to confidential treatment under the applicable 2 legal principles. 3 4 B. GOOD CAUSE STATEMENT 5 This action is likely to involve personal, medical, financial, and/or other 6 information for which special protection from public disclosure and from use for any 7 purpose other than prosecution of this action is warranted. Such confidential and 8 proprietary materials and information consist of, among other things, information 9 regarding confidential government investigations, confidential medical records and 10 information, confidential information pertaining to third parties, information 11 otherwise generally unavailable to the public, or which may be privileged or otherwise 12 protected from disclosure under state or federal statutes, court rules, case decisions, 13 or common law. 14 Specifically, this action is brought under

, and involves 15 allegations by Plaintiff that Defendant City of Torrance and/or its peace officer 16 employees unlawfully arrested and utilized excessive force against her in violation of 17 her Constitutional rights. The discovery sought, and likely to be sought in the future, 18 includes, but is not limited to, documents and records relating to internal affairs 19 investigation files and related complaints, statements, and records (which also relate 20 to third parties); police officers’ personnel files; and individual parties’ medical and 21 financial information. The public and uncontrolled release of these documents, 22 without first allowing the affected parties and non-parties to identify confidential 23 information and claim protection, could cause the parties personal and institutional 24 embarrassment and harm. 25 Accordingly, to expedite the flow of information, to facilitate the prompt 26 resolution of disputes over confidentiality of discovery materials, to adequately 27 protect information the parties are entitled to keep confidential, to ensure that the 28 parties are permitted reasonable necessary uses of such material in preparation for and 2 1648101.1 Case 8:21-cv-00839-JLS-DFM Document 41 Filed 04/18/22 Page 3 of 18 Page ID #:192

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

(9th Cir. 2006); Phillips v. Gen. Motors 19 Corp.,

, 1210-11 (9th Cir. 2002);Makar-Welbon v. Sony Electrics, Inc., 20

(E.D. Wis. 1999) (even stipulated protective orders require good 21 cause showing), and a specific showing of good cause or compelling reasons with 22 proper evidentiary support and legal justification, must be made with respect to 23 Protected Material that a party seeks to file under seal. The parties’ mere designation 24 of Disclosure or Discovery Material as CONFIDENTIAL does not—without the 25 submission of competent evidence by declaration, establishing that the material 26 sought to be filed under seal qualifies as confidential, privileged, or otherwise 27 protectable—constitute good cause. 28 /// 3 1648101.1 Case 8:21-cv-00839-JLS-DFM Document 41 Filed 04/18/22 Page 4 of 18 Page ID #:193

1 Further, if a party requests sealing related to a dispositive motion or trial, then 2 compelling reasons, not only good cause, for the sealing must be shown, and the relief 3 sought shall be narrowly tailored to serve the specific interest to be protected. See 4 Pintos v. Pacific Creditors Ass’n,

(9th Cir. 2010). For each 5 item or type of information, document, or thing sought to be filed or introduced under 6 seal in connection with a dispositive motion or trial, the party seeking protection must 7 articulate compelling reasons, supported by specific facts and legal justification, for 8 the requested sealing order. Again, competent evidence supporting the application to 9 file documents under seal must be provided by declaration. 10 Any document that is not confidential, privileged, or otherwise protectable in 11 its entirety will not be filed under seal if the confidential portions can be redacted. If 12 documents can be redacted, then a redacted version for public viewing, omitting only 13 the confidential, privileged, or otherwise protectable portions of the document shall 14 be filed. Any application that seeks to file documents under seal in their entirety 15 should include an explanation of why redaction is not feasible. 16 17 2. DEFINITIONS 18 2.1 Action: this pending federal lawsuit. 19 2.2 Challenging Party: a Party or Non-Party that challenges the 20 designation of information or items under this Order. 21 2.3 “CONFIDENTIAL” Information or Items: information (regardless 22 of how it is generated, stored or maintained) or tangible things that qualify for 23 protection under Federal Rule of Civil Procedure 26(c), and as specified above in the 24 Good Cause Statement. 25 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 26 their support staff). 27 2.5 Designating Party: a Party or Non-Party that designates information or 28 items that it produces in disclosures or in responses to discovery as 4 1648101.1 Case 8:21-cv-00839-JLS-DFM Document 41 Filed 04/18/22 Page 5 of 18 Page ID #:194

1 “CONFIDENTIAL.” 2 2.6 Disclosure or Discovery Material: all items or information, regardless 3 of the medium or manner in which it is generated, stored, or maintained (including, 4 among other things, testimony, transcripts, and tangible things) that are produced or 5 generated in disclosures or responses to discovery in this matter. 6 2.7 Expert: a person with specialized knowledge or experience in a matter 7 pertinent to the litigation who has been retained by a Party or its counsel to serve as 8 an expert witness or as a consultant in this Action. 9 2.8 House Counsel: attorneys who are employees of a party to this Action. 10 House Counsel does not include Outside Counsel of Record or any other outside 11 counsel. 12 2.9 Non-Party: any natural person, partnership, corporation, association or 13 other legal entity not named as a Party to this action. 14 2.10 Outside Counsel of Record: attorneys who are not employees of a party 15 to this Action but are retained to represent or advise a party to this Action and have 16 appeared in this Action on behalf of that party or are affiliated with a law firm that 17 has appeared on behalf of that party, and includes support staff. 18 2.11 Party: any party to this Action, including all of its officers, directors, 19 employees, consultants, retained experts, and Outside Counsel of Record (and their 20 support staffs). 21 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 22 Discovery Material in this Action. 23 2.13 Professional Vendors: persons or entities that provide litigation support 24 services (e.g., photocopying, videotaping, translating, preparing exhibits or 25 demonstrations, and organizing, storing, or retrieving data in any form or medium) 26 and their employees and subcontractors. 27 2.14 Protected Material: any Disclosure or Discovery Material that is 28 designated as “CONFIDENTIAL.” 5 1648101.1 Case 8:21-cv-00839-JLS-DFM Document 41 Filed 04/18/22 Page 6 of 18 Page ID #:195

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 5 Protected Material (as defined above), but also (1) any information copied or extracted 6 from Protected Material; (2) all copies, excerpts, summaries, or compilations of 7 Protected Material; and (3) any testimony, conversations, or presentations by Parties 8 or their Counsel that might reveal Protected Material. 9 Any use of Protected Material at trial shall be governed by the orders of the 10 trial judge. This Order does not govern the use of Protected Material at trial. 11 12 4. DURATION 13 Once a case proceeds to trial, information that was designated as 14 CONFIDENTIAL or maintained pursuant to this protective order which is used or 15 introduced as an exhibit at trial becomes public and will be presumptively available 16 to all members of the public, including the press, unless compelling reasons supported 17 by specific factualfindings to proceed otherwise are made to the trial judge in advance 18 of the trial. See Kamakana,

(distinguishing “good cause” 19 showing for sealing documents produced in discovery from “compelling reasons” 20 standard when merits-related documents are part of court record). Accordingly, with 21 respect to material that is used or introduced as an exhibit at trial, the terms of this 22 protective order do not extend beyond the commencement of trial. In all other respects 23 (i.e. Confidential Material which is not used or introduced as an exhibit at trial), the 24 terms of this protective order shall survive the conclusion of trial in this case. 25 5. DESIGNATING PROTECTED MATERIAL 26 5.1 Exercise of Restraint and Care in Designating Material for 27 Protection. 28 Each Party or Non-Party that designates information or items for protection 6 1648101.1 Case 8:21-cv-00839-JLS-DFM Document 41 Filed 04/18/22 Page 7 of 18 Page ID #:196

1 under this Order must take care to limit any such designation to specific material that 2 qualifies under the appropriate standards. The Designating Party must designate for 3 protection only those parts of material, documents, items or oral or written 4 communications that qualify so that other portions of the material, documents, items 5 or communications for which protection is not warranted are not swept unjustifiably 6 within the ambit of this Order. 7 Mass, indiscriminate or routinized designations are prohibited. Designations 8 that are shown to be clearly unjustified or that have been made for an improper 9 purpose (e.g., to unnecessarily encumber the case development process or to impose 10 unnecessary expenses and burdens on other parties) may expose the Designating 11 Party to sanctions. 12 If it comes to a Designating Party’s attention that information or items that it 13 designated for protection do not qualify for protection, that Designating Party must 14 promptly notify all other Parties that it is withdrawing the inapplicable designation. 15 5.2 Manner and Timing of Designations. Except as otherwise provided in 16 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 17 stipulated or ordered, Disclosure of Discovery Material that qualifies for protection 18 under this Order must be clearly so designated before the material is disclosed or 19 produced. 20 Designation in conformity with this Order requires: 21 (a) for information in documentary form (e.g., paper or electronic 22 documents, but excluding transcripts of depositions or other pretrial or trial 23 proceedings), that the Producing Party affix at a minimum, the legend 24 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 25 contains protected material. If only a portion of the material on a page qualifies for 26 protection, the Producing Party also must clearly identify the protected portion(s) 27 (e.g., by making appropriate markings in the margins). 28 A Party or Non-Party that makes original documents available for inspection 7 1648101.1 Case 8:21-cv-00839-JLS-DFM Document 41 Filed 04/18/22 Page 8 of 18 Page ID #:197

1 need not designate them for protection until after the inspecting Party has indicated 2 which documents it would like copied and produced. During the inspection and 3 before the designation, all of the material made available for inspection shall be 4 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents 5 it wants copied and produced, the Producing Party must determine which documents, 6 or portions thereof, qualify for protection under this Order. Then, before producing 7 the specified documents, the Producing Party must affix the “CONFIDENTIAL 8 legend” to each page that contains Protected Material. If only a portion of the material 9 on a page qualifies for protection, the Producing Party also must clearly identify the 10 protected portion(s) (e.g., by making appropriate markings in the margins). 11 (b) for testimony given in depositions that the Designating Party identifies 12 the Disclosure or Discovery Material on the record, before the close of the deposition 13 all protected testimony. 14 (c) for information produced in some form other than documentary and for 15 any other tangible items, that the Producing Party affix in a prominent place on the 16 exterior of the container or containers in which the information is stored the legend 17 “CONFIDENTIAL.” If only a portion or portions of the information warrants 18 protection, the Producing Party, to the extent practicable, shall identify the protected 19 portion(s). 20 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 21 failure to designate qualified information or items does not, standing alone, waive the 22 Designating Party’s right to secure protection under this Order for such material. 23 Upon timely correction of a designation, the Receiving Party must make reasonable 24 efforts to assure that the material is treated in accordance with the provisions of this 25 Order. 26 27 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 28 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 8 1648101.1 Case 8:21-cv-00839-JLS-DFM Document 41 Filed 04/18/22 Page 9 of 18 Page ID #:198

1 designation of confidentiality at any time that is consistent with the Court’s 2 Scheduling Order. 3 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 4 resolution process under Local Rule 37.1 et seq. 5 6.3 Burden and Protection During Challenge. The burden of persuasion 6 in any such challenge proceeding shall be on the Designating Party. Frivolous 7 challenges, and those made for an improper purpose (e.g., to harass or impose 8 unnecessary expenses and burdens on other parties) may expose the Challenging Party 9 to sanctions. Unless the Designating Party has waived or withdrawn the 10 confidentiality designation, all parties shall continue to afford the material in question 11 the level of protection to which it is entitled under the Producing Party’s designation 12 until the Court rules on the challenge. 13 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 Actionhas 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 27 “CONFIDENTIAL” only to: 28 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 9 1648101.1 Case 8:21-cv-00839-JLS-DFM Document 41 Filed 04/18/22 Page 10 of 18 Page ID #:199

1 as employees of said Outside Counsel of Record to whom it is reasonably necessary 2 to disclose the information for this Action; 3 (b) the officers, directors, and employees (including House Counsel) of the 4 Receiving Party to whom disclosure is reasonably necessary for this Action; 5 (c) Experts (as defined in this Order) of the Receiving Party to whom 6 disclosure is reasonably necessary for this Action and who have signed the 7 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 8 (d) the court and its personnel; 9 (e) court reporters and their staff; 10 (f) professional jury or trial consultants, mock jurors, and Professional 11 Vendors to whom disclosure is reasonably necessary for this Action and who have 12 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 13 (g) the author or recipient of a document containing the information or a 14 custodian or other person who otherwise possessed or knew the information; 15 (h) during their depositions, witnesses, and attorneys for witnesses, in the 16 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 17 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will 18 not be permitted to keep any confidential information unless they sign the 19 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 20 agreed by the Designating Party or ordered by the court. Pages of transcribed 21 deposition testimony or exhibits to depositions that reveal Protected Material may be 22 separately bound by the court reporter and may not be disclosed to anyone except as 23 permitted under this Stipulated Protective Order; and 24 (i) any mediator or settlement officer, and their supporting personnel, 25 mutually agreed upon by any of the parties engaged in settlement discussions. 26 /// 27 /// 28 /// 10 1648101.1 Case 8:21-cv-00839-JLS-DFM Document 41 Filed 04/18/22 Page 11 of 18 Page ID #:200

1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 2 PRODUCED IN OTHER LITIGATION 3 If a Party is served with a subpoena or a court order issued in other litigation 4 that 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 shall 7 include a copy of the subpoena or court order; 8 (b) promptly notify in writing the party who caused the subpoena or order 9 to issue in the other litigation that some or all of the material covered by the subpoena 10 or order is subject to this Protective Order. Such notification shall include a copy of 11 this 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 shall 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 shall 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 23 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 24 PRODUCED IN THIS LITIGATION 25 (a) The terms of this Order are applicable to information produced by a 26 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 27 produced by Non-Parties in connection with this litigation is protected by the 28 remedies and relief provided by this Order. Nothing in these provisions should be 11 1648101.1 Case 8:21-cv-00839-JLS-DFM Document 41 Filed 04/18/22 Page 12 of 18 Page ID #:201

1 construed as prohibiting a Non-Party from seeking additional protections. 2 (b) In the event that a Party is required, by a valid discovery request, to 3 produce a Non-Party’s confidential information in its possession, and the Party is 4 subject to an agreement with the Non-Party not to produce the Non-Party’s 5 confidential information, then the Party shall: 6 (1) promptly notify in writing the Requesting Party and the Non-Party 7 that some or all of the information requested is subject to a confidentiality agreement 8 with a Non-Party; 9 10 (2) promptly provide the Non-Party with a copy of the Stipulated 11 Protective Order in this Action, the relevant discovery request(s), and a reasonably 12 specific description of the information requested; and 13 (3) make the information requested available for inspection by the Non- 14 Party, if requested. 15 (c) If the Non-Party fails to seek a protective order from this court within 16 14 days of receiving the notice and accompanying information, the Receiving Party 17 may produce the Non-Party’s confidential information responsive to the discovery 18 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 19 not produce any information in its possession or control that is subject to the 20 confidentiality agreement with the Non-Party before a determination by the court. 21 Absent a court order to the contrary, the Non-Party shall bear the burden and expense 22 of seeking protection in this court of its Protected Material. 23 24 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 25 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 26 Protected Material to any person or in any circumstance not authorized under this 27 Stipulated Protective Order, the Receiving Party must immediately (a) notify, in 28 writing, the Designating Party of the unauthorized disclosures, (b) use its best efforts 12 1648101.1 Case 8:21-cv-00839-JLS-DFM Document 41 Filed 04/18/22 Page 13 of 18 Page ID #:202

1 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 2 persons to whom unauthorized disclosures were made of all the terms of this Order, 3 and (d) request such person or persons to execute the “Acknowledgment and 4 Agreement to Be Bound” that is attached hereto as Exhibit A. 5 6 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 7 PROTECTED MATERIAL 8 When a Producing Party gives notice to Receiving Parties that certain 9 inadvertently produced material is subject to a claim of privilege or other protection, 10 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 11 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 12 may be established in an e-discovery order that provides for production without prior 13 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 14 parties reach an agreement on the effect of disclosure of a communication or 15 information covered by the attorney-client privilege or work product protection, the 16 parties may incorporate their agreement in the stipulated protective order submitted 17 to the court. 18 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 Protected Material must comply with Local Civil Rule 79-5. Protected Material may 13 1648101.1 Case 8:21-cv-00839-JLS-DFM Document 41 Filed 04/18/22 Page 14 of 18 Page ID #:203

1 only be filed under seal pursuant to a court order authorizing the sealing of the specific 2 Protected Material at issue. If a Party’s request to file Protected Material under seal 3 is denied by the court, then the Receiving Party may file the information in the public 4 record unless otherwise instructed by the court. 5 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 or destroy such material as set forth in 10 the written request. As used in this subdivision, “all Protected Material” includes all 11 copies, abstracts, compilations, summaries, and any other format reproducing or 12 capturing any of the Protected Material. Whether the Protected Material is returned 13 or destroyed, the Receiving Party must submit a written certification to the Producing 14 Party (and, if not the same person or entity, to the Designating Party) by the 60 day 15 deadline that (1) identifies (by category, where appropriate) all the Protected Material 16 that was returned or destroyed and (2) affirms that the Receiving Party has not 17 retained any copies, abstracts, compilations, summaries or any other format 18 reproducing or capturing any of the Protected Material. Notwithstanding this 19 provision, Counsel are entitled to retain an archival copy of all pleadings, motion 20 papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence, 21 deposition and trial exhibits, expert reports, attorney work product, and consultant 22 and expert work product, even if such materials contain Protected Material. Any such 23 archival copies that contain or constitute Protected Material remain subject to this 24 Protective Order as set forth in Section 4 (DURATION). 25 14. VIOLATION 26 Any violation of this Order may be punished by appropriate measures 27 including, without limitation, contempt proceedings and/or monetary sanctions. 28 14 1648101.1 Case §:21-cv-00839-JLS-DFM Document 41 Filed 04/18/22 Page 15o0f18 Page ID #:204

1 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 3 || DATED: April 12, 2022 LAW OFFICES OF ERIN DARLING 4 By: □ s/Erin Darling 5 Erin Darling, Esq. Attorney for Plaintiff 6 Sheila Bates g || DATED: April 12, 2022 WOODRUFF, SPRADLIN & SMART 9 By: Jason McEwen Patrick Desmond 10 Jason McEwen il Attorneys for Defendants City of Torrance, Officer Brian Kawamoto, 12 Officer Christopher Allen-Young, 13 Officer Nelson and Officer T. Knox 14 15. || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 16 17_ || DATED: April 18, 2022 18 19 >? me HON. BOUGLAS F. McCORMICK 20 || Un'ted States Magictret> T=49¢ 21 22 23 24 25 26 27 28 15 1648101.1

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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 penalty of perjury that 6 I have read in its entirety and understand the Stipulated Protective Order that was 7 issued by the United States District Court for the Central District of California on 8 ___________[date] in the case of Sheila Bates v. City of Torrance, et al. U.S.D.C. 9 Case No. 8:21-cv-0839-JLS (DFMx). I agree to comply with and to be bound by all 10 the terms of this Stipulated Protective Order and I understand and acknowledge that 11 failure to so comply could expose me to sanctions and punishment in the nature of 12 contempt. I solemnly promise that I will not disclose in any manner any information 13 or item that is subject to this Stipulated Protective Order to any person or entity except 14 in strict compliance with the provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District Court 16 for the Central District of California for enforcing the terms of this Stipulated 17 Protective Order, even if such enforcement proceedings occur after termination of this 18 action. I hereby appoint __________________________ [print or type full name] of 19 _______________________________________ [print or type full address and 20 telephone number] as my California agent for service of process in connection with 21 this action or any proceedings related to enforcement of this Stipulated Protective 22 Order. 23 Date: ______________________________________ 24 City and State where sworn and signed: _________________________________ 25 26 Printed name: _______________________________ 27 28 Signature: __________________________________ 16 1648101.1 Case $:21-cv-00839-JLS-DFM Document 41 Filed 04/18/22 Page17of18 Page ID #:206

PROOF OF SERVICE

5 STATE OF CALIFORNIA, COUNTY OF ORANGE I am over the age of 18 and not a patty to the within action; I am employed by 3 || WOODRUFF, SPRADLIN & SMART in the County of Orange at 555 “Anton 4 Boulevard, Suite 1200, Costa Mesa, CA 92626-7670. On Apt 12, 2022, I served the foregoing document(s) described as 5 || STIPULATED PROTECTIVE ORDER 6 || O by placing the true copies thereof enclosed in sealed envelopes addressed as 5 stated on the attached mailing list; L) by placing L) the original U a true copy thereof enclosed in sealed envelopes 8 addressed as follows: g || O (BY MAIL) I placed said envelope(s) for collection and mailing. following ordinary business practices, at the business offices of WOODRUFF, 10 SPRADLIN & SMART, and addressed as shown on the attached service list, or deposit in the United States Postal Service. | am readily familiar with the for de he United States Postal S I dily familiar with th 1 practice of WOODRUFF, SPRADLIN & SMART for collection and processing correspondence for mailing with the United States Postal Service, 12 and said envclope(s) will be deposited with the United States Postal Service on said date in the ordinary course of business. 8 (BY ELECTRONIC SERVICE) by causing the foregoing document(s) to be 14 electronically filed using. the Court’s Electronic Filing System which constitutes service of the filed document(s) on the individual(s) listed on the 15 attached mailing list. 16 || O (BY OVERNIGHT DELIVERY) I placed said documents in. envelopes) for collection following ordinary business practices, at the business offices of 17 WOODRUFF, SPRADLIN & SMART, and addressed as shown on_the attached service list, for collection and delivery to a courier authorized_by 18 to receive said documents, with delivery fees provided for. I am readily familiar with the practices of WOODRUFF, 19 PRADLIN & SMART for collection and processing. of documents for overnight delivery, and said envelope(s) will be deposited for receipt by 20 on said date in the ordinary course of business. 1 (Federal) I declare that | am employed in the office of a member of the bar of this court at whose direction the service was made. I declare under penalty of perjury that the above ts true and correct. 22 23 Executed on April 12, 2022, at Costa Mesa, California. “a s/ Vilay Lee 25 VILAY LEE 26 27 28 17 1648101.1

Case 8:21-cv-00839-JLS-DFM Document 41 Filed 04/18/22 Page 18 of 18 Page ID #:207

SHEILA BATES v. CITY OF TORRANCE, et al. 1 USDC, CENTRAL DISTRICT OF CALIFORNIA 2 CASE NO. 8:21-cv-00839-JLS-DFMx 3 BEFORE THE HONORABLE JOSEPHINE L. STATON 4 COURTROOM 10A 5 SERVICE LIST 6 Erin Darling Attorney for Plaintiff 7 LAW OFFICES OF ERIN DARLING SHEILA BATES 3435 Wilshire Blvd., Suite 2910 8 Los Angeles, CA 90010 Telephone: (323) 736-2230 9 Email: [email protected] 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 18 1648101.1