CCaassee 22::2211--ccvv--0022116655--FFLLAA--PPDD DDooccuummeenntt 2289 FFiilleedd 0055//1189//2222 PPaaggee 11 ooff 1166 PPaaggee IIDD ##::118928

1 JILL WILLIAMS – State Bar No. 221793 [email protected] 2 DANIELLE C. FOSTER – State Bar No. 281385 [email protected] 3 CARPENTER, ROTHANS & DUMONT 500 S. Grand Avenue, 19th Floor 4 Los Angeles, CA 90071 (213) 228-0400 / (213) 228-0401 (fax)

5 Attorneys for Defendant County of Los Angeles

6

7

8 UNITED STATES DISTRICT COURT

9 CENTRAL DISTRICT OF CALIFORNIA

10

11 N.B, a minor, et al. ) Case No.: 2:21-cv-02165-FLA-PD ) 12 Plaintiffs, ) ) ** DISCOVERY MATTER ** 13 vs. ) ) 14 COUNTY OF LOS ANGELES, et al. ) STIPULATED PROTECTIVE ) ORDER1 15 Defendants. ) ) 16 ) ) Hon. Patricia Donahue 17 ) U.S. Magistrate Judge

18 19 IT IS HEREBY STIPULATED by and among the parties hereto, through 20 their respective counsel of record, as follows: 21 1A. PURPOSES AND LIMITATIONS 22 Discovery in this action is likely to involve production of confidential and 23 private information for which special protection from public disclosure and from 24 use for any purpose other than prosecuting this litigation may be warranted. 25 Accordingly, the parties hereby stipulate to and petition the Court to enter the 26 27 28 1 This Stipulated Protective Order is substantially based on the model protective order provided under Magistrate Judge Patricia Donahue’s Procedures. - 1 - STIPULATED PROTECTIVE ORDER CCaassee 22::2211--ccvv--0022116655--FFLLAA--PPDD DDooccuummeenntt 2289 FFiilleedd 0055//1189//2222 PPaaggee 22 ooff 1166 PPaaggee IIDD ##::118939

1 following Stipulated Protective Order. The parties acknowledge that this Order 2 does not confer blanket protections on all disclosures or responses to discovery and 3 that the protection it affords from public disclosure and use extends only to the 4 limited information or items that are entitled to confidential treatment under the 5 applicable legal principles. 6 1B. GOOD CAUSE STATEMENT 7 This action is likely to involve confidential and private information for 8 which special protection from public disclosure and from use for any purpose other 9 than litigation of this action is warranted. Such information may implicate the 10 privacy interests of the parties and non-parties, and are properly protected through 11 a Federal Rule of Civil Procedure 26(c) protective order. See Seattle Times Co. v. 12 Rhinehart,

, 35 n.21 (1984) (“Rule 26(c) includes among its express 13 purposes the protection of a ‘party or person from annoyance, embarrassment, 14 oppression or undue burden or expense.’ Although the Rule contains no specific 15 reference to privacy or to other rights or interests that may be implicated, such 16 matters are implicit in the broad purpose and language of the Rule.”); Soto v. City 17 of Concord,

(N.D. Cal. 1995) (a party’s privacy rights are to 18 be protected through a “carefully crafted protective order.”). 19 Such confidential materials and information consist of, among other things, 20 peace officer investigations, sensitive reports, medical records, information 21 implicating privacy rights of parties and third parties, and information otherwise 22 generally unavailable to the public, or which may be privileged or otherwise 23 protected from disclosure under state or federal statutes, court rules, case decisions, 24 or common law. Accordingly, to expedite the flow of information, to facilitate the 25 prompt resolution of disputes over confidentiality of discovery materials, to 26 adequately protect information the parties are entitled to keep confidential, to 27 ensure that the parties are permitted reasonable necessary uses of such material in 28 preparation for and in the conduct of trial, to address their handling at the end of - 2 - STIPULATED PROTECTIVE ORDER CCaassee 22::2211--ccvv--0022116655--FFLLAA--PPDD DDooccuummeenntt 2289 FFiilleedd 0055//1189//2222 PPaaggee 33 ooff 1166 PPaaggee IIDD ##::128040

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

(9th Cir. 2006), Phillips v. 18 Gen. Motors Corp.,

, 1210-11 (9th Cir. 2002), Makar-Welbon v. 19 Sony Electrics, Inc.,

(E.D. Wis. 1999) (even stipulated 20 protective orders require good cause showing), and a specific showing of good 21 cause or compelling reasons with proper evidentiary support and legal justification, 22 must be made with respect to Protected Material that a party seeks to file under 23 seal. The parties’ mere designation of Disclosure or Discovery Material as 24 CONFIDENTIAL does not—without the submission of competent evidence by 25 declaration, establishing that the material sought to be filed under seal qualifies as 26 confidential, privileged, or otherwise protectable—constitute good cause. 27 Further, if a party requests sealing related to a dispositive motion or trial, 28 then compelling reasons, not only good cause, for the sealing must be shown, and - 3 - STIPULATED PROTECTIVE ORDER CCaassee 22::2211--ccvv--0022116655--FFLLAA--PPDD DDooccuummeenntt 2289 FFiilleedd 0055//1189//2222 PPaaggee 44 ooff 1166 PPaaggee IIDD ##::128051

1 the relief sought shall be narrowly tailored to serve the specific interest to be 2 protected. See Pintos v. Pacific Creditors Ass’n,

(9th Cir. 3 2010). For each item or type of information, document, or thing sought to be filed 4 or introduced under seal in connection with a dispositive motion or trial, the party 5 seeking protection must articulate compelling reasons, supported by specific facts 6 and legal justification, for the requested sealing order. Again, competent evidence 7 supporting the application to file documents under seal must be provided by 8 declaration. 9 Any document that is not confidential, privileged, or otherwise protectable 10 in its entirety will not be filed under seal if the confidential portions can be 11 redacted. If documents can be redacted, then a redacted version for public 12 viewing, omitting only the confidential, privileged, or otherwise protectable 13 portions of the document, shall be filed. Any application that seeks to file 14 documents under seal in their entirety should include an explanation of why 15 redaction is not feasible. 16 2. DEFINITIONS 17 2.1 Action: This pending federal lawsuit, bearing case number 2:21-cv- 18 02165-FLA-PD. 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 of 22 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 24 the 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 28 or items that it produces in disclosures or in responses to discovery as - 4 - STIPULATED PROTECTIVE ORDER CCaassee 22::2211--ccvv--0022116655--FFLLAA--PPDD DDooccuummeenntt 2289 FFiilleedd 0055//1189//2222 PPaaggee 55 ooff 1166 PPaaggee IIDD ##::128062

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 5 or generated in disclosures or responses to discovery in this matter. 6 2.7 Expert: A person with specialized knowledge or experience in a 7 matter pertinent to the litigation who has been retained by a Party or its counsel to 8 serve as an expert witness or as a consultant in this Action. 9 2.8 House Counsel: Attorneys who are employees of a Party to this 10 Action. House Counsel does not include Outside Counsel of Record or any other 11 outside counsel. 12 2.9 Non-Party: Any natural person, partnership, corporation, association, 13 or 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 15 Party to this Action but are retained to represent or advise a party to this Action 16 and have appeared in this Action on behalf of that Party or are affiliated with a law 17 firm which 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 24 support 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 - STIPULATED PROTECTIVE ORDER CCaassee 22::2211--ccvv--0022116655--FFLLAA--PPDD DDooccuummeenntt 2289 FFiilleedd 0055//1189//2222 PPaaggee 66 ooff 1166 PPaaggee IIDD ##::128073

1 2.15 Receiving Party: A Party that receives Disclosure or Discovery 2 Material 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 6 extracted from Protected Material; (2) all copies, excerpts, summaries, or 7 compilations of Protected Material; and (3) any testimony, conversations, or 8 presentations by Parties 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 4. DURATION 12 FINAL DISPOSITION of the action is defined as the conclusion of any 13 appellate proceedings, or, if no appeal is taken, when the time for filing of an 14 appeal has run. Except as set forth below, the terms of this protective order apply 15 through FINAL DISPOSITION of the action. The parties may stipulate that the 16 they will be contractually bound by the terms of this agreement beyond FINAL 17 DISPOSITION, but will have to file a separate action for enforcement of the 18 agreement once all proceedings in this case are complete. 19 Once a case proceeds to trial, information that was designated as 20 CONFIDENTIAL or maintained pursuant to this protective order used or 21 introduced as an exhibit at trial becomes public and will be presumptively 22 available to all members of the public, including the press, unless compelling 23 reasons supported by specific factual findings to proceed otherwise are made to the 24 trial judge in advance of the trial. See Kamakana,

-81 25 (distinguishing “good cause” showing for sealing documents produced in 26 discovery from “compelling reasons” standard when merits-related documents are 27 part of court record). Accordingly, for such materials, the terms of this protective 28 order do not extend beyond the commencement of the trial. - 6 - STIPULATED PROTECTIVE ORDER CCaassee 22::2211--ccvv--0022116655--FFLLAA--PPDD DDooccuummeenntt 2289 FFiilleedd 0055//1189//2222 PPaaggee 77 ooff 1166 PPaaggee IIDD ##::128084

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 4 under this Order must take care to limit any such designation to specific material 5 that qualifies under the appropriate standards. The Designating Party must 6 designate for protection only those parts of material, documents, items or oral or 7 written communications that qualify so that other portions of the material, 8 documents, items or communications for which protection is not warranted are not 9 swept unjustifiably within the ambit of this Order. 10 Mass, indiscriminate or routinized designations are prohibited. Designations 11 that are shown to be clearly unjustified or that have been made for an improper 12 purpose (e.g., to unnecessarily encumber the case development process or to 13 impose unnecessary expenses and burdens on other parties) may expose the 14 Designating Party to sanctions. 15 If it comes to a Designating Party’s attention that information or items that it 16 designated for protection do not qualify for protection, that Designating Party must 17 promptly notify all other Parties that it is withdrawing the inapplicable designation. 18 5.2 Manner and Timing of Designations. Except as otherwise provided in 19 this Order (see, e.g., second paragraph of Section 5.2(a) below), or as otherwise 20 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 21 under this Order must be clearly so designated before the material is disclosed or 22 produced. 23 Designation in conformity with this Order requires: 24 (a) For information in documentary form (e.g., paper or electronic 25 documents, but excluding transcripts of depositions or other pretrial or trial 26 proceedings), that the Producing Party affix at a minimum, the legend 27 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 28 contains protected material. If only a portion or portions of the material on a page - 7 - STIPULATED PROTECTIVE ORDER CCaassee 22::2211--ccvv--0022116655--FFLLAA--PPDD DDooccuummeenntt 2289 FFiilleedd 0055//1189//2222 PPaaggee 88 ooff 1166 PPaaggee IIDD ##::128095

1 qualifies for protection, the Producing Party also must clearly identify the 2 protected 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 6 before the designation, all of the material made available for inspection shall be 7 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 8 documents it wants copied and produced, the Producing Party must determine 9 which documents, or portions thereof, qualify for protection under this Order. 10 Then, before producing the specified documents, the Producing Party must affix 11 the “CONFIDENTIAL legend” to each page that contains Protected Material. If 12 only a portion or portions of the material on a page qualifies for protection, the 13 Producing Party also must clearly identify the protected portion(s) (e.g., by making 14 appropriate markings in the 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 20 place on the exterior of the container or containers in which the information is 21 stored the legend “CONFIDENTIAL.” If only a portion or portions of the 22 information warrants protection, the Producing Party, to the extent practicable, 23 shall identify the 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 reasonable efforts to assure that the material is treated in accordance with the - 8 - STIPULATED PROTECTIVE ORDER CCaassee 22::2211--ccvv--0022116655--FFLLAA--PPDD DDooccuummeenntt 2289 FFiilleedd 0055//1189//2222 PPaaggee 99 ooff 1166 PPaaggee IIDD ##::129006

1 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 under Local Rule 37.1 et seq. 8 6.3 The burden of persuasion in any such challenge proceeding shall be 9 on the Designating Party. Frivolous challenges, and those made for an improper 10 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 11 parties) may expose the Challenging Party to sanctions. Unless the Designating 12 Party has waived or withdrawn the confidentiality designation, all parties shall 13 continue to afford the material in question the level of protection to which it is 14 entitled under the Producing Party’s designation until the Court rules on the 15 challenge. 16 7. ACCESS TO AND USE OF PROTECTED MATERIAL 17 7.1 Basic Principles. A Receiving Party may use Protected Material that 18 is disclosed or produced by another Party or by a Non-Party in connection with 19 this Action only for prosecuting, defending, or attempting to settle this Action. 20 Such Protected Material may be disclosed only to the categories of persons and 21 under the conditions described in this Order. When the Action has been 22 terminated, a Receiving Party must comply with the provisions of Section 13 23 below (FINAL DISPOSITION). 24 Protected Material must be stored and maintained by a Receiving Party at a 25 location and in a secure manner that ensures that access is limited to the persons 26 authorized under this Order. 27 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 28 otherwise ordered by the court or permitted in writing by the Designating Party, a - 9 - STIPULATED PROTECTIVE ORDER CCaassee 22::2211--ccvv--0022116655--FFLLAA--PPDD DDooccuummeenntt 2289 FFiilleedd 0055//1189//2222 PPaaggee 1100 ooff 1166 PPaaggee IIDD ##::129017

1 Receiving Party may disclose any information or item designated 2 “CONFIDENTIAL” only to: 3 (a) The Receiving Party’s Outside Counsel of Record in this 4 Action, as well as employees of said Outside Counsel of Record to whom it is 5 reasonably necessary to disclose the information for this Action; 6 (b) The officers, directors, and employees (including House 7 Counsel) of the Receiving Party to whom disclosure is reasonably necessary for 8 this Action; 9 (c) Experts (as defined in this Order) of the Receiving Party to 10 whom disclosure is reasonably necessary for this Action and who have signed the 11 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 12 (d) The court and its personnel; 13 (e) Court reporters and their staff; 14 (f) Professional jury or trial consultants, mock jurors, and 15 Professional Vendors to whom disclosure is reasonably necessary for this Action 16 and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit 17 A); 18 (g) The author or recipient of a document containing the 19 information or a custodian or other person who otherwise possessed or knew the 20 information; 21 (h) During their depositions, witnesses, and attorneys for witnesses, 22 in the Action to whom disclosure is reasonably necessary provided: (i) the 23 deposing party requests that the witness sign the form attached as Exhibit A hereto; 24 and (ii) they will not be permitted to keep any confidential information unless they 25 sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless 26 otherwise agreed by the Designating Party or ordered by the court. Pages of 27 transcribed deposition testimony or exhibits to depositions that reveal Protected 28 Material may be separately bound by the court reporter and may not be disclosed - 10 - STIPULATED PROTECTIVE ORDER CCaassee 22::2211--ccvv--0022116655--FFLLAA--PPDD DDooccuummeenntt 2289 FFiilleedd 0055//1189//2222 PPaaggee 1111 ooff 1166 PPaaggee IIDD ##::129028

1 to anyone except as permitted under this Stipulated Protective Order; and 2 (i) Any mediator or settlement officer, and their supporting 3 personnel, mutually agreed upon by any of the parties engaged in settlement 4 discussions. 5 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 6 PRODUCED IN OTHER LITIGATION 7 If a Party is served with a subpoena or a court order issued in other litigation 8 that compels disclosure of any information or items designated in this Action as 9 “CONFIDENTIAL,” that Party must: 10 (a) Promptly notify in writing the Designating Party. Such notification 11 shall include a copy of the subpoena or court order; 12 (b) Promptly notify in writing the party who caused the subpoena or order 13 to issue in the other litigation that some or all of the material covered by the 14 subpoena or order is subject to this Protective Order. Such notification shall 15 include a copy of this Stipulated Protective Order; and 16 (c) Cooperate with respect to all reasonable procedures sought to be 17 pursued by the Designating Party whose Protected Material may be affected. 18 If the Designating Party timely seeks a protective order, the Party served 19 with the subpoena or court order shall not produce any information designated in 20 this action as “CONFIDENTIAL” before a determination by the court from which 21 the subpoena or order issued, unless the Party has obtained the Designating Party’s 22 permission. The Designating Party shall bear the burden and expense of seeking 23 protection in that court of its confidential material and nothing in these provisions 24 should be construed as authorizing or encouraging a Receiving Party in this Action 25 to disobey a lawful directive from another court. 26 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 27 PRODUCED IN THIS LITIGATION 28 (a) The terms of this Order are applicable to information produced by a - 11 - STIPULATED PROTECTIVE ORDER CCaassee 22::2211--ccvv--0022116655--FFLLAA--PPDD DDooccuummeenntt 2289 FFiilleedd 0055//1189//2222 PPaaggee 1122 ooff 1166 PPaaggee IIDD ##::129039

1 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 3 remedies and relief provided by this Order. Nothing in these provisions should be 4 construed as 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 shall: 9 (i) Promptly notify in writing the Requesting Party and the Non- 10 Party that some or all of the information requested is subject to a confidentiality 11 agreement with a Non-Party; 12 (ii) Promptly provide the Non-Party with a copy of the Stipulated 13 Protective Order in this Action, the relevant discovery request(s), and a reasonably 14 specific description of the information requested; and 15 (iii) Make the information requested available for inspection by the 16 Non-Party, if requested. 17 (c) If the Non-Party fails to seek a protective order from this court within 18 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 shall not produce any information in its possession or control that is subject 22 to the confidentiality agreement with the Non-Party before a determination by the 23 court. Absent a court order to the contrary, the Non-Party shall bear the burden 24 and expense 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 27 disclosed Protected Material to any person or in any circumstance not authorized 28 under this Stipulated Protective Order, the Receiving Party must immediately: (a) - 12 - STIPULATED PROTECTIVE ORDER CCaassee 22::2211--ccvv--0022116655--FFLLAA--PPDD DDooccuummeenntt 2289 FFiilleedd 0055//1189//2222 PPaaggee 1133 ooff 1166 PPaaggee IIDD ##::129140

1 notify in writing the Designating Party of the unauthorized disclosures, (b) use its 2 best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform 3 the person or persons to whom unauthorized disclosures were made of all the terms 4 of this Order, and (d) request such person or persons to execute the 5 “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit

11. INADVERTENT PRODUCTION OF PRIVILEGED OR 8 OTHERWISE 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 11 protection, the obligations of the Receiving Parties are those set forth in Federal 12 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 13 whatever procedure may be established in an e-discovery order that provides for 14 production without prior privilege review. Pursuant to Federal Rule of Evidence 15 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure 16 of a communication or information covered by the attorney-client privilege or 17 work product protection, the parties may incorporate their agreement in the 18 stipulated protective order submitted to the court. 19 12. MISCELLANEOUS 20 12.1 Right to Further Relief. Nothing in this Order abridges the right of 21 any 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 25 this Stipulated Protective Order. Similarly, no Party waives any right to object on 26 any ground to use in evidence of any of the material covered by this Protective 27 Order. 28 12.3 Filing Protected Material. A Party that seeks to file under seal any - 13 - STIPULATED PROTECTIVE ORDER CCaassee 22::2211--ccvv--0022116655--FFLLAA--PPDD DDooccuummeenntt 2289 FFiilleedd 0055//1189//2222 PPaaggee 1144 ooff 1166 PPaaggee IIDD ##::129151

1 Protected Material must comply with Civil Local Rule 79-5. Protected Material 2 may only be filed under seal pursuant to a court order authorizing the sealing of the 3 specific Protected Material at issue. If a Party’s request to file Protected Material 4 under seal is denied by the court, then the Receiving Party may file the information 5 in the public record unless otherwise instructed by the court. 6 13. FINAL DISPOSITION 7 After the final disposition of this Action, as defined in Section 4, within 60 8 days of a written request by the Designating Party, each Receiving Party must 9 return all Protected Material to the Producing Party or destroy such material. As 10 used in this subdivision, “all Protected Material” includes all copies, abstracts, 11 compilations, summaries, and any other format reproducing or capturing any of the 12 Protected Material. Whether the Protected Material is returned or destroyed, the 13 Receiving Party must submit a written certification to the Producing Party (and, if 14 not the same person or entity, to the Designating Party) by the 60 day deadline that 15 (1) identifies (by category, where appropriate) all the Protected Material that was 16 returned or destroyed and (2)affirms that the Receiving Party has not retained any 17 copies, abstracts, compilations, summaries or any other format reproducing or 18 capturing any of the Protected Material. Notwithstanding this provision, Counsel 19 are entitled to retain an archival copy of all pleadings, motion papers, trial, 20 deposition, and hearing transcripts, legal memoranda, correspondence, deposition 21 and trial exhibits, expert reports, attorney work product, and consultant and expert 22 work product, even if such materials contain Protected Material. Any such archival 23 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 any and all appropriate 27 measures including, without limitation, contempt proceedings and/or monetary 28 sanctions. - 14 - STIPULATED PROTECTIVE ORDER Case 2:21-cv-02165-FLA-PD Document 28 Filed 05/18/22 Page 15o0f16 Page ID #:298

1 || IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 3 || DATED: May 18, 2022 LAW OFFICES OF DALE K. GALIPO 4 /s/ Dale K. Galipo 5 By: 6 DALE K. GALIPO Attomey for Plaintiffs - 8 || DATED: May 18, 2022 CARPENTER, ROTHANS & DUMONT 9 /s/ Danielle Foster 10 By JILL WILLIAMS i DANIELLE C. FOSTER 12 Attorneys for Defendant County of Los B Angeles 14 Local Rule 5-4.3.4 15 All other signatories listed, and on whose behalf the filing is submitted, 16 || concur in the filing’s content and have authorized the filing. 17 18 19 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 20 21 IIDATED: May 19, 2022 biatiscur Donati 7 Honorable Patricia Donahue United States Magistrate Judge 23 24 25 26 27 28 -15- STIPULATED PROTECTIVE ORDER

CCaassee 22::2211--ccvv--0022116655--FFLLAA--PPDD DDooccuummeenntt 2289 FFiilleedd 0055//1189//2222 PPaaggee 1166 ooff 1166 PPaaggee IIDD ##::129173

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, ______________________ [print or type full name], of 4 _______________________________ [print or type full address], declare under 5 penalty of perjury that I have read in its entirety and understand the Stipulated 6 Protective Order that was issued by the United States District Court for the Central 7 District of California on ________________ [date] in the case of N.B., et al. v. 8 9 County of Los Angeles, Case No. 2:21-cv-02165-FLA-PD. I agree to comply with and to be bound by all the terms of this Stipulated Protective Order and I 10 understand and acknowledge that failure to so comply could expose me to 11 sanctions and punishment in the nature of contempt. I solemnly promise that I will 12 not disclose in any manner any information or item that is subject to this Stipulated 13 Protective Order to any person or entity except in strict compliance with the 14 provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District 16 Court for the Central District of California for the purpose of enforcing the terms 17 of this Stipulated Protective Order, even if such enforcement proceedings occur 18 after termination of this action. I hereby appoint __________________________ 19 [print or type full name] of _____________________ [print or type full address 20 and telephone number] as my California agent for service of process in connection 21 with this action or any proceedings related to enforcement of this Stipulated 22 Protective Order. 23

24 Date: ______________________________________ 25 City and State where sworn and signed: _________________________________ 26 Printed name: _______________________________ 27 Signature: __________________________________ 28

- 16 - STIPULATED PROTECTIVE ORDER