Case 2:21-cv-08065-DSF-GJS Document 51 Filed 05/27/22 Page 1 of 17 Page ID #:323

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7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA

10 HEATHER WILSON, AMANDA Case No. 2:21-cv-8065-DSF-GJS LUNDBERG, JESUS CAMPOS, 11 JUVEL MAR INGAL, PATRICIA FOLGER, JEFF FLEISS, MALINA STIPULATED PROTECTIVE 12 TRAN, and SILVIO CURTIS, ORDER1 individuals, 13

14 Plaintiff,

15 v.

16 L.A. ARENA COMPANY, LLC, L.A. LIVE PROPERTIES, LLC; 17 CITY OF LOS ANGELES; OFFICER MARTINEZ, OFFICER 18 ARAMBULA, in their individual capacities; and DOES 1–10, 19 inclusive, 20 Defendant.

21 22 1. A. PURPOSES AND LIMITATIONS 23 Discovery in this action is likely to involve production of confidential, 24 proprietary or private information for which special protection from public 25 disclosure and from use for any purpose other than prosecuting this litigation may 26 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 27

28 1 This Stipulated Protective Order is substantially based on the model protective order provided under Magistrate Judge Gail J. Standish’s Procedures.

14216530.1 Case 2:21-cv-08065-DSF-GJS Document 51 Filed 05/27/22 Page 2 of 17 Page ID #:324

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. 6 B. GOOD CAUSE STATEMENT 7 This action involves the City of Los Angeles, the Los Angeles Police 8 Department, L.A. Arena Company, LLC, and L.A. Live Properties, LLC, 9 (“Defendants”). Plaintiffs are seeking materials and information that Defendants 10 maintain as confidential, such as Internal Affairs materials and information, video 11 recordings, audio recordings, and information, personnel records and other 12 administrative materials and information currently in the possession of Defendants 13 which may be entitled to special protection from public disclosure and from use for 14 any purpose other than prosecuting this litigation. Additionally, discovery may 15 include sensitive confidential financial and business information, which may require 16 heightened protection from public disclosure and from use for any purpose other 17 than prosecuting this litigation. 18 Accordingly, to expedite the flow of information, to facilitate the prompt 19 resolution of disputes over confidentiality of discovery materials, to adequately 20 protect information the parties are entitled to keep confidential, to ensure that the 21 parties are permitted reasonable necessary uses of such material in preparation for 22 and in the conduct of trial, to address their handling at the end of the litigation, and 23 serve the ends of justice, a protective order for such information is justified in this 24 matter. It is the intent of the parties that information will not be designated as 25 confidential for tactical reasons and that nothing be so designated without a good 26 faith belief that it has been maintained in a confidential, non-public manner, and 27 there is good cause why it should not be part of the public record of this case. This 28 also includes (1) any information copied or extracted from the Confidential 2 14216530.1 Case 2:21-cv-08065-DSF-GJS Document 51 Filed 05/27/22 Page 3 of 17 Page ID #:325

1 information; (2) copies, excerpts, summaries or compilations of Confidential 2 information; and (3) any testimony, conversations, or presentations that are 3 reasonably likely to reveal Confidential information. 4 5 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 6 The parties further acknowledge, as set forth in Section 12.3, below, that this 7 Stipulated Protective Order does not entitle them to file confidential information 8 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed 9 and the standards that will be applied when a party seeks permission from the court 10 to file material under seal. 11 There is a strong presumption that the public has a right of access to judicial 12 proceedings and records in civil cases. In connection with non-dispositive motions, 13 good cause must be shown to support a filing under seal. See Kamakana v. City and 14 County of Honolulu,

(9th Cir. 2006), Phillips v. Gen. Motors 15 Corp.,

, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, 16 Inc.,

(E.D. Wis. 1999) (even stipulated protective orders 17 require good cause showing), and a specific showing of good cause or compelling 18 reasons with proper evidentiary support and legal justification, must be made with 19 respect to Protected Material that a party seeks to file under seal. The parties’ mere 20 designation of Disclosure or Discovery Material as CONFIDENTIAL does not— 21 without the submission of competent evidence by declaration, establishing that the 22 material sought to be filed under seal qualifies as confidential, privileged, or 23 otherwise protectable—constitute good cause. 24 Further, if a party requests sealing related to a dispositive motion or trial, then 25 compelling reasons, not only good cause, for the sealing must be shown, and the 26 relief sought shall be narrowly tailored to serve the specific interest to be protected. 27 See Pintos v. Pacific Creditors Ass’n,

(9th Cir. 2010). For 28 each item or type of information, document, or thing sought to be filed or introduced 3 14216530.1 Case 2:21-cv-08065-DSF-GJS Document 51 Filed 05/27/22 Page 4 of 17 Page ID #:326

1 under seal in connection with a dispositive motion or trial, the party seeking 2 protection must articulate compelling reasons, supported by specific facts and legal 3 justification, for the requested sealing order. Again, competent evidence supporting 4 the application to file documents under seal must be provided by declaration. 5 Any document that is not confidential, privileged, or otherwise protectable in 6 its entirety will not be filed under seal if the confidential portions can be redacted. 7 If documents can be redacted, then a redacted version for public viewing, omitting 8 only the confidential, privileged, or otherwise protectable portions of the document, 9 shall be filed. Any application that seeks to file documents under seal in their 10 entirety should include an explanation of why redaction is not feasible. 11 2. DEFINITIONS 12 2.1 Action: this pending federal lawsuit. 13 2.2 Challenging Party: a Party or Non-Party that challenges the 14 designation of information or items under this Order. 15 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 16 how it is generated, stored or maintained) or tangible things that qualify for 17 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 18 the Good Cause Statement. This also includes (1) any information copied or 19 extracted from the Confidential information; (2) copies, excerpts, summaries or 20 compilations of Confidential information; and (3) any testimony, conversations, or 21 presentations that are reasonably likely to reveal Confidential information. 22 References to “CONFIDENTIAL” information or items in this Protective Order 23 shall also include information or items designated “HIGHLY CONFIDENTIAL – 24 ATTORNEYS’ EYES ONLY,” unless stated otherwise. 25 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 26 their support staff). 27 28 4 14216530.1 Case 2:21-cv-08065-DSF-GJS Document 51 Filed 05/27/22 Page 5 of 17 Page ID #:327

1 2.5 Designating Party: a Party or Non-Party that designates information or 2 items that it produces in disclosures or in responses to discovery as 3 “CONFIDENTIAL.” 4 2.6 Disclosure or Discovery Material: all items or information, regardless 5 of the medium or manner in which it is generated, stored, or maintained (including, 6 among other things, testimony, transcripts, and tangible things), that are produced or 7 generated in disclosures or responses to discovery in this matter. 8 2.7 Expert: a person with specialized knowledge or experience in a matter 9 pertinent to the litigation who has been retained by a Party or its counsel to serve as 10 an expert witness or as a consultant in this Action. 11 2.8 House Counsel: attorneys who are employees of a party to this Action. 12 House Counsel does not include Outside Counsel of Record or any other outside 13 counsel. 14 2.9 Non-Party: any natural person, partnership, corporation, association or 15 other legal entity not named as a Party to this action. 16 2.10 Outside Counsel of Record: attorneys who are not employees of a 17 party to this Action but are retained to represent or advise a party to this Action and 18 have appeared in this Action on behalf of that party or are affiliated with a law firm 19 that has appeared on behalf of that party, and includes support staff. 20 2.11 Party: any party to this Action, including all of its officers, directors, 21 employees, consultants, retained experts, and Outside Counsel of Record (and their 22 support staffs). 23 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 24 Discovery Material in this Action. 25 2.13 Professional Vendors: persons or entities that provide litigation 26 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 27 demonstrations, and organizing, storing, or retrieving data in any form or medium) 28 and their employees and subcontractors. 5 14216530.1 Case 2:21-cv-08065-DSF-GJS Document 51 Filed 05/27/22 Page 6 of 17 Page ID #:328

1 2.14 Protected Material: any Disclosure or Discovery Material that is 2 designated as “CONFIDENTIAL.” 3 2.15 Receiving Party: a Party that receives Disclosure or Discovery 4 Material from a Producing Party. 5 3. SCOPE 6 The protections conferred by this Stipulation and Order cover not only 7 Protected Material (as defined above), but also (1) any information copied or 8 extracted from Protected Material; (2) all copies, excerpts, summaries, or 9 compilations of Protected Material; and (3) any testimony, conversations, or 10 presentations by Parties or their Counsel that are reasonably likely to reveal 11 Protected Material. 12 Any use of Protected Material at trial shall be governed by the orders of the 13 trial judge. This Order does not govern the use of Protected Material at trial. 14 4. DURATION 15 FINAL DISPOSITION of the action is defined as the conclusion of any 16 appellate proceedings, or, if no appeal is taken, when the time for filing of an appeal 17 has run. Except as set forth below, the terms of this protective order apply through 18 FINAL DISPOSITION of the action. The parties may stipulate that they will be 19 contractually bound by the terms of this agreement beyond FINAL DISPOSITION, 20 but will have to file a separate action for enforcement of the agreement once all 21 proceedings in this case are complete. 22 Once a case proceeds to trial, information that was designated as 23 CONFIDENTIAL or maintained pursuant to this protective order used or introduced 24 as an exhibit at trial becomes public and will be presumptively available to all 25 members of the public, including the press, unless compelling reasons supported by 26 specific factual findings to proceed otherwise are made to the trial judge in advance 27 of the trial. See Kamakana,

(distinguishing “good cause” 28 showing for sealing documents produced in discovery from “compelling reasons” 6 14216530.1 Case 2:21-cv-08065-DSF-GJS Document 51 Filed 05/27/22 Page 7 of 17 Page ID #:329

1 standard when merits-related documents are part of court record). Accordingly, for 2 such materials, the terms of this protective order do not extend beyond the 3 commencement of the trial. 4 5. DESIGNATING PROTECTED MATERIAL 5 5.1 Exercise of Restraint and Care in Designating Material for Protection. 6 Each Party or Non-Party that designates information or items for protection under 7 this Order must take care to limit any such designation to specific material that 8 qualifies under the appropriate standards. The Designating Party must designate for 9 protection only those parts of material, documents, items or oral or written 10 communications that qualify so that other portions of the material, documents, items 11 or communications for which protection is not warranted are not swept unjustifiably 12 within the ambit of this Order. 13 Mass, indiscriminate or routinized designations are prohibited. Designations 14 that are shown to be clearly unjustified or that have been made for an improper 15 purpose (e.g., to unnecessarily encumber the case development process or to impose 16 unnecessary expenses and burdens on other parties) may expose the Designating 17 Party to sanctions. 18 If it comes to a Designating Party’s attention that information or items that it 19 designated for protection do not qualify for protection, that Designating Party must 20 promptly notify all other Parties that it is withdrawing the inapplicable designation. 21 5.2 Manner and Timing of Designations. Except as otherwise provided in 22 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 23 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 24 under this Order must be clearly so designated before the material is disclosed or 25 produced. 26 Designation in conformity with this Order requires: 27 (a) for information in documentary form (e.g., paper or electronic 28 documents, but excluding transcripts of depositions or other pretrial or trial 7 14216530.1 Case 2:21-cv-08065-DSF-GJS Document 51 Filed 05/27/22 Page 8 of 17 Page ID #:330

1 proceedings), that the Producing Party affix at a minimum, the legend 2 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 3 ONLY” (hereinafter “CONFIDENTIAL legend”), to each page that contains 4 protected material. If only a portion of the material on a page qualifies for 5 protection, the Producing Party also must clearly identify the protected portion(s) 6 (e.g., by making appropriate markings in the margins). 7 A Party or Non-Party that makes original documents available for inspection 8 need not designate them for protection until after the inspecting Party has indicated 9 which documents it would like copied and produced. During the inspection and 10 before the designation, all of the material made available for inspection shall be 11 deemed “CONFIDENTIAL” (not “HIGHLY CONFIDENTIAL – ATTORNEYS’ 12 EYES ONLY”). After the inspecting Party has identified the documents it wants 13 copied and produced, the Producing Party must determine which documents, or 14 portions thereof, qualify for protection under this Order. Then, before producing the 15 specified documents, the Producing Party must affix the “CONFIDENTIAL legend” 16 to each page that contains Protected Material. If only a portion of the material on a 17 page qualifies for protection, the Producing Party also must clearly identify the 18 protected portion(s) (e.g., by making appropriate markings in the margins). 19 (b) for testimony given in depositions that the Designating Party identifies 20 the Disclosure or Discovery Material on the record, before the close of the 21 deposition all protected testimony. Any Party also may designate information 22 disclosed at a deposition as “CONFIDENTIAL” (or “HIGHLY CONFIDENTIAL – 23 ATTORNEYS’ EYES ONLY”) by notifying all Parties in writing, not later than 30 24 days after receipt of the transcript, of the specific pages and lines of the transcript 25 that should be treated thereafter as “CONFIDENTIAL.” All deposition transcripts 26 shall be treated as “CONFIDENTIAL” (not “HIGHLY CONFIDENTIAL – 27 ATTORNEYS’ EYES ONLY”) for a period of 30 days after initial receipt of the 28 transcript. 8 14216530.1 Case 2:21-cv-08065-DSF-GJS Document 51 Filed 05/27/22 Page 9 of 17 Page ID #:331

1 (c) for information produced in some form other than documentary and 2 for any other tangible items, that the Producing Party affix in a prominent place on 3 the exterior of the container or containers in which the information is stored the 4 “CONFIDENTIAL legend.” If only a portion or portions of the information 5 warrants protection, the Producing Party, to the extent practicable, shall identify the 6 protected portion(s). 7 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 8 failure to designate qualified information or items does not, standing alone, waive 9 the Designating Party’s right to secure protection under this Order for such material. 10 Upon timely correction of a designation, the Receiving Party must make reasonable 11 efforts to assure that the material is treated in accordance with the provisions of this 12 Order. 13 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 14 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 15 designation of confidentiality at any time that is consistent with the Court’s 16 Scheduling Order. 17 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 18 resolution process under Local Rule 37.1 et seq. 19 6.3 The burden of persuasion in any such challenge proceeding shall be on 20 the Designating Party. Frivolous challenges, and those made for an improper 21 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 22 parties) may expose the Challenging Party to sanctions. Unless the Designating 23 Party has waived or withdrawn the confidentiality designation, all parties shall 24 continue to afford the material in question the level of protection to which it is 25 entitled under the Producing Party’s designation until the Court rules on the 26 challenge. 27 28 9 14216530.1 Case 2:21-cv-08065-DSF-GJS Document 51 Filed 05/27/22 Page 10 of 17 Page ID #:332

1 7. ACCESS TO AND USE OF PROTECTED MATERIAL 2 7.1 Basic Principles. A Receiving Party may use Protected Material that is 3 disclosed or produced by another Party or by a Non-Party in connection with this 4 Action only for prosecuting, defending or attempting to settle this Action. Such 5 Protected Material may be disclosed only to the categories of persons and under the 6 conditions described in this Order. When the Action has been terminated, a 7 Receiving Party must comply with the provisions of section 13 below (FINAL 8 DISPOSITION). 9 Protected Material must be stored and maintained by a Receiving Party at a 10 location and in a secure manner that ensures that access is limited to the persons 11 authorized under this Order. 12 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 13 otherwise ordered by the court or permitted in writing by the Designating Party, a 14 Receiving Party may disclose any information or item designated 15 “CONFIDENTIAL” only to: 16 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 17 well as employees of said Outside Counsel of Record to whom it is reasonably 18 necessary to disclose the information for this Action; 19 (b) the officers, directors, and employees (including House Counsel) of 20 the Receiving Party to whom disclosure is reasonably necessary for this Action; 21 (c) Experts (as defined in this Order) of the Receiving Party to whom 22 disclosure is reasonably necessary for this Action and who have signed the 23 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 24 (d) the court and its personnel; 25 (e) court reporters and their staff; 26 (f) professional jury or trial consultants, and mock jurors, to whom 27 disclosure is reasonably necessary for this Action and who have signed the 28 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 10 14216530.1 Case 2:21-cv-08065-DSF-GJS Document 51 Filed 05/27/22 Page 11 of 17 Page ID #:333

1 (g) Professional Vendors to whom disclosure is reasonably necessary for 2 this Action, and who have signed the “Acknowledgment and Agreement to Be 3 Bound” (Exhibit A) within 30 days of the provision of services; 4 (h) the author or recipient of a document containing the information or a 5 custodian or other person who otherwise possessed or knew the information; 6 (i) during their depositions, witnesses, and attorneys for witnesses, in the 7 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 8 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will 9 not be permitted to keep any confidential information unless they sign the 10 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 11 agreed by the Designating Party or ordered by the court. Pages of transcribed 12 deposition testimony or exhibits to depositions that reveal Protected Material may 13 be separately bound by the court reporter and may not be disclosed to anyone except 14 as permitted under this Stipulated Protective Order; and 15 (j) any mediator or settlement officer, and their supporting personnel, 16 mutually agreed upon by any of the parties engaged in settlement discussions. 17 7.3 Disclosure of “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 18 ONLY” Information or Items. Unless otherwise ordered by the court or permitted in 19 writing by the Designating Party, a Receiving Party may disclose any information or 20 item designated “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” only 21 to the persons listed in Paragraphs 7.2(a), (c), (d), (e), (f), (g), (h), and (j) above and 22 House Counsel of the Receiving Party. 23 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 24 IN OTHER LITIGATION 25 If a Party is served with a subpoena or a court order issued in other litigation 26 that compels disclosure of any information or items designated in this Action as 27 “CONFIDENTIAL,” that Party must: 28 11 14216530.1 Case 2:21-cv-08065-DSF-GJS Document 51 Filed 05/27/22 Page 12 of 17 Page ID #:334

1 (a) promptly notify in writing the Designating Party. Such notification 2 shall include a copy of the subpoena or court order; 3 (b) promptly notify in writing the party who caused the subpoena or order 4 to issue in the other litigation that some or all of the material covered by the 5 subpoena or order is subject to this Protective Order. Such notification shall include 6 a copy of this Stipulated Protective Order; and 7 (c) cooperate with respect to all reasonable procedures sought to be 8 pursued by the Designating Party whose Protected Material may be affected. 9 If the Designating Party timely seeks a protective order, the Party served with 10 the subpoena or court order shall not produce any information designated in this 11 action as “CONFIDENTIAL” before a determination by the court from which the 12 subpoena or order issued, unless the Party has obtained the Designating Party’s 13 permission. The Designating Party shall bear the burden and expense of seeking 14 protection in that court of its confidential material and nothing in these provisions 15 should be construed as authorizing or encouraging a Receiving Party in this Action 16 to disobey a lawful directive from another court. 17 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 18 PRODUCED IN THIS LITIGATION 19 (a) The terms of this Order are applicable to information produced by a 20 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 21 produced by Non-Parties in connection with this litigation is protected by the 22 remedies and relief provided by this Order. Nothing in these provisions should be 23 construed as prohibiting a Non-Party from seeking additional protections. 24 (b) In the event that a Party is required, by a valid discovery request, to 25 produce a Non-Party’s confidential information in its possession, and the Party is 26 subject to an agreement with the Non-Party not to produce the Non-Party’s 27 confidential information, then the Party shall: 28 12 14216530.1 Case 2:21-cv-08065-DSF-GJS Document 51 Filed 05/27/22 Page 13 of 17 Page ID #:335

1 (1) promptly notify in writing the Requesting Party and the Non-Party 2 that some or all of the information requested is subject to a confidentiality 3 agreement with a Non-Party; 4 (2) promptly provide the Non-Party with a copy of the Stipulated 5 Protective Order in this Action, the relevant discovery request(s), and a reasonably 6 specific description of the information requested; and 7 (3) make the information requested available for inspection by the 8 Non-Party, if requested. 9 (c) If the Non-Party fails to seek a protective order from this court within 10 14 days of receiving the notice and accompanying information, the Receiving Party 11 may produce the Non-Party’s confidential information responsive to the discovery 12 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 13 not produce any information in its possession or control that is subject to the 14 confidentiality agreement with the Non-Party before a determination by the court. 15 Absent a court order to the contrary, the Non-Party shall bear the burden and 16 expense of seeking protection in this court of its Protected Material. 17 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 18 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 19 Protected Material to any person or in any circumstance not authorized under this 20 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 21 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 22 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 23 persons to whom unauthorized disclosures were made of all the terms of this Order, 24 and (d) request such person or persons to execute the “Acknowledgment and 25 Agreement to Be Bound” that is attached hereto as Exhibit A. 26 27 28 13 14216530.1 Case 2:21-cv-08065-DSF-GJS Document 51 Filed 05/27/22 Page 14 of 17 Page ID #:336

1 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 2 PROTECTED MATERIAL 3 When a Producing Party gives notice to Receiving Parties that certain 4 inadvertently produced material is subject to a claim of privilege or other protection, 5 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 6 Procedure 26(b)(5)(B). This provision is not intended to modify whatever 7 procedure may be established in an e-discovery order that provides for production 8 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e) 9 the inadvertent disclosure or production of documents protected by the attorney- 10 client privilege or work-product protection will not constitute a waiver of the 11 privilege or protection by the disclosing Party in either the litigation pending before 12 the Court, or any other federal or state proceeding. 13 12. MISCELLANEOUS 14 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 15 person to seek its modification by the Court in the future. 16 12.2 Right to Assert Other Objections. By stipulating to the entry of this 17 Protective Order, no Party waives any right it otherwise would have to object to 18 disclosing or producing any information or item on any ground not addressed in this 19 Stipulated Protective Order. Similarly, no Party waives any right to object on any 20 ground to use in evidence of any of the material covered by this Protective Order. 21 12.3 Filing Protected Material. A Party that seeks to file under seal any 22 Protected Material must comply with Local Civil Rule 79-5. Protected Material 23 may only be filed under seal pursuant to a court order authorizing the sealing of the 24 specific Protected Material at issue. If a Party’s request to file Protected Material 25 under seal is denied by the court, then the Receiving Party may file the information 26 in the public record unless otherwise instructed by the court. 27 28 14 14216530.1 Case 2:21-cv-08065-DSF-GJS Document 51 Filed 05/27/22 Page 15 of 17 Page ID #:337

1 13. FINAL DISPOSITION 2 After the final disposition of this Action, as defined in paragraph 4, within 60 3 days of a written request by the Designating Party, each Receiving Party must return 4 all Protected Material to the Producing Party or destroy such material. As used in 5 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 6 summaries, and any other format reproducing or capturing any of the Protected 7 Material. Whether the Protected Material is returned or destroyed, the Receiving 8 Party must submit a written certification to the Producing Party (and, if not the same 9 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 10 (by category, where appropriate) all the Protected Material that was returned or 11 destroyed and (2) affirms that the Receiving Party has not retained any copies, 12 abstracts, compilations, summaries or any other format reproducing or capturing any 13 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 14 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 15 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 16 reports, attorney work product, and consultant and expert work product, even if such 17 materials contain Protected Material. Any such archival copies that contain or 18 constitute Protected Material remain subject to this Protective Order as set forth in 19 Section 4 (DURATION). 20 21 // 22 23 24 25 // 26 27 28 // 15 14216530.1 Case □□□□□□□□□□□□□□□□□□□□□ Document 51 Filed 05/27/22 Page 16of17 Page ID #:338

1 || 14. VIOLATION 2 || Any violation of this Order may be punished by appropriate measures including, 3 || without limitation, contempt proceedings and/or monetary sanctions. 5 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD. 7 || Dated: May 24, 2022 LAW OFFICE OF JEROLD D. FRIEDMAN 8 /s/Jerold D. Friedman Jerold D. Friedman, Esq. 9 Attorneys for Plaintiffs 10 11 || Dated: May 24, 2022 MITCHELL SILBERBERG & KNUPP LLP 12 /s/Emily F. Evitt Emily F. Evitt, Esq. 13 Attorneys for Defendants L.A. Live Properties, 4 LLC, L.A. Arena Company, LLC

1S |) Dated: May 24, 2022 MICHAEL N. FEUER, City Attorney SCOTT MARCUS, Chief Assistant City Attorney 16 CORY M. BRENTE, Sr. Assistant City Attorney 7 DORDANEH GHAEMI, Deputy City Attorney /s(Dordaneh Ghaemi 18 Dordaneh Ghaemi, Deputy, City Attorney 19 Attorneys for Defendant City of Los Angeles 20 |} FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 21 22 || DATED: May 27, 2022 HON. GAIL J. STANDISH 23 United States Magistrate Judge 24 25 26 27 28 16 14216530.1

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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 penalty of perjury 5 that I have read in its entirety and understand the Stipulated Protective Order that 6 was issued by the United States District Court for the Central District of California 7 in the case of Heather Wilson, et al v. L.A. Arena Company, LLC, et al., Case No. 8 CV21-8065-DSF (GJSx), I agree to comply with and to be bound by all the terms of 9 this Stipulated Protective Order and I understand and acknowledge that failure to so 10 comply could expose me to sanctions and punishment in the nature of contempt. I 11 solemnly promise that I will not disclose in any manner any information or item that 12 is subject to this Stipulated Protective Order to any person or entity except in strict 13 compliance with the provisions of this Order. 14 I further agree to submit to the jurisdiction of the United States District Court for the 15 Central District of California for enforcing the terms of this Stipulated Protective 16 Order, even if such enforcement proceedings occur after termination of this action. 17 I hereby appoint __________________________ [print or type full name] of 18 _______________________________________ [print or type full address and 19 telephone number] as my California agent for service of process in connection with 20 this action or any proceedings related to enforcement of this Stipulated Protective 21 Order. 22 Date: ______________________________________ 23 City and State where sworn and signed: _________________________________ 24 Printed name: _______________________________ 25 26 Signature: __________________________________ 27 28 17 14216530.1