Case 2:21-cv-09915-FWS-AS Document 28 Filed 07/25/22 Page 1 of 16 Page ID #:209 MICHAEL N. FEUER, City Attorney - SBN 111529 1 SCOTT MARCUS, Chief Assistant City Attorney - SBN 184980 CORY M. BRENTE, Chief Assistant City Attorney – SBN 115453 2 COLLEEN R. SMITH, Deputy City Attorney – SBN 209719 200 North Main Street, 6th Floor, City Hall East 3 Los Angeles, CA 90012 Phone No.: (213) 978-7027 4 Fax No.: (213) 978-8785 5 Email: [email protected] 6 Attorneys for Defendants CITY OF LOS ANGELES, ALEJANDRO HIGAREDA and JUAN AGUILA 7 UNITED STATES DISTRICT COURT 8 CENTRAL DISTRICT OF CALIFORNIA 9 10 11 NATHAN ROCKY GLOVER, CASE NO.: CV21-09915-FWS (ASx) Hon. Fred W. Slaughter, Crtm. 9C, 9th Flr. 12 Plaintiff, Hon. Mag. Alka Sagar, Crtm. 540, 5th Flr. v. 13 CITY OF LOS ANGELES; PROTECTIVE ORDER 14 ALEJANDRO HIGAREDA; JUAN 15 AGUILA; and DOES 1-10, inclusive, 16 Defendants. 17 18 19 1. A. PURPOSES AND LIMITATIONS 20 Discovery in this action is likely to involve production of confidential, proprietary, 21 or private information for which special protection from public disclosure and from use 22 for any purpose other than prosecuting this litigation may be warranted. Accordingly, the 23 parties hereby stipulate to and petition the Court to enter the following Stipulated 24 Protective Order. The parties acknowledge that this Order does not confer blanket 25 protections on all disclosures or responses to discovery and that the protection it affords 26 from public disclosure and use extends only to the limited information or items that are 27 entitled to confidential treatment under the applicable legal principles. The parties further 28 acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective Order does STIPULATED PROTECTIVE ORDER (Glover v. City of Los Angeles, et al) 1 Case 2:21-cv-09915-FWS-AS Document 28 Filed 07/25/22 Page 2 of 16 Page ID #:210

1 not entitle them to file confidential information under seal; Civil Local Rule 79-5 sets forth 2 the procedures that must be followed and the standards that will be applied when a party 3 seeks permission from the court to file material under seal. 4 5 B. GOOD CAUSE STATEMENT 6 This action involves the City of Los Angeles and members of the Los Angeles 7 Police Department. Plaintiff is seeking materials and information that Defendants the City 8 of Los Angeles et al. (“City”) maintain as confidential, such as personnel files of the police 9 officers involved in this incident, Internal Affairs materials and information, video 10 recordings, audio recordings, photographs, Force Investigation Division materials and 11 information and other administrative materials and information currently in the possession 12 of the City and which the City believes need special protection from public disclosure and 13 from use for any purpose other than prosecuting this litigation. Plaintiff is also seeking 14 official information contained in the personnel files of the police officers involved in the 15 subject incident, which the City maintains as strictly confidential and which the City 16 believes need special protection from public disclosure and from use for any purpose other 17 than prosecuting this litigation. 18 The City asserts that the confidentiality of the materials and information sought by 19 Plaintiffs is recognized by California and federal law, as evidenced inter alia by California 20 Penal Code section 832.7 and Kerr v. United States Dist. Ct. for N.D. Cal.,

, 21 198 (9th Cir. 1975), aff'd,

(1976). The City has not publicly released the 22 materials and information referenced above except under protective order or pursuant to 23 a court order, if at all. These materials and information are of the type that has been used 24 to initiate disciplinary action against Los Angeles Police Department (“LAPD”) officers, 25 and has been used as evidence in disciplinary proceedings, where the officers’ conduct 26 was considered to be contrary to LAPD policy. 27 The City contends that absent a protective order delineating the responsibilities of 28 nondisclosure on the part of the parties hereto, there is a specific risk of unnecessary and

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1 undue disclosure by one or more of the many attorneys, secretaries, law clerks, paralegals 2 and expert witnesses involved in this case, as well as the corollary risk of embarrassment, 3 harassment and professional and legal harm on the part of the LAPD officers referenced 4 in the materials and information. 5 The City also contends that the unfettered disclosure of the materials and 6 information, absent a protective order, would allow the media to share this information 7 with potential jurors in the area, impacting the rights of the City herein to receive a fair 8 trial. 9 Accordingly, to expedite the flow of information, to facilitate the prompt resolution 10 of disputes over confidentiality of discovery materials, to adequately protect information 11 the parties are entitled to keep confidential, to ensure that the parties are permitted 12 reasonable necessary uses of such material in preparation for and in the conduct of trial, 13 to address their handling at the end of the litigation, and serve the ends of justice, a 14 protective order for such information is justified in this matter. It is the intent of the parties 15 that information will not be designated as confidential for tactical reasons and that nothing 16 be so designated without a good faith belief that it has been maintained in a confidential, 17 non-public manner, and there is good cause why it should not be part of the public record 18 of this case. 19 The parties agree that there is Good Cause for a Protective Order so as to preserve 20 the respective interests of the parties while streamlining the process of resolving any 21 disagreements. 22 The parties therefore stipulate that there is Good Cause for, and hereby jointly 23 request that the honorable Court issue a Protective Order regarding confidential 24 documents consistent with the terms and provisions of this Stipulation. However, the 25 entry of a Protective Order by the Court pursuant to this Stipulation shall not be construed 26 as any ruling by the Court on the aforementioned legal statements or privilege claims in 27 this section, no shall this section be construed as part of any such Court Order. 28

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1 2. DEFINITIONS 2 2.1 Action: This pending federal lawsuit, Nathan Rocky Glover v. City of Los 3 Angeles, et al. CV21-09915-FWS (ASx). 4 2.2 Challenging Party: a Party or Non-Party that challenges the designation of 5 information or items under this Order. 6 2.3 “CONFIDENTIAL” Information or Items: Information (regardless of 7 how it is generated, stored or maintained) or tangible things that qualify for 8 protection under Federal Rule of Civil Procedure 26(c), and as specified 9 above in the Good Cause Statement. 10 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 11 support staff), including counsel of record for the parties to this civil litigation 12 and their support staff. 13 2.5 Designating Party: A Party or Non-party that designates information or 14 items that it produces in disclosures or in responses to discovery as 15 “CONFIDENTIAL.” 16 2.6 Disclosure or Discovery Material: All items or information, regardless of 17 the medium or manner in which it is generated, stored, or maintained 18 (including, among other things, testimony, transcripts, and tangible things), 19 that are produced or generated in disclosures or responses to discovery in this 20 matter. 21 2.7 Expert: A person with specialized knowledge or experience in a matter 22 pertinent to the litigation who has been retained by a Party or its counsel to 23 serve as an expert witness or as a consultant in this Action. 2.8 House Counsel: Attorneys who are employees of a party to this Action. 24 House Counsel does not include Outside Counsel of Record or any other 25 outside counsel. 26 2.9 Non-party: Any natural person, partnership, corporation, association or 27 other legal entity not named as a Party to this action. 28

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

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1 2 4. DURATION 3 Even after Final Disposition of this litigation, the confidentiality obligations 4 imposed by this Order shall remain in effect until a Designating Party agrees otherwise in 5 writing or a court order otherwise directs. Final disposition of this pending federal Action 6 shall be deemed to be the later of (1) dismissal of all claims and defenses in this federal 7 Action, with or without prejudice; and (2) final judgment in this federal Action after the 8 completion and exhaustion of all appeals, rehearings, remands (as it relates to appeals of 9 this federal Action), trials, or reviews of this federal Action, including the time limits for 10 filing any motions or applications for extension of time pursuant to applicable law. 11 12 5. DESIGNATING PROTECTED MATERIAL 13 5.1 Exercise of Restraint and Care in Designating Material for Protection. 14 Each Party or Nonparty that designates information or items for protection under 15 this Order must take care to limit any such designation to specific material that qualifies 16 under the appropriate standards. The Designating Party must designate for protection only 17 those parts of material, documents, items or oral or written communications that qualify 18 so that other portions of the material, documents, items or communications for which 19 protection is not warranted are not swept unjustifiably within the ambit of this Order. 20 Mass, indiscriminate or routinized designations are prohibited. Designations that 21 are shown to be clearly unjustified or that have been made for an improper purpose (e.g., 22 to unnecessarily encumber the case development process or to impose unnecessary 23 expenses and burdens on other parties) may expose the Designating Party to sanctions. 24 If it comes to a Designating Party’s attention that information or items that it 25 designated for protection do not qualify for protection, that Designating Party must 26 promptly notify all other Parties that it is withdrawing the inapplicable designation. 27 28 STIPULATED PROTECTIVE ORDER (Glover v. City of Los Angeles, et al) 6 Case 2:21-cv-09915-FWS-AS Document 28 Filed 07/25/22 Page 7 of 16 Page ID #:215

1 5.2 Manner and Timing of Designations. Except as otherwise provided in this 2 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or 3 ordered, Disclosure or Discovery Material that qualifies for protection under this Order 4 must be clearly so designated before the material is disclosed or produced. 5 Designation in conformity with this Order requires: 6 (a) for information in documentary form (e.g., paper or electronic 7 documents, but excluding transcripts of depositions or other pretrial or trial proceedings), 8 that the Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 9 “CONFIDENTIAL legend”), to each page that contains protected material. If only a 10 portion or portions of the material on a page qualifies for protection, the Producing Party 11 also must clearly identify the protected portion(s) (e.g., by making appropriate markings 12 in the margins). 13 A Party or Nonparty that makes original documents available for inspection 14 need not designate them for protection until after the inspecting Party has indicated which 15 documents it would like copied and produced. During the inspection and before the 16 designation, all of the material made available for inspection shall be deemed 17 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 18 copied and produced, the Producing Party must determine which documents, or portions 19 thereof, qualify for protection under this Order. Then, before producing the specified 20 documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page 21 that contains Protected Material. If only a portion of the material on a page qualifies for 22 protection, the Producing Party also must clearly identify the protected portion(s) (e.g., by 23 making appropriate markings in the margins). 24 (b) for testimony given in depositions that the Designating Party identifies 25 the Disclosure or Discovery Material on the record, before the close of the deposition all 26 protected testimony. 27 (c) for information produced in some form other than documentary and 28 for any other tangible items, that the Producing Party affix in a prominent place on the

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1 exterior of the container or containers in which the information is stored the legend 2 “CONFIDENTIAL.” If only a portion or portions of the information warrants protection, 3 the Producing Party, to the extent practicable, shall identify the protected portion(s). 4 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 5 failure to designate qualified information or items does not, standing alone, waive the 6 Designating Party’s right to secure protection under this Order for such material. Upon 7 timely correction of a designation, the Receiving Party must make reasonable efforts to 8 assure that the material is treated in accordance with the provisions of this Order. 9 5.4 Alteration of Confidentiality Stamp Prohibited. A Receiving Party shall 10 not alter, edit, or modify any Protected Material so as to conceal, obscure, or remove a 11 “CONFIDENTIAL” stamp or legend thereon; nor shall a Receiving Party take any other 12 action so as to make it appear that Protected Material is not subject to the terms and 13 provisions of this Stipulation and its associated Order. However, nothing in this section 14 shall be construed so as to prevent a Receiving Party from challenging a confidentiality 15 designation subject to the provisions of section 6, infra. 16 17 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 18 6.1 Timing of Challenges. Any Party or Nonparty may challenge a designation 19 of confidentiality at any time that is consistent with the Court’s Scheduling Order. 20 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution 21 process set forth in the Court’s Procedures and Schedules. 22 see http://www.cacd.uscourts.gov/honorable-alka-sagar 23 6.3 Burden of Persuasion. The burden of persuasion in any such challenge 24 proceeding shall be on the Designating Party. Frivolous challenges, and those made for an 25 improper purpose (e.g., to harass or impose unnecessary expenses and burdens on other 26 parties) may expose the Challenging Party to sanctions. Unless the Designating Party has 27 waived or withdrawn the confidentiality designation, all parties shall continue to afford 28

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

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1 (f) professional jury or trial consultants, mock jurors, and Professional Vendors 2 to whom disclosure is reasonably necessary for this Action and who have signed the 3 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 4 (g) 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 (h) during their depositions, witnesses, and attorneys for witnesses, in the Action 7 to whom disclosure is reasonably necessary provided: (1) the deposing party requests that 8 the witness sign the form attached as Exhibit A hereto; and (2) they will not be permitted 9 to keep any confidential information unless they sign the “Acknowledgment and 10 Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party 11 or ordered by the court. Pages of transcribed deposition testimony or exhibits to 12 depositions that reveal Protected Material may be separately bound by the court reporter 13 and may not be disclosed to anyone except as permitted under this Stipulated Protective 14 Order; and 15 (i) Any mediator or settlement officer, and their supporting personnel, mutually 16 agreed upon by any of the parties engaged in settlement discussions. 17 18 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 19 OTHER LITIGATION 20 If a Party is served with a subpoena or a court order issued in other litigation that 21 compels disclosure of any information or items designated in this Action as 22 “CONFIDENTIAL,” that Party must: 23 (a) promptly notify in writing the Designating Party. Such notification shall 24 include a copy of the subpoena or court order; 25 (b) promptly notify in writing the party who caused the subpoena or order to 26 issue in the other litigation that some or all of the material covered by the subpoena or 27 order is subject to this Protective Order. Such notification shall include a copy of this 28 Stipulated Protective Order; and STIPULATED PROTECTIVE ORDER (Glover v. City of Los Angeles, et al) 10 Case 2:21-cv-09915-FWS-AS Document 28 Filed 07/25/22 Page 11 of 16 Page ID #:219

1 (c) cooperate with respect to all reasonable procedures sought to be pursued by 2 the Designating Party whose Protected Material may be affected. 3 If the Designating Party timely seeks a protective order, the Party served with the 4 subpoena or court order shall not produce any information designated in this action as 5 “CONFIDENTIAL” before a determination by the court from which the subpoena or order 6 issued, unless the Party has obtained the Designating Party’s permission. The Designating 7 Party shall bear the burden and expense of seeking protection in that court of its 8 confidential material and nothing in these provisions should be construed as authorizing 9 or encouraging a Receiving Party in this Action to disobey a lawful directive from another 10 court. 11 12 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 13 PRODUCED IN THIS LITIGATION 14 (a) The terms of this Order are applicable to information produced by a Non- 15 Party in this Action and designated as “CONFIDENTIAL.” Such information produced 16 by Non-parties in connection with this litigation is protected by the remedies and relief 17 provided by this Order. Nothing in these provisions should be construed as prohibiting a 18 Non-party from seeking additional protections. 19 (b) In the event that a Party is required, by a valid discovery request, to produce 20 a Non-Party’s confidential information in its possession, and the Party is subject to an 21 agreement with the Non-Party not to produce the Non-Party’s confidential information, 22 then the Party shall: 23 (1) promptly notify in writing the Requesting Party and the Non-Party that some 24 or all of the information requested is subject to a confidentiality agreement with a Non- 25 Party; 26 (2) promptly provide the Non-Party with a copy of the Stipulated Protective 27 Order in this Action, the relevant discovery request(s), and a reasonably specific 28 description of the information requested; and STIPULATED PROTECTIVE ORDER (Glover v. City of Los Angeles, et al) 11 Case 2:21-cv-09915-FWS-AS Document 28 Filed 07/25/22 Page 12 of 16 Page ID #:220

1 (3) make the information requested available for inspection by the Non-Party, if 2 requested. 3 (c) If the Non-Party fails to seek a protective order from this court within 14 days 4 of receiving the notice and accompanying information, the Receiving Party may produce 5 the Non-Party’s confidential information responsive to the discovery request. If the Non- 6 Party timely seeks a protective order, the Receiving Party shall not produce any 7 information in its possession or control that is subject to the confidentiality agreement 8 with the Non-Party before a determination by the court. Absent a court order to the 9 contrary, the Non-Party shall bear the burden and expense of seeking protection in this 10 court of its Protected Material. 11 12 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 13 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 14 Protected Material to any person or in any circumstance not authorized under this 15 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 16 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve all 17 unauthorized copies of the Protected Material, (c) inform the person or persons to whom 18 unauthorized disclosures were made of all the terms of this Order, and (d) request such 19 person or persons to execute the “Acknowledgment and Agreement to Be Bound” that is 20 attached hereto as Exhibit A. 21 22 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 23 PROTECTED MATERIAL 24 When a Producing Party gives notice to Receiving Parties that certain inadvertently 25 produced material is subject to a claim of privilege or other protection, the obligations of 26 the Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). 27 This provision is not intended to modify whatever procedure may be established in an e- 28 discovery order that provides for production without prior privilege review. Pursuant to STIPULATED PROTECTIVE ORDER (Glover v. City of Los Angeles, et al) 12 Case 2:21-cv-09915-FWS-AS Document 28 Filed 07/25/22 Page 13 of 16 Page ID #:221

1 Federal Rule of Evidence 502(d) and (e), insofar as the parties reach an agreement on the 2 effect of disclosure of a communication or information covered by the attorney-client 3 privilege or work product protection, the parties may incorporate their agreement in the 4 stipulated protective order submitted to the court. 5 6 12. MISCELLANEOUS 7 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 8 person to seek its modification by the Court in the future. 9 12.2 Right to Assert Other Objections. By stipulating to the entry of this 10 Protective Order no Party waives any right it otherwise would have to object to disclosing 11 or producing any information or item on any ground not addressed in this Stipulated 12 Protective Order. Similarly, no Party waives any right to object on any ground to use in 13 evidence of any of the material covered by this Protective Order. 14 12.3 Filing Protected Material. A Party that seeks to file under seal any 15 Protected Material must comply with Civil Local Rule 79-5. Protected Material may only 16 be filed under seal pursuant to a court order authorizing the sealing of the specific 17 Protected Material at issue. If a Party's request to file Protected Material under seal is 18 denied by the court, then the Receiving Party may file the information in the public record 19 unless otherwise instructed by the court. 20 21 13. FINAL DISPOSITION 22 After the final disposition of this Action, as defined in paragraph 4, within 60 days 23 of a written request by the Designating Party, each Receiving Party must return all 24 Protected Material to the Producing Party or destroy such material. As used in this 25 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 26 summaries, and any other format reproducing or capturing any of the Protected Material. 27 Whether the Protected Material is returned or destroyed, the Receiving Party must submit 28 a written certification to the Producing Party (and, if not the same person or entity, to the STIPULATED PROTECTIVE ORDER (Glover v. City of Los Angeles, et al) 13 Case 2:21-cv-09915-FWS-AS Document 28 Filed 07/25/22 Page 14 of 16 Page ID #:222

1 Designating Party) by the 60 day deadline that (1) identifies (by category, where 2 appropriate) all the Protected Material that was returned or destroyed and (2) affirms that 3 the Receiving Party has not retained any copies, abstracts, compilations, summaries or any 4 other format reproducing or capturing any of the Protected Material. Notwithstanding this 5 provision, Counsel are entitled to retain an archival copy of all pleadings, motion papers, 6 trial, deposition, and hearing transcripts, legal memoranda, correspondence, deposition 7 and trial exhibits, expert reports, attorney work product, and consultant and expert work 8 product, even if such materials contain Protected Material. Any such archival copies that 9 contain or constitute Protected Material remain subject to this Protective Order as set forth 10 in Section 4 (DURATION). 11 12 14. VIOLATION 13 Any violation of this Stipulated Protective Order may be punished by any and all 14 appropriate measures including, without limitation, contempt proceedings and/or 15 monetary sanctions. 16 17 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD: 18 19 Dated: July 22, 2022 LAW OFFICES OF DALE K. GALIPO 20 By: /s/ Dale K. Galipo 21 DALE K. GALIPO, Esq. 22 MARCEL F. SINCICH, Esq. Attorneys for Plaintiff, NATHAN ROCKY GLOVER 23 24 Dated: July 22, 2022 LAW OFFICES OF GREGORY A. YATES 25 By: /s/ Gregory A. Yates 26 GREGORY A. YATES, Esq. 27 Attorneys for Plaintiff, NATHAN ROCKY GLOVER 28 Dated: July 22, 2022 MICHAEL N. FEUER, City Attorney STIPULATED PROTECTIVE ORDER (Glover v. City of Los Angeles, et al) 14 Case 2:21-cv-09915-FWS-AS Document 28 Filed 07/25/22 Page 15 of 16 Page ID #:223 SCOTT MARCUS, Chief Assistant City Attorney 1 CORY M. BRENTE, Senior Assistant City Attorney 2 3 By: /s/ Colleen R. Smith COLLEEN R. SMITH, Deputy City Attorney 4 Attorneys for Defendants, CITY OF LOS ANGELES, 5 et al. 6 7 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 8 9 Dated: July 25, 2022 / s / Sagar 10 HONORABLE ALKA SAGAR UNITED STATES MAGISTRATE JUDGE 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 STIPULATED PROTECTIVE ORDER (Glover v. City of Los Angeles, et al) 15 Case 2:21-cv-09915-FWS-AS Document 28 Filed 07/25/22 Page 16 of 16 Page ID #:224

1 EXHIBIT A 2 ACKNOWLEDGEMENT AND AGREEMENT TO BE BOUND 3 4 I, [full name], of 5 [address], declare under penalty of perjury that I have read in its 6 entirety and understand the Stipulated Protective Order that was issued by the United 7 States District Court for the Central District of California on [date] in 8 the case of Nathan Rocky Glover v. City of Los Angeles, et al , United States District Court 9 for the Central District of California, Central Division, Case No. CV21-09915 FWS 10 (ASx). I agree to comply with and to be bound by all the terms of this Stipulated Protective 11 Order, and I understand and acknowledge that failure to so comply could expose me to 12 sanctions and punishment in the nature of contempt. I solemnly promise that I will not 13 disclose in any manner any information or item that is subject to this Stipulated Protective 14 Order to any person or entity except in strict compliance with the provisions of this 15 Stipulated Protective Order. 16 I further agree to submit to the jurisdiction of the United States District Court for 17 the Central District of California for the purpose of enforcing the terms of this Stipulated 18 Protective Order, even if such enforcement proceedings occur after termination of this 19 action. I hereby appoint [full name] of 20 [address and telephone number] as my California agent 21 for service of process in connection with this action or any proceedings related to 22 enforcement of this Stipulated Protective Order. 23 24 Signature: 25 Printed Name: 26 Date: 27 City and State Where Sworn and Signed: 28 STIPULATED PROTECTIVE ORDER (Glover v. City of Los Angeles, et al) 16