Case 8:22-cv-00235-JVS-JDE Document 37 Filed 08/24/22 Page 1 of 16 Page ID #:220

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77 UNITED STATES DISTRICT COURT 88 CENTRAL DISTRICT OF CALIFORNIA 99 PATRICIA MEDINA, individual and as 1100 Case No. 8:22-cv-00235-JVS-JDEx guardian ad litem for V.P., J.G., S.M., and 1111 B.P; VALORIE PEREZ, individually and as guardian ad litem for E.M. and T.M.; 1122 STIPULATED PROTECTIVE MARIA ELENA MIRANDA, ORDER 1133 Plaintiffs, 1144 vs. 1155 CITY OF GARDEN GROVE; and DOES 1166 1 through 10, inclusive, 1177 Defendants. 1188 1199 Per the parties’ Stipulation (Dkt. 36) and for good cause shown, the Court 2200 finds and orders as follows. 1. PURPOSES AND LIMITATIONS 2211 Discovery in this action is likely to involve production of confidential, 2222 proprietary or private information for which special protection from public 2233 disclosure and from use for any purpose other than pursuing this litigation may 2244 be warranted. Accordingly, the parties hereby stipulate to and petition the 2255 Court to enter the following Stipulated Protective Order. The parties 2266 acknowledge that this Order does not confer blanket protections on all 2277

disclosures or responses to discovery and that the protection it affords from 2288 -1- STIPULATED PROTECTIVE ORDER Case 8:22-cv-00235-JVS-JDE Document 37 Filed 08/24/22 Page 2 of 16 Page ID #:221

11 public disclosure and use extends only to the limited information or items that

22 are entitled to confidential treatment under the applicable legal principles. 33 2. GOOD CAUSE STATEMENT 44 This action is likely to involve information which one or more of the parties 55 contend special protection from use for any purpose other than litigation of this 66 action is warranted. Such confidential and proprietary materials and information 77 consist of, among other things, documents that contain personal and confidential 88 information regarding individuals which information is generally unavailable to the 99 public, including third party identities and information who are not involved with 1100 the present litigation. The disclosure of these types of information to the public 1111 may violate these individuals’ privacy rights. 1122 Accordingly, to expedite the flow of information, to facilitate the prompt 1133 resolution of disputes over confidentiality of discovery materials, to adequately 1144 protect information the parties are entitled to keep confidential, to ensure that the 1155 parties are permitted reasonable necessary uses of such material in preparation for 1166 and in the conduct of trial, to address their handling at the end of the litigation, and 1177 serve the ends of justice, a protective order for such information is justified in this 1188 matter. It is the intent of the parties that the information will not be designated as 1199 confidential for tactical reasons and that nothing be so designated without a good 2200 faith belief that is has been maintained in a confidential, non-public manner, and 2211 there is a good cause why it should not be part of the public record of this case. 2222 3. ACKNOWLEDGMENT OF UNDER SEAL FILING 2233 PROCEDURE 2244 The parties further acknowledge, as set forth in Section 14.3, below, that 2255 this Stipulated Protective Order does not entitle them to file confidential 2266 information under seal; Local Civil Rule 79-5 sets forth the procedures that 2277 must be followed and the standards that will be applied when a party seeks

2288 permission from the court to file material under seal. There is a strong -2- STIPULATED PROTECTIVE ORDER Case 8:22-cv-00235-JVS-JDE Document 37 Filed 08/24/22 Page 3 of 16 Page ID #:222

11 presumption that the public has a right of access to judicial proceedings and

22 records in civil cases. In connection with non-dispositive motions, good cause 33 must be shown to support a filing under seal. See Kamakana v. City and 44 County of Honolulu,

(9th Cir. 2006), Phillips v. Gen. 55 Motors Corp.,

, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony 66 Electrics, Inc.,

(E.D. Wis. 1999) (even stipulated 77 protective orders require good cause showing), and a specific showing of good 88 cause or compelling reasons with proper evidentiary support and legal 99 justification, must be made with respect to Protected Material that a party 1100 seeks to file under seal. The parties’ mere designation of Disclosure or 1111 Discovery Material as CONFIDENTIAL does not— without the submission 1122 of competent evidence by declaration, establishing that the material sought to 1133 be filed under seal qualifies as confidential, privileged, or otherwise 1144 protectable—constitute good cause. 1155 Further, if a party requests sealing related to a dispositive motion or trial, 1166 then compelling reasons, not only good cause, for the sealing must be shown, 1177 and the relief sought shall be narrowly tailored to serve the specific interest to 1188 be protected. See Pintos v. Pacific Creditors Ass’n.,

(9th 1199 Cir. 2010). For each item or type of information, document, or thing sought to 2200 be filed or introduced under seal, the party seeking protection must articulate 2211 compelling reasons, supported by specific facts and legal justification, for the 2222 requested sealing order. Again, competent evidence supporting the application 2233 to file documents under seal must be provided by declaration. 2244 Any document that is not confidential, privileged, or otherwise protectable in 2255 its entirety will not be filed under seal if the confidential portions can be 2266 redacted. If documents can be redacted, then a redacted version for public 2277 viewing, omitting only the confidential, privileged, or otherwise protectable 2288 -3- STIPULATED PROTECTIVE ORDER Case 8:22-cv-00235-JVS-JDE Document 37 Filed 08/24/22 Page 4 of 16 Page ID #:223

11 portions of the document, shall be filed. Any application that seeks to file

22 documents under seal in their entirety should include an explanation of why 33 redaction is not feasible. 44 4. DEFINITIONS 55 4.1 Action: This pending federal lawsuit. 66 4.2 Challenging Party: a Party or Non-Party that challenges the 77 designation of information or items under this Order. 88 4.3 “CONFIDENTIAL” Information or Items: information 99 (regardless of how it is generated, stored or maintained) or tangible things that 1100 qualify for protection under Federal Rule of Civil Procedure 26(c), and as 1111 specified above in the Good Cause Statement. 1122 4.4 Counsel: Outside Counsel of Record and House Counsel (as well 1133 as their support staff). 1144 4.5 Designating Party: a Party or Non-Party that designates 1155 information or items that it produces in disclosures or in responses to discovery 1166 as “CONFIDENTIAL.” 1177 4.6 Disclosure or Discovery Material: all items or information, 1188 regardless of the medium or manner in which it is generated, stored, or 1199 maintained (including, among other things, testimony, transcripts, and tangible 2200 things), that are produced or generated in disclosures or responses to discovery. 2211 4.7 Expert: a person with specialized knowledge or experience in a 2222 matter pertinent to the litigation who has been retained by a Party or its 2233 counsel to serve as an expert witness or as a consultant in this Action. 2244 4.8 House Counsel: attorneys who are employees of a party to this 2255 Action. House Counsel does not include Outside Counsel of Record or any 2266 other outside counsel. 2277 4.9 Non-Party: any natural person, partnership, corporation, 2288 -4- STIPULATED PROTECTIVE ORDER Case 8:22-cv-00235-JVS-JDE Document 37 Filed 08/24/22 Page 5 of 16 Page ID #:224

11 association or other legal entity not named as a Party to this action.

22 4.10 Outside Counsel of Record: attorneys who are not employees of a 33 party to this Action but are retained to represent a party to this Action and 44 have appeared in this Action on behalf of that party or are affiliated with a law 55 firm that has appeared on behalf of that party, and includes support staff. 66 4.11 Party: any party to this Action, including all of its officers, 77 directors, employees, consultants, retained experts, and Outside Counsel of 88 Record (and their support staffs). 99 4.12 Producing Party: a Party or Non-Party that produces Disclosure or 1100 Discovery Material in this Action. 1111 4.13 Professional Vendors: persons or entities that provide litigation 1122 support services (e.g., photocopying, videotaping, translating, preparing 1133 exhibits or demonstrations, and organizing, storing, or retrieving data in any 1144 form or medium) and their employees and subcontractors. 1155 4.14 Protected Material: any Disclosure or Discovery Material that is 1166 designated as “CONFIDENTIAL.” 1177 4.15 Receiving Party: a Party that receives Disclosure or Discovery 1188 Material from a Producing Party. 1199 5. SCOPE 2200 The protections conferred by this Stipulation and Order cover not only 2211 Protected Material (as defined above), but also (1) any information copied or 2222 extracted from Protected Material; (2) all copies, excerpts, summaries, or 2233 compilations of Protected Material; and (3) any testimony, conversations, or 2244 presentations by Parties or their Counsel that might reveal Protected Material. 2255 Any use of Protected Material at trial shall be governed by the orders of 2266 the trial judge and other applicable authorities. This Order does not govern the 2277 use of Protected Material at trial. 2288 -5- STIPULATED PROTECTIVE ORDER Case 8:22-cv-00235-JVS-JDE Document 37 Filed 08/24/22 Page 6 of 16 Page ID #:225

11 6. DURATION

22 Once a case proceeds to trial, information that was designated as 33 CONFIDENTIAL or maintained pursuant to this protective order used or 44 introduced as an exhibit at trial becomes public and will be presumptively 55 available to all members of the public, including the press, unless compelling 66 reasons supported by specific factual findings to proceed otherwise are made to 77 the trial judge in advance of the trial. See Kamakana,

-81 88 (distinguishing “good cause” showing for sealing documents produced in 99 discovery from “compelling reasons” standard when merits-related documents 1100 are part of court record). Accordingly, the terms of this protective order do not 1111 extend beyond the commencement of the trial. 1122 7. DESIGNATING PROTECTED MATERIAL 1133 7.1 Exercise of Restraint and Care in Designating Material for 1144 Protection. Each Party or Non-Party that designates information 1155 or items for protection under this Order must take care to limit any such 1166 designation to specific material that qualifies under the appropriate standards. 1177 The Designating Party must designate for protection only those parts of 1188 material, documents, items or oral or written communications that qualify so 1199 that other portions of the material, documents, items or communications for 2200 which protection is not warranted are not swept unjustifiably within the ambit 2211 of this Order. 2222 Mass, indiscriminate or routinized designations are prohibited. 2233 Designations that are shown to be clearly unjustified or that have been made 2244 for an improper purpose (e.g., to unnecessarily encumber the case development 2255 process or to impose unnecessary expenses and burdens on other parties) may 2266 expose the Designating Party to sanctions. 2277 If it comes to a Designating Party’s attention that information or items 2288 -6- STIPULATED PROTECTIVE ORDER Case 8:22-cv-00235-JVS-JDE Document 37 Filed 08/24/22 Page 7 of 16 Page ID #:226

11 that it designated for protection do not qualify for protection, that Designating

22 Party must promptly notify all other Parties that it is withdrawing the 33 inapplicable designation. 44 7.2 Manner and Timing of Designations. Except as otherwise 55 provided in this Order, or as otherwise stipulated or ordered, Disclosure of 66 Discovery Material that qualifies for protection under this Order must be 77 clearly so designated before the material is disclosed or produced. 88 Designation in conformity with this Order requires: 99 (a) for information in documentary form (e.g., paper or electronic 1100 documents, but excluding transcripts of depositions or other pretrial or trial 1111 proceedings), that the Producing Party affix at a minimum, the legend 1122 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page 1133 that contains protected material. If only a portion of the material on a page 1144 qualifies for protection, the Producing Party also must clearly identify the 1155 protected portion(s) (e.g., by making appropriate markings in the margins). 1166 A Party or Non-Party that makes original documents available for 1177 inspection need not designate them for protection until after the inspecting 1188 Party has indicated which documents it would like copied and produced. 1199 During the inspection and before the designation, all of the material made 2200 available for inspection shall be deemed “CONFIDENTIAL.” After the 2211 inspecting Party has identified the documents it wants copied and produced, 2222 the Producing Party must determine which documents, or portions thereof, 2233 qualify for protection under this Order. Then, before producing the specified 2244 documents, the Producing Party must affix the “CONFIDENTIAL legend” to 2255 each page that contains Protected Material. If only a portion of the material on 2266 a page qualifies for protection, the Producing Party also must clearly identify 2277 the protected portion(s) (e.g., by making appropriate markings in the margins). 2288 -7- STIPULATED PROTECTIVE ORDER Case 8:22-cv-00235-JVS-JDE Document 37 Filed 08/24/22 Page 8 of 16 Page ID #:227

11 (b) for testimony given in depositions that the Designating Party

22 identifies the Disclosure or Discovery Material on the record, before the close 33 of the deposition all protected testimony. 44 (c) for information produced in some form other than 55 documentary and for any other tangible items, that the Producing Party affix 66 in a prominent place on the exterior of the container or containers in which the 77 information is stored the legend “CONFIDENTIAL.” If only a portion or 88 portions of the information warrants protection, the Producing Party, to the 99 extent practicable, shall identify the protected portion(s). 1100 7.3 Inadvertent Failures to Designate. If timely corrected, an 1111 inadvertent failure to designate qualified information or items does not, 1122 standing alone, waive the Designating Party’s right to secure protection under 1133 this Order for such material. Upon timely correction of a designation, the 1144 Receiving Party must make reasonable efforts to assure that the material is 1155 treated in accordance with the provisions of this Order. 1166 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS 1177 8.1. Timing of Challenges. Any Party or Non-Party may challenge a 1188 designation of confidentiality at any time that is consistent with the Court’s 1199 Scheduling Order. 2200 8.2 Meet and Confer. The Challenging Party shall initiate the dispute 2211 resolution process under Local Rule 37-1 et seq. 2222 8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a 2233 joint stipulation pursuant to Local Rule 37-2. 2244 8.4 The burden of persuasion in any such challenge proceeding shall be 2255 on the Designating Party. Frivolous challenges, and those made for an 2266 improper purpose (e.g., to harass or impose unnecessary expenses and burdens 2277 on other parties) may expose the Challenging Party to sanctions. Unless the 2288 -8- STIPULATED PROTECTIVE ORDER Case 8:22-cv-00235-JVS-JDE Document 37 Filed 08/24/22 Page 9 of 16 Page ID #:228

11 Designating Party has waived or withdrawn the confidentiality designation, all

22 parties shall continue to afford the material in question the level of protection 33 to which it is entitled under the Producing Party’s designation until the Court 44 rules on the challenge. 55 9. ACCESS TO AND USE OF PROTECTED MATERIAL 66 9.1 Basic Principles. A Receiving Party may use Protected Material that 77 is disclosed or produced by another Party or by a Non-Party in connection 88 with this Action only for prosecuting, defending or attempting to settle this 99 Action. Such Protected Material may be disclosed only to the categories of 1100 persons and under the conditions described in this Order. When the Action has 1111 been terminated, a Receiving Party must comply with the provisions of section 1122 15 below (FINAL DISPOSITION). 1133 Protected Material must be stored and maintained by a Receiving Party 1144 at a location and in a secure manner that ensures that access is limited to the 1155 persons authorized under this Order. 1166 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 1177 otherwise ordered by the court or permitted in writing by the Designating 1188 Party, a Receiving Party may disclose any information or item designated 1199 “CONFIDENTIAL” only to: 2200 (a) the Receiving Party’s Outside Counsel of Record in this 2211 Action, as well as employees of said Outside Counsel of Record to whom it is 2222 reasonably necessary to disclose the information for this Action; 2233 (b) the officers, directors, and employees (including House 2244 Counsel) of the Receiving Party to whom disclosure is reasonably necessary 2255 for this Action; 2266 (c) Experts (as defined in this Order) of the Receiving Party to 2277

whom disclosure is reasonably necessary for this Action and who have signed 2288 -9- STIPULATED PROTECTIVE ORDER Case 8:22-cv-00235-JVS-JDE Document 37 Filed 08/24/22 Page 10 of 16 Page ID #:229

11 the “Acknowledgment and Agreement to Be Bound” (Exhibit A)

22 (d) the court and its personnel; 33 (e) court reporters and their staff; 44 (f) professional jury or trial consultants, mock jurors, and 55 Professional Vendors to whom disclosure is reasonably necessary for this 66 Action and who have signed the “Acknowledgment and Agreement to Be 77 Bound” (Exhibit A); 88 (g) the author or recipient of a document containing the 99 information or a custodian or other person who otherwise possessed or knew 1100 the information; 1111 (h) during their depositions, witnesses, and attorneys for witnesses, 1122 in the Action to whom disclosure is reasonably necessary provided: (1) the 1133 deposing party requests that the witness sign the form attached as Exhibit A 1144 hereto; and (2) they will not be permitted to keep any confidential information 1155 unless they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit 1166 A), unless otherwise agreed by the Designating Party or ordered by the court. 1177 Pages of transcribed deposition testimony or exhibits to depositions that reveal 1188 Protected Material may be separately bound by the court reporter and may not 1199 be disclosed to anyone except as permitted under this Stipulated Protective 2200 Order; and 2211 (i) any mediators or settlement officers and their supporting 2222 personnel, mutually agreed upon by any of the parties engaged in settlement 2233 discussions. 2244 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED 2255 PRODUCED IN OTHER LITIGATION

2266 If a Party is served with a subpoena or a court order issued in other 2277 litigation that compels disclosure of any information or items designated in this 2288 -10- STIPULATED PROTECTIVE ORDER Case 8:22-cv-00235-JVS-JDE Document 37 Filed 08/24/22 Page 11 of 16 Page ID #:230

11 Action as “CONFIDENTIAL,” that Party must:

22 (a) promptly notify in writing the Designating Party. Such 33 notification shall include a copy of the subpoena or court order; 44 (b) promptly notify in writing the party who caused the subpoena 55 or order to issue in the other litigation that some or all of the material covered 66 by the subpoena or order is subject to this Protective Order. Such notification 77 shall include a copy of this Stipulated Protective Order; and 88 (c) cooperate with respect to all reasonable procedures sought to be 99 pursued by the Designating Party whose Protected Material may be affected. If 1100 the Designating Party timely seeks a protective order, the Party served with the 1111 subpoena or court order shall not produce any information designated in this 1122 action as “CONFIDENTIAL” before a determination by the court from which 1133 the subpoena or order issued, unless the Party has obtained the Designating 1144 Party’s permission. The Designating Party shall bear the burden and expense 1155 of seeking protection in that court of its confidential material and nothing in 1166 these provisions should be construed as authorizing or encouraging a 1177 Receiving Party in this Action to disobey a lawful directive from another court. 1188 11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO 1199 BE PRODUCED IN THIS LITIGATION 2200 (a) The terms of this Order are applicable to information produced 2211 by a Non-Party in this Action and designated as “CONFIDENTIAL.” Such 2222 information produced by Non-Parties in connection with this litigation is 2233 protected by the remedies and relief provided by this Order. Nothing in these 2244 provisions should be construed as prohibiting a Non-Party from seeking 2255 additional protections. 2266 (b) In the event that a Party is required, by a valid discovery 2277

request, to produce a Non-Party’s confidential information in its possession, 2288 -11- STIPULATED PROTECTIVE ORDER Case 8:22-cv-00235-JVS-JDE Document 37 Filed 08/24/22 Page 12 of 16 Page ID #:231

11 and the Party is subject to an agreement with the Non-Party not to produce the

22 Non-Party’s confidential information, then the Party shall: 33 (1) promptly notify in writing the Requesting Party and the Non- 44 Party that some or all of the information requested is subject to a 55 confidentiality agreement with a Non-Party; 66 (2) promptly provide the Non-Party with a copy of the Stipulated 77 Protective Order in this Action, the relevant discovery request(s), and a 88 reasonably specific description of the information requested; and 99 (3) make the information requested available for inspection by the 1100 Non-Party, if requested. 1111 (c) If the Non-Party fails to seek a protective order from this court 1122 within 14 days of receiving the notice and accompanying information, the 1133 Receiving Party may produce the Non-Party’s confidential information 1144 responsive to the discovery request. If the Non-Party timely seeks a protective 1155 order, the Receiving Party shall not produce any information in its possession 1166 or control that is subject to the confidentiality agreement with the Non-Party 1177 before a determination by the court. Absent a court order to the contrary, the 1188 Non-Party shall bear the burden and expense of seeking protection in this court 1199 of its Protected Material. 2200 12. UNAUTHORIZED DISCLOSURE OF PROTECTED 2211 MATERIAL

2222 If a Receiving Party learns that, by inadvertence or otherwise, it has 2233 disclosed Protected Material to any person or in any circumstance not 2244 authorized under this Stipulated Protective Order, the Receiving Party must 2255 immediately (a) notify in writing the Designating Party of the unauthorized 2266 disclosures, (b) use its best efforts to retrieve all unauthorized copies of the 2277 Protected Material, (c) inform the person or persons to whom unauthorized 2288 -12- STIPULATED PROTECTIVE ORDER Case 8:22-cv-00235-JVS-JDE Document 37 Filed 08/24/22 Page 13 of 16 Page ID #:232

11 disclosures were made of all the terms of this Order, and (d) request such

22 person or persons to execute the “Acknowledgment an Agreement to Be 33 Bound” attached hereto as Exhibit A. 44 13. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED MATERIAL 55

66 When a Producing Party gives notice to Receiving Parties that certain 77 inadvertently produced material is subject to a claim of privilege or other 88 protection, the obligations of the Receiving Parties are those set forth in 99 Federal Rule of Civil\ Procedure 26(b)(5)(B). This provision is not intended to 1100 modify whatever procedure may be established in an e-discovery order that 1111 provides for production without prior privilege review. Pursuant to Federal 1122 Rule of Evidence 502(d) and (e), insofar as the parties reach an agreement on 1133 the effect of disclosure of a communication or information covered by the 1144 attorney-client privilege or work product protection, the parties may 1155 incorporate their agreement in the stipulated protective order submitted to the 1166 court. 1177 14. MISCELLANEOUS 1188 14.1 Right to Further Relief. Nothing in this Order abridges the right of 1199 any person to seek its modification by the Court in the future. 2200 14.2 Right to Assert Other Objections. By stipulating to the entry of this 2211 Protective Order, no Party waives any right it otherwise would have to object 2222 to disclosing or producing any information or item on any ground not 2233 addressed in this Stipulated Protective Order. Similarly, no Party waives any 2244 right to object on any ground to use in evidence of any of the material covered 2255 by this Protective Order. 2266 14.3 Filing Protected Material. A Party that seeks to file under seal any 2277 Protected Material must comply with Local Civil Rule 79-5. Protected 2288 -13- STIPULATED PROTECTIVE ORDER Case 8:22-cv-00235-JVS-JDE Document 37 Filed 08/24/22 Page 14 of 16 Page ID #:233

11 Material may only be filed under seal pursuant to a court order authorizing the

22 sealing of the specific Protected Material. If a Party’s request to file Protected 33 Material under seal is denied by the court, then the Receiving Party may file 44 the information in the public record unless otherwise instructed by the court. 55 15. FINAL DISPOSITION 66 After the final disposition of this Action, as defined in paragraph 6, 77 within 60 days of a written request by the Designating Party, each Receiving 88 Party must return all Protected Material to the Producing Party or destroy such 99 material. As used in this subdivision, “all Protected Material” includes all 1100 copies, abstracts, compilations, summaries, and any other format reproducing 1111 or capturing any of the Protected Material. Whether the Protected Material is 1122 returned or destroyed, the Receiving Party must submit a written certification 1133 to the Producing Party (and, if not the same person or entity, to the 1144 Designating Party) by the 60-day deadline that (1) identifies (by category, 1155 where appropriate) all the Protected Material that was returned or destroyed 1166 and (2) affirms that the Receiving Party has not retained any copies, abstracts, 1177 compilations, summaries or any other format reproducing or capturing any of 1188 the Protected Material. Notwithstanding this provision, Counsel are entitled to 1199 retain an archival copy of all pleadings, motion papers, trial, deposition, and 2200 hearing transcripts, legal memoranda, correspondence, deposition and trial 2211 exhibits, expert reports, attorney work product, and consultant and expert 2222 work product, even if such materials contain Protected Material. Any such 2233 archival copies that contain or constitute Protected Material remain subject to 2244 this Protective Order as set forth in Section 6 (DURATION). 2255 16. VIOLATION 2266 Any violation of this Order may be punished by appropriate measures 2277 including, without limitation, contempt proceedings and/or monetary 2288 -14- STIPULATED PROTECTIVE ORDER Case 8:22-cv-00235-JVS-JDE Document 37 Filed 08/24/22 Page 15o0f16 Page ID #:234

1 || sanctions. 3 | FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

DATED: August 24, 2022 ! 8 D. EARLY 9 nited States Magistrate Judge 10 1] 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

STIPULATED PROTECTIVE ORDER

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33 EXHIBIT A ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 44 I, _____________________________ [print or type full name], of 55 ____________________________________________ [print or type full address], 66 declare under penalty of perjury that I have read in its entirety and understand the 77 Stipulated Protective Order that was issued by the United States District Court for 88 the Central District of California on August 24, 2022, in the case of Patricia 99 Median, et al. v. City of Garden Grove, et al., Case No. 8:22-cv-00235-JVS- 1100 JDE. I agree to comply with and to be bound by all the terms of this Stipulated 1111 Protective Order and I understand and acknowledge that failure to so comply could 1122 expose me to sanctions and punishment in the nature of contempt. I solemnly 1133 promise that I will not disclose in any manner any information or item that is 1144 subject to this Stipulated Protective Order to any person or entity except in strict 1155 compliance with the provisions of this Order. 1166 I further agree to submit to the jurisdiction of the United States District 1177 Court for the Central District of California for the purpose of enforcing the terms 1188 of this Stipulated Protective Order, even if such enforcement proceedings occur 1199 after termination of this action. I hereby appoint __________________________ 2200 [print or type full name] of _______________________________________ [print 2211 or type full address and telephone number] as my California agent for service of 2222 process in connection with this action or any proceedings related to enforcement of 2233 this Stipulated Protective Order. 2244 Date: ______________________________________ 2255

2266 City and State where sworn and signed: _________________________________ 2277 Printed name: _______________________________

2288 Signature: _________________ -16- STIPULATED PROTECTIVE ORDER