1 || ROB BONTA Attorney General of California 2 || GIAM M. NGUYEN Supervising Deputy Attorney General 3 || JASON TORRES Deputy Attomey General 4 || State Bar No. 285997 300 South Spring Street, Suite 1702 5 Los Angeles, CA 90013-1230 Telephone: (213) 269-6182 6 Fax: (916) 761-3641 E-mail: Jason. [email protected] 7 Attorneys for Defendants C. Burkhammer, J. Stout, and M. Mangayao 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 VICTOR RUIZ, 11 . Case No. 2:21-cv-03300-DSF-RAO Plaintiff, 12 v. STIPULATED PROTECTIVE 13 ORDER! CORRECTION OFFICER 14 STOUT, et al., 15 Defendants. 16 17 1. A. PURPOSES AND LIMITATIONS 18 Discovery in this action is likely to involve production of confidential, 19 || proprietary or private information for which special protection from public 20 || disclosure and from use for any purpose other than prosecuting this litigation may 21 || be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 22 || enter the following Stipulated Protective Order. The parties acknowledge that this 23 || Order does not confer blanket protections on all disclosures or responses to 24 || discovery and that the protection it affords from public disclosure and use extends 25 || only to the limited information or items that are entitled to confidential treatment 26 || under the applicable legal principles. 27 9g || | This Stipulated Protective Order is substantially based on the model protective order provided under Magistrate Judge Rozella A. Oliver’s Procedures.

1 B. GOOD CAUSE STATEMENT 2 Defendants C. Burkhammer, J. Stout, and M. Mangayao are producing 3 || documents which may contain confidential internal policies and procedures, which 4 || information and documents are generally unavailable to the public. The disclosure 5 || of this information may jeopardize the security of the operations of the California 6 || Department of Corrections and Rehabilitation or California Men’s Colony. 7 The documents Defendants are producing may also contain personal and 8 || confidential information regarding individuals which information is generally not 9 || available to the public, including third party personal identifying information and 10 || peace officer personnel records. The disclosure of this information to the public 11 || may violate those individuals’ privacy rights. 12 The documents Defendants are producing may also contain investigation 13 || reports, all of which are generally unavailable to the public, and the disclosure of 14 || which could violate individuals’ privacy rights and jeopardize the safety of officers. 15 Accordingly, to expedite the flow of information, to facilitate the prompt 16 || resolution of disputes over confidentiality of discovery materials, to adequately 17 || protect information the parties are entitled to keep confidential, to ensure that the 18 || parties are permitted reasonable necessary uses of such material in preparation for 19 || and in the conduct of trial, to address their handling at the end of the litigation, and 20 || serve the ends of justice, a protective order for such information is justified in this 21 || matter. It is the intent of the parties that information will not be designated as 22 || confidential for tactical reasons and that nothing be so designated without a good 23 || faith belief that it has been maintained in a confidential, non-public manner, and 24 || there is good cause why it should not be part of the public record of this case. 25 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 26 The parties further acknowledge, as set forth in Section 12.3, below, that this 27 || Stipulated Protective Order does not entitle them to file confidential information 28 || under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed

1 || and the standards that will be applied when a party seeks permission from the court 2 || to file material under seal. 3 There is a strong presumption that the public has a right of access to judicial 4 || proceedings and records in civil cases. In connection with non-dispositive motions, 5 || good cause must be shown to support a filing under seal. See Kamakana v. City and 6 || County of Honolulu,

(9th Cir. 2006); Phillips v. Gen. Motors 7 || Corp.,

, 1210-11 (9th Cir. 2002); Makar-Welbon v. Sony Electrics, 8 || Inc.,

(E.D. Wis. 1999) (even stipulated protective orders 9 || require good cause showing), and a specific showing of good cause or compelling 10 || reasons with proper evidentiary support and legal justification, must be made with 11 || respect to Protected Material that a party seeks to file under seal. The parties’ mere 12 || designation of Disclosure or Discovery Material as CONFIDENTIAL does not— 13 || without the submission of competent evidence by declaration, establishing that the 14 || material sought to be filed under seal qualifies as confidential, privileged, or 15 || otherwise protectable—constitute good cause. 16 Further, if a party requests sealing related to a dispositive motion or trial, then 17 || compelling reasons, not only good cause, for the sealing must be shown, and the 18 || relief sought shall be narrowly tailored to serve the specific interest to be protected. 19 || See Pintos v. Pacific Creditors Ass’n,

(9th Cir. 2010). For 20 || each item or type of information, document, or thing sought to be filed or introduced 21 || under seal in connection with a dispositive motion or trial, the party seeking 22 || protection must articulate compelling reasons, supported by specific facts and legal 23 || justification, for the requested sealing order. Again, competent evidence supporting 24 || the application to file documents under seal must be provided by declaration. 25 Any document that is not confidential, privileged, or otherwise protectable in 26 || its entirety will not be filed under seal if the confidential portions can be redacted. 27 || If documents can be redacted, then a redacted version for public viewing, omitting 28 || only the confidential, privileged, or otherwise protectable portions of the document

1 || shall be filed. Any application that seeks to file documents under seal in their 2 || entirety should include an explanation of why redaction is not feasible. 3 | 2. DEFINITIONS 4 2.1 Action: Victor Ruiz v. Correction Officer Stout, et al. 5 2.2 Challenging Party: a Party or Non-Party that challenges the 6 || designation of information or items under this Order. 7 2.3. “CONFIDENTIAL” Information or Items: information (regardless of 8 || how it is generated, stored or maintained) or tangible things that qualify for 9 || protection under Federal Rule of Civil Procedure 26(c), and as specified above in 10 || the Good Cause Statement. 11 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 12 || 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 17 || of the medium or manner in which it is generated, stored, or maintained (including, 18 || among other things, testimony, transcripts, and tangible things) that are produced or 19 || generated in disclosures or responses to discovery in this matter. 20 2.7 Expert: a person with specialized knowledge or experience in a matter 21 || pertinent to the litigation who has been retained by a Party or its counsel to serve as 22 || an expert witness or as a consultant in this Action. 23 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 outside 25 || 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 2.10 Outside Counsel of Record: attorneys who are not employees of a

1 || party to this Action but are retained to represent or advise a party to this Action and 2 || have appeared in this Action on behalf of that party or are affiliated with a law firm 3 || that has appeared on behalf of that party, and includes support staff. 4 2.11 Party: any party to this Action, including all of its officers, directors, 5 || employees, consultants, retained experts, and Outside Counsel of Record (and their 6 || support staffs). 7 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 8 || Discovery Material in this Action. 9 2.13 Professional Vendors: persons or entities that provide litigation 10 || support services (e.g., photocopying, videotaping, translating, preparing exhibits or 11 || demonstrations, and organizing, storing, or retrieving data in any form or medium) 12 || and their employees and subcontractors. 13 2.14 Protected Material: any Disclosure or Discovery Material that is 14 || designated as “CONFIDENTIAL.” 15 2.15 Receiving Party: a Party that receives Disclosure or Discovery 16 || Material from a Producing Party. 17 || 3. SCOPE 18 The protections conferred by this Stipulation and Order cover not only 19 || Protected Material (as defined above), but also (1) any information copied or 20 || extracted from Protected Material; (2) all copies, excerpts, summaries, or 21 || compilations of Protected Material; and (3) any testimony, conversations, or 22 || presentations by Parties or their Counsel that might reveal Protected Material. 23 Any use of Protected Material at trial shall be governed by the orders of the 24 || trial judge. This Order does not govern the use of Protected Material at trial. 25 || 4. DURATION 26 Even after final disposition of this litigation, the confidentiality obligations 27 || imposed by this Stipulated Protective Order shall remain in effect until a 28 || Designating Party agrees otherwise in writing or a court order otherwise directs.

1 || Final disposition shall be deemed to be the later of (1) dismissed of all claims and 2 || defenses in this Action, with or without prejudice; and (2) final judgment herein 3 || after the completion and exhaustion of all appeals, rehearings, remands, trials, or 4 || reviews of this Action, including the time limits for filing any motions or 5 || applications for extension of time pursuant to applicable law. 6 || 5. DESIGNATING PROTECTED MATERIAL 7 5.1 Exercise of Restraint and Care in Designating Material for Protection. 8 || Each Party or Non-Party that designates information or items for protection under 9 || this Order must take care to limit any such designation to specific material that 10 || qualifies under the appropriate standards. The Designating Party must designate for 11 || protection only those parts of material, documents, items or oral or written 12 || communications that qualify so that other portions of the material, documents, items 13 || or communications for which protection is not warranted are not swept unjustifiably 14 || within the ambit of this Order. 15 Mass, indiscriminate or routinized designations are prohibited. Designations 16 || that are shown to be clearly unjustified or that have been made for an improper 17 || purpose (e.g., to unnecessarily encumber the case development process or to impose 18 || unnecessary expenses and burdens on other parties) may expose the Designating 19 || Party to sanctions. 20 If it comes to a Designating Party’s attention that information or items that it 21 || designated for protection do not qualify for protection, that Designating Party must 22 || promptly notify all other Parties that it is withdrawing the inapplicable designation. 23 5.2 Manner and Timing of Designations. Except as otherwise provided in 24 || this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 25 || stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 26 || under this Order must be clearly so designated before the material is disclosed or 27 || produced. 28 Designation in conformity with this Order requires:

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

1 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 2 || failure to designate qualified information or items does not, standing alone, waive 3 || the Designating Party’s right to secure protection under this Order for such material. 4 || Upon timely correction of a designation, the Receiving Party must make reasonable 5 || efforts to assure that the material is treated in accordance with the provisions of this 6 || Order. 7 || 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 8 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 9 || designation of confidentiality at any time that is consistent with the Court’s 10 || Scheduling Order. 11 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 12 || resolution process under Local Rule 37.1 et seq. 13 6.3. The burden of persuasion in any such challenge proceeding shall be on 14 || the Designating Party. Frivolous challenges, and those made for an improper 15 || purpose (e.g., to harass or impose unnecessary expenses and burdens on other 16 || parties) may expose the Challenging Party to sanctions. Unless the Designating 17 || Party has waived or withdrawn the confidentiality designation, all parties shall 18 || continue to afford the material in question the level of protection to which it is 19 || entitled under the Producing Party’s designation until the Court rules on the 20 || challenge. 21 || 7. ACCESS TO AND USE OF PROTECTED MATERIAL 22 7.1 Basic Principles. A Receiving Party may use Protected Material that is 23 || disclosed or produced by another Party or by a Non-Party in connection with this 24 || Action only for prosecuting, defending or attempting to settle this Action. Such 25 || Protected Material may be disclosed only to the categories of persons and under the 26 || conditions described in this Order. When the Action has been terminated, a 27 || Receiving Party must comply with the provisions of section 13 below (FINAL 28 || DISPOSITION).

1 Protected Material must be stored and maintained by a Receiving Party at a 2 |) location and in a secure manner that ensures that access is limited to the persons 3 || authorized under this Order. 4 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 5 || otherwise ordered by the court or permitted in writing by the Designating Party, a 6 || Receiving Party may disclose any information or item designated 7 || “CONFIDENTIAL” only to: 8 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 9 || well as employees of said Outside Counsel of Record to whom it is reasonably 10 || necessary to disclose the information for this Action;7 11 (b) Experts (as defined in this Order) of the Receiving Party to whom 12 || disclosure is reasonably necessary for this Action and who have signed the 13 || “Acknowledgment and Agreement to Be Bound” (Exhibit A); 14 (d) the court and its personnel; 15 (e) court reporters and their staff; 16 (f) professional jury or trial consultants, mock jurors, and Professional 17 || Vendors to whom disclosure is reasonably necessary for this Action and who have 18 || signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 19 (g) the author or recipient of a document containing the information or a 20 || custodian or other person who otherwise possessed or knew the information; 21 (h) during their depositions, witnesses, and attorneys for witnesses, in the 22 || Action to whom disclosure is reasonably necessary provided: (1) the deposing party 23 || requests that the witness sign the form attached as Exhibit A hereto; and (2) they 24 || will not be permitted to keep any confidential information unless they sign the 25 || “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 26 || agreed by the Designating Party or ordered by the court. Pages of transcribed 27 28 veo IS not currently Tepresented but 7.2(a) should apply were Plaintiff to obtain

1 || deposition testimony or exhibits to depositions that reveal Protected Material may 2 || be separately bound by the court reporter and may not be disclosed to anyone except 3 || as permitted under this Stipulated Protective Order; and 4 (i) any mediator or settlement officer, and their supporting personnel, 5 || mutually agreed upon by any of the parties engaged in settlement discussions. 6 || 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 7 IN OTHER LITIGATION 8 If a Party is served with a subpoena or a court order issued in other litigation 9 || that compels disclosure of any information or items designated in this Action as 10 || “CONFIDENTIAL,” that Party must: 11 (a) promptly notify in writing the Designating Party. Such notification 12 || shall include a copy of the subpoena or court order; 13 (b) promptly notify in writing the party who caused the subpoena or order 14 || to issue in the other litigation that some or all of the material covered by the 15 || subpoena or order is subject to this Protective Order. Such notification shall include 16 || acopy of this Stipulated Protective Order; and 17 (c) cooperate with respect to all reasonable procedures sought to be 18 || pursued by the Designating Party whose Protected Material may be affected. 19 If the Designating Party timely seeks a protective order, the Party served with 20 || the subpoena or court order shall not produce any information designated in this 21 || action as “CONFIDENTIAL” before a determination by the court from which the 22 || subpoena or order issued, unless the Party has obtained the Designating Party’s 23 || permission. The Designating Party shall bear the burden and expense of seeking 24 || protection in that court of its confidential material and nothing in these provisions 25 || should be construed as authorizing or encouraging a Receiving Party in this Action 26 || to disobey a lawful directive from another court. 27 || 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 28 PRODUCED IN THIS LITIGATION 10

1 (a) The terms of this Order are applicable to information produced by a 2 || Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 3 || produced by Non-Parties in connection with this litigation is protected by the 4 || remedies and relief provided by this Order. Nothing in these provisions should be 5 || construed as prohibiting a Non-Party from seeking additional protections. 6 (b) In the event that a Party is required, by a valid discovery request, to 7 || produce a Non-Party’s confidential information in its possession, and the Party is 8 || subject to an agreement with the Non-Party not to produce the Non-Party’s 9 || confidential information, then the Party shall: 10 (1) promptly notify in writing the Requesting Party and the Non-Party 11 || that some or all of the information requested is subject to a confidentiality 12 || agreement with a Non-Party; 13 (2) promptly provide the Non-Party with a copy of the Stipulated 14 || Protective Order in this Action, the relevant discovery request(s), and a reasonably 15 || specific description of the information requested; and 16 (3) make the information requested available for inspection by the 17 || Non-Party, if requested. 18 (c) If the Non-Party fails to seek a protective order from this court within 19 || 14 days of receiving the notice and accompanying information, the Receiving Party 20 || may produce the Non-Party’s confidential information responsive to the discovery 21 || request. If the Non-Party timely seeks a protective order, the Receiving Party shall 22 || not produce any information in its possession or control that is subject to the 23 || confidentiality agreement with the Non-Party before a determination by the court. 24 || Absent a court order to the contrary, the Non-Party shall bear the burden and 25 || expense of seeking protection in this court of its Protected Material. 26 || 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 27 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 28 || Protected Material to any person or in any circumstance not authorized under this 11

1 || Stipulated Protective Order, the Receiving Party must immediately (a) notify in 2 || writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 3 || to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 4 || persons to whom unauthorized disclosures were made of all the terms of this Order, 5 || and (d) request such person or persons to execute the “Acknowledgment and 6 || Agreement to Be Bound” that is attached hereto as Exhibit A. 7 || 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 8 PROTECTED MATERIAL 9 When a Producing Party gives notice to Receiving Parties that certain 10 || inadvertently produced material is subject to a claim of privilege or other protection, 11 || the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 12 || Procedure 26(b)(5)(B). This provision is not intended to modify whatever 13 || procedure may be established in an e-discovery order that provides for production 14 || without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and 15 || (e), insofar as the parties reach an agreement on the effect of disclosure of a 16 || communication or information covered by the attorney-client privilege or work 17 || product protection, the parties may incorporate their agreement in the stipulated 18 || protective order submitted to the court. 19 || 12. MISCELLANEOUS 20 12.1 Right to Further Relief. Nothing in this Stipulated Protective Order 21 || abridges the right of any person to seek its modification by the Court in the future. 22 12.2 Right to Assert Other Objections. By stipulating to the entry of this 23 || Protective Order, no Party waives any right it otherwise would have to object to 24 || disclosing or producing any information or item on any ground not addressed in this 25 || Stipulated Protective Order. Similarly, no Party waives any right to object on any 26 || ground to use in evidence of any of the material covered by this Protective Order. 27 12.3 Filing Protected Material. A Party that seeks to file under seal any 28 || Protected Material must comply with Local Civil Rule 79-5. Protected Material 12

1 || may only be filed under seal pursuant to a court order authorizing the sealing of the 2 || specific Protected Material at issue. If a Party’s request to file Protected Material 3 || under seal is denied by the court, then the Receiving Party may file the information 4 || in the public record unless otherwise instructed by the court. 5 || 13. FINAL DISPOSITION 6 After the final disposition of this Action, as defined in paragraph 4, within 60 7 || days of a written request by the Designating Party, each Receiving Party must return 8 || all Protected Material to the Producing Party or destroy such material. As used in 9 || this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 10 || summaries, and any other format reproducing or capturing any of the Protected 11 || Material. Whether the Protected Material is returned or destroyed, the Receiving 12 || Party must submit a written certification to the Producing Party (and, if not the same 13 || person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 14 || (by category, where appropriate) all the Protected Material that was returned or 15 || destroyed and (2) affirms that the Receiving Party has not retained any copies, 16 || abstracts, compilations, summaries or any other format reproducing or capturing any 17 || of the Protected Material. Notwithstanding this provision, Counsel are entitled to 18 || retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 19 || transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 20 || reports, attorney work product, and consultant and expert work product, even if such 21 || materials contain Protected Material. Any such archival copies that contain or 22 || constitute Protected Material remain subject to this Protective Order as set forth in 23 || Section 4 (DURATION). 24 | ///// 25 |} ///// 26 | ///// 27 | ///// 28 13

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. 4 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD. 6 || DATED aT [23 7

Victor Ruiz 9 |) In Pro Per 10 1] DATED: July 28, 2023 12 13 /s/ Jason Torres 14 || Jason Torres Deputy Attorney General 15 || Attorney for Defendants 16 17 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 18 19 DATED: August 3, 2023 20 "| Rapelln , OC—~ 22 || HON. ROZELLA A. OLIVER United States Magistrate Judge 24 25 26 27 28 14

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 4 || I, [print or type full name], of 5 [print or type full address], declare under penalty of perjury 6 || that I have read in its entirety and understand the Stipulated Protective Order that 7 || was issued by the United States District Court for the Central District of California 8 || on [date] in the case of [insert formal name of the case and the 9 || number and initials assigned to it by the court]. I agree to comply with and to be 10 || bound by all the terms of this Stipulated Protective Order and I understand and 11 || acknowledge that failure to so comply could expose me to sanctions and punishment 12 || in the nature of contempt. I solemnly promise that I will not disclose in any manner 13 || any information or item that is subject to this Stipulated Protective Order to any 14 || person or entity except in strict compliance with the provisions of this Order. 15 || I further agree to submit to the jurisdiction of the United States District Court for the 16 || Central District of California for enforcing the terms of this Stipulated Protective 17 || Order, even if such enforcement proceedings occur after termination of this action. 18 || [hereby appoint [print or type full name] of 19 [print or type full address and 20 || telephone number] as my California agent for service of process in connection with 21 || this action or any proceedings related to enforcement of this Stipulated Protective 22 || Order. 23 || Date: 24 || City and State where sworn and signed: 25 26 || Printed name: 27 28 || Signature: 15

CERTIFICATE OF SERVICE Case Name: Ruiz, Victor v. Stout, et al. No. _2:21-cv-03300-DSF-RAO I hereby certify that on August 1, 2023, I electronically filed the following documents with the Clerk of the Court by using the CM/ECF system: STIPULATED PROTECTIVE ORDER Participants in the case who are registered CM/ECF users will be served by the CM/ECF system. I declare under penalty of perjury under the laws of the State of California and the United States of America the foregoing is true and correct and that this declaration was executed on August 1, 2023, at Los Angeles, California.

R. Hill /s/ R. Hill Declarant for eFiling Signature I am employed in the Office of the Attorney General, which is the office of a member of the California State Bar at which member's direction this service is made. I am 18 years of age or older and not a party to this matter. I] am familiar with the business practice at the Office of the Attorney General for collection and processing of correspondence for mailing with the United States Postal Service. In accordance with that practice, correspondence placed in the internal mail collection system at the Office of the Attorney General is deposited with the United States Postal Service with postage thereon fully prepaid that same day in the ordinary course of business. I further certify that some of the participants in the case are not registered CM/ECF users. On August 1, 2023, the foregoing document(s) have been mailed in the Office of the Attorney General's internal mail system, by First-Class Mail, postage prepaid, or have dispatched it to a third party commercial carrier for delivery within three (3) calendar days to the following non- CM/ECF participants: Victor Ruiz 6247 State Street Huntington Park, CA 90255

I declare under penalty of perjury under the laws of the State of California and the United States of America the foregoing is true and correct and that this declaration was executed on August 1, 2023, at Los Angeles, California. Lg □□ R. Busuego {ZL LM" Declarant for Service by U.S. Mail EY Signat fe / LA2021604355/66126719.docx