1 || Charles E. Slyngstad (SBN 89103) E-mail: [email protected] 2 || Brian S. Ginter (SBN 265786 E-mail: [email protected] 3 || Kyle Anne Piasecki (SBN 311961) Email: RDLASECKIGL Duy slaw com 4 || BURKE, WILLIAMS & SORENSEN, LLP 444 South Flower Street, Suite 2400 5 || Los Angeles, CA 90071-2953 ‘ Tel: 213.236.0600 Fax: 213.236.2700 Attorneys for Defendant 7 | CITY GF LOS ANGELES 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 JONATHAN PELTZ and KATHLEEN | Case No. 2:22-cv-03106-MWF-AGR 12 | GALLAGHER PROPOSED} STIPULATED 13 Plaintiffs, PROTECTIVE ORDER RE: DISCLOSURE OF CONFIDENTIAL 14 || v. INFORMATION 15 || CITY OF LOS ANGELES, a municipal entity; CHIEF MICHEL 16 || MOORE, a public entity, and DOES 1 {Discovery Document: Referred to through 10, inclusive, agistrate Judge Alicia G. Rosenberg] 17 Defendants. 18 19 1. ENERAL 20 GEN >] 1.1. Purposes and Limitations. Discovery in this action is likely to involve production of confidential, 73 proprietary or private information for which special protection from public disclosure and from use for any purpose other than prosecuting this litigation may 95 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 26 enter the following Stipulated Protective Order (the “Order’’). The parties acknowledge that this Order does not confer blanket protections on all disclosures ng |) OF fesponses to discovery and that the protection it affords from public disclosure WILLIAMS & CASE NO. 2:22-CV-03106-MWF-AGR 4895-2104-5344v 1 LA #4863-3022-7530 v1 -l- PROPOSED STIPULATED

1 || and use extends only to the limited information or items that are entitled to 2 || confidential treatment under the applicable legal principles. 3 1.2 Good Cause Statement. 4 Each party to this action expects to disclose information during discovery 5 || that it contends is confidential. For example, Defendant the City of Los Angeles et 6 || al. (“City”) contends that personnel files of the police officers involved in this 7 || incident, Internal Affairs materials and information, video recordings (including 8 || Body Worn Video recordings and Digital In-Car Video recordings), audio 9 || recordings, and documents defined by Penal Code section 832.5 are confidential 10 || and require special protection from public disclosure and from use for any purpose 11 || other than prosecuting this litigation. Plaintiffs disagree that this information is 12 || confidential. Plaintiffs contend that their medical records are confidential and 13 || require special protection from public disclosure and from use for any purpose 14 || other than prosecuting this litigation. 15 Accordingly, the parties seek a protective order to expedite the flow of 16 || information, to facilitate the prompt resolution of disputes over confidentiality of 17 || discovery materials, to adequately protect information the parties are entitled to 18 || keep confidential, to ensure that the parties are permitted reasonably necessary uses 19 || of such material in preparation for and in the conduct of trial, to address their 20 || handling at the end of the litigation, and serve the ends of justice. It is the intent of 21 || the parties that information will not be designated as confidential for tactical 22 || reasons and that nothing be so designated without a good faith belief that it has 23 || been maintained in a confidential, non-public manner, and there is good cause why 24 || it should not be part of the public record of this case. 25 The parties acknowledge that this Order does not confer blanket protections 26 || on all disclosures or responses to discovery and that its protections extend only to 27 || the limited information or items that are entitled to confidential treatment under the 28 || applicable legal principles. In addition, the parties further acknowledge that a party LLP 4895-2104-5344v 1 LA #4863-3022-7530 v1 -2- CASE eoposep □□□□□

1 || that seeks to seal exhibits attached to a dispositive motion, or portions of the motion 2 || itself, must overcome the “strong presumption” of public access to judicial records 3 || by establishing “compelling reasons” and supporting facts to justify sealing. 4 | Kamakana v. City & Cty. of Honolulu,

, 1178 (9th Cir. 2006). 5 13 Acknowledgment of Procedure for Filing Under Seal. 6 The parties agree to follow the procedures set forth in Local Civil Rule 79- 7 || 5.2.2, without modification, when seeking to file any materials in court under seal. 8 The parties further acknowledge, as set forth in Section 12.3, below, that this 9 || Order does not automatically entitle them to file confidential information under seal 10 || and that Local Civil Rule 79-5 sets forth the procedures that must be followed and 11 || the standards that will be applied when a party seeks permission from the Court to 12 || file material under seal. 13 In addition, the parties acknowledge that any party seeking to seal any 14 || portion of a dispositive motion and exhibit must overcome the “strong 15 || presumption” of public access to judicial records by establishing “compelling 16 || reasons” and supporting facts to justify sealing. Kamakana, 447 F.3d at 1171-81 17 || CTA] ‘good cause’ showing alone will not suffice to fulfill the “compelling 18 || reasons” standard that a party must meet to rebut the presumption of access to 19 || dispositive pleadings and attachments.”). 20 | 2. DEFINITIONS 21 2.1. Action: Jonathan Peltz, et al. v. City of Los Angeles, et al. Case No. 22 || 2:22-CV-03106-MWF-AGR. 23 2.2 Challenging Party: a Party or Non-Party that challenges the 24 || designation of information or items under this Order. 25 23 “CONFIDENTIAL” Information or Items: information (regardless 26 || of how it is generated, stored or maintained) or tangible things that qualify for 27 || protection under Federal Rule of Civil Procedure 26(c), and as specified above in 28 || the Good Cause Statement. This also includes (1) any information copied or LEP 4gys.9104-5344v1 LA #4863.9022-7530 3. cise se PROPOSED STIPULATED

1 || extracted from the Confidential information; (2) all copies, excerpts, summaries, 2 || abstracts or compilations of Confidential information; and (3) any testimony, 3 || conversations, or presentations that might reveal Confidential information. 4 2.4 Counsel: Counsel of record for the parties to this civil litigation and 5 || their support staff. 6 2.5 Designating Party: a Party or Non-Party that designates information 7 || or 1tems that it produces in disclosures or in responses to discovery as 8 || “CONFIDENTIAL.” 9 2.6 Disclosure or Discovery Material: all items or information, 10 || regardless of the medium or manner in which it is generated, stored, or maintained 11 || G@ncluding, among other things, testimony, transcripts, and tangible things), that are 12 || produced or generated in disclosures or responses to discovery in this matter. 13 2.7 Expert: a person with specialized knowledge or experience in a matter 14 || pertinent to the litigation who has been retained by a Party or its counsel to serve as 15 || an expert witness or as a consultant in this Action. 16 2.8 Final Disposition: when this Action has been fully and completely 17 || terminated by way of settlement, dismissal, trial and/or appeal. 18 2.9 House Counsel: attorneys other than Counsel (as defined in paragraph 19 || 2.4) and who are employees of a party to this Action. 20 2.10 Non-Party: any natural person, partnership, corporation, association 21 || or other legal entity not named as a Party to this action. 22 2.11 Outside Counsel of Record: attorneys who are not employees of a 23 || party to this Action but are retained to represent or advise a party to this Action and 24 || have appeared in this Action on behalf of that party or are affiliated with a law firm 25 || that has appeared on behalf of that party, and includes support staff. 26 2.12 Party: any party to this Action, including all of its officers, directors, 27 || boards, departments, divisions, employees, consultants, retained experts, and 28 || Outside Counsel of Record (and their support staffs). LEP 4gys.9104-5344v1 LA #4863.9022-7530 -4- cise se PROPOSED STIPULATED

1 2.13 Producing Party: a Party or Non-Party that produces Disclosure or 2 || Discovery Material in this Action. 3 2.14 Professional Vendors: persons or entities that provide litigation 4 || support services (e.g., photocopying, videotaping, translating, preparing exhibits or 5 || demonstrations, and organizing, storing, or retrieving data in any form or medium) 6 || and their employees and subcontractors. 7 2.15 Protected Material: any Disclosure or Discovery Material that is 8 || designated as “CONFIDENTIAL.” 9 2.16 Receiving Party: a Party that receives Disclosure or Discovery 10 || Material from a Producing Party. 11] 3. SCOPE 12 The protections conferred by this Order cover not only Protected Material (as 13 || defined above), but also (1) any information copied or extracted from Protected 14 || Material; (2) all copies, excerpts, abstracts, summaries, or compilations of Protected 15 || Material; and (3) any testimony, conversations, or presentations by Parties or their 16 || Counsel that might reveal Protected Material, other than during a court hearing or 17 || trial. 18 Any use of Protected Material during a court hearing or at trial shall be 19 || governed by the orders of the presiding judge. This Order does not govern the use 20 || of Protected Material during a court hearing, at trial, or in proceedings before a 21 || higher court. 224. DURATION 23 Once a trial commences in this Action, information that was designated as 24 || CONFIDENTIAL or maintained pursuant to this Order and that is introduced or 25 || admitted as an exhibit at trial becomes public and will be presumptively available to 26 || all members of the public, including the press, unless the Designating Party files a 27 || noticed motion with the Court citing “compelling” reasons supported by specific 28 || facts in advance of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing LEP 4gys.9104-5344v1 LA #4863.9022-7530 _5- cise se PROPOSED STIPULATED

1 || “good cause” showing for sealing documents produced in discovery from 2 || “compelling reasons” standard that applies when Designating Party seeks to seal 3 || records attached to merits-related documents). Accordingly, the terms of this Order 4 || do not extend beyond the commencement of the trial as to the CONFIDENTIAL 5 || information and materials introduced or admitted as an exhibit at trial. 6 || 5. DESIGNATING PROTECTED MATERIAL 7 5.1 Exercise of Restraint and Care in Designating Material for 8 || Protection. 9 Each Party or Non-Party that designates information or items for protection 10 || under this Order must take care to limit any such designation to specific material 11 || that qualifies under the appropriate standards. The Designating Party must 12 || designate for protection only those parts of material, documents, items or oral or 13 || written communications that qualify so that other portions of the material, 14 || documents, items or communications for which protection is not warranted are not 15 || swept unjustifiably within the ambit of this Order. 16 Mass, indiscriminate or routinized designations are prohibited. Designations 17 || that are shown to be clearly unjustified or that have been made for an improper 18 || purpose (e.g., to unnecessarily encumber the case development process or to 19 || impose unnecessary expenses and burdens on other parties) may expose the 20 || Designating Party to sanctions. 21 If it comes to a Designating Party’s attention that information or items that it 22 || designated for protection do not qualify for protection, the Designating Party must 23 || promptly notify all other Parties that it is withdrawing the inapplicable designation. 24 5.2. Manner and Timing of Designations. Except as otherwise provided 25 || in this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 26 || stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 27 || under this Order must be clearly so designated before the material is disclosed or 28 || produced. LLP 4895-2104-5344v 1 LA #4863-3022-7530 v1 -6- CASE ROPOSED □□□□□□ □□□

l Designation in conformity with this Order requires: 2 (a) for information in documentary form (e.g., paper or electronic 3 || documents, but excluding transcripts of depositions or other pretrial or trial 4 || proceedings), that the Producing Party affix the word “CONFIDENTIAL” 5 || (hereinafter “CONFIDENTIAL Legend”), to each page that contains protected 6 || material. If only a portion of the material on a page qualifies for protection, the 7 || Producing Party also must clearly identify the protected portion(s) (e.g., by making 8 || appropriate markings in the margins). 9 A Party or Non-Party that makes original documents available for inspection 10 || need not designate them for protection until after the inspecting Party has indicated 11 || which documents it would like copied and produced. During the inspection and 12 || before the designation, all of the material made available for inspection shall be 13 || deemed “CONFIDENTIAL.” After the inspecting Party has identified the 14 || documents it wants copied and produced, the Producing Party must determine 15 || which documents, or portions thereof, qualify for protection under this Order. Then, 16 || before producing the specified documents, the Producing Party must affix the 17 | CONFIDENTIAL Legend to each page that contains Protected Material. If only a 18 || portion of the material on a page qualifies for protection, the Producing Party also 19 || must clearly identify the protected portion(s) (e.g., by making appropriate markings 20 || in the margins). 21 (b) for testimony given in depositions that the Designating Party 22 || identifies the Disclosure or Discovery Material on the record, before the close of 23 || the deposition all protected testimony. 24 (c) for information produced in some form other than documentary 25 || and for any other tangible items, that the Producing Party affix in a prominent place 26 || on the exterior of the container or containers in which the information is stored the 27 || CONFIDENTIAL Legend with the case name and case number. If only a portion or 28 LEP 4gys.9104-5344v1 LA #4863.9022-7530 _7- cise se PROPOSED STIPULATED

1 || portions of the information warrants protection, the Producing Party, to the extent 2 || practicable, shall identify the protected portion(s). 3 5.3. Inadvertent Failures to Designate. If timely corrected, an inadvertent 4 | failure to designate qualified information or items does not, standing alone, waive 5 || the Designating Party’s right to secure protection under this Order for such 6 || material. Upon timely correction of a designation, the Receiving Party must make 7 || reasonable efforts to assure that the material is treated in accordance with the 8 || provisions of this Order. 9 || 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 10 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 11 || designation of confidentiality at any time that is consistent with the Court’s 12 || Scheduling Order. 13 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 14 || resolution process under Local Rule 37-1, et seq. 15 6.3. Burden. The burden of persuasion in any such challenge proceeding 16 || shall be on the Designating Party. Frivolous challenges, and those made for an 17 || improper purpose (e.g., to harass or impose unnecessary expenses and burdens on 18 || other parties) may expose the Challenging Party to sanctions. Unless the 19 || Designating Party has waived or withdrawn the confidentiality designation, all 20 || parties shall continue to afford the material in question the level of protection to 21 || which it is entitled under the Producing Party’s designation until the Court rules on 22 || the challenge. 23 | 7. ACCESS TO AND USE OF PROTECTED MATERIAL 24 7.1 Basic Principles. A Receiving Party may use Protected Material that 25 || is disclosed or produced by another Party or by a Non-Party in connection with this 26 || Action only for prosecuting, defending or attempting to settle this Action. Such 27 || Protected Material may be disclosed only to the categories of persons and under the 28 || conditions described in this Order. When the Action has been terminated, a LEP 4gys.9104-5344v1 LA #4863.9022-7530 _8- cise se PROPOSED STIPULATED

1 || Receiving Party must comply with the provisions of section 13 below (FINAL 2 || DISPOSITION). 3 Protected Material must be stored and maintained by a Receiving Party at a 4 || location and in a secure manner that ensures that access is limited to the persons 5 || authorized under this Order. 6 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 7 || otherwise ordered by the court or permitted in writing by the Designating Party, a 8 || Receiving Party may disclose any information or item designated 9 | “CONFIDENTIAL” only to: 10 (a) Parties to the action, 1.e., Plaintiffs Jonathan Peltz and Kathleen 11 || Gallagher, and City representatives who have a need to receive the information; 12 (b) the Receiving Party’s Counsel of Record in this Action, as well 13 || as employees of said Counsel of Record to whom it is reasonably necessary to 14 || disclose the information for this Action; 15 (c) Experts (as defined in this Order) of the Receiving Party to 16 || whom disclosure is reasonably necessary for this Action and who have signed the 17 || “Acknowledgment and Agreement to Be Bound” (Exhibit A); 18 (d) the Court and its personnel; 19 (e) court reporters and their staff; 20 (f) professional jury or trial consultants, mock jurors, and 21 || Professional Vendors to whom disclosure is reasonably necessary for this Action 22 || and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit 23 || A); 24 (g) the author or recipient of a document containing the information 25 || or a custodian or other person who otherwise possessed or knew the information; 26 (h) during their depositions, witnesses, and attorneys for witnesses, 27 || in the Action to whom disclosure is reasonably necessary provided: (1) the 28 || deposing party requests that the witness sign the form attached as Exhibit “A” LEP 4gys.9104-5344v1 LA #4863.9022-7530 -9- cise se PROPOSED STIPULATED

1 || hereto; and (2) they will not be permitted to keep any confidential information 2 || unless they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit 3 || “A’’), unless otherwise agreed by the Designating Party or ordered by the Court. 4 || Pages of transcribed deposition testimony or exhibits to depositions that reveal 5 || Protected Material may be separately bound by the court reporter and may not be 6 || disclosed to anyone except as permitted under this Order; and 7 (1) any mediator or settlement officer, and their supporting 8 || personnel, mutually agreed upon by any of the parties engaged in settlement 9 || discussions and who have signed the “Acknowledgment and Agreement to Be 10 || Bound” (Exhibit A). 11 7.3 Counsel making the disclosure to any qualified person described 12 || herein shall retain the original executed copy of the signed “Acknowledgment and 13 || Agreement to Be Bound” form (Exhibit A) until sixty (60) days after this litigation 14 || has become final, including any appellate review, and monitoring of an injunction. 15 || Counsel for the Receiving Party shall maintain all signed Nondisclosure 16 || Agreements and shall produce the original signature page upon reasonable written 17 || notice from opposing counsel. If an issue arises regarding a purported unauthorized 18 || disclosure of Confidential Information, upon noticed motion of contempt filed by 19 || the Designating Party, counsel for the Receiving Party may be required to file the 20 || signed “Acknowledgment and Agreement to Be Bound” form (Exhibit A), as well 21 || asa list of the disclosed materials, in camera with the Court having jurisdiction of 22 || the Order. 23 || 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 24 PRODUCED 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 (a) promptly notify in writing the Designating Party. Such LEP 4gys.9104-5344v1 LA #4863.9022-7530 -10- cise se PROPOSED STIPULATED

1 || notification shall include a copy of the subpoena or court order; 2 (b) promptly notify in writing the party who caused the subpoena or 3 || order to issue in the other litigation that some or all of the material covered by the 4 || subpoena or order is subject to this Order. Such notification shall include a copy of 5 || this Order; and 6 (c) cooperate with respect to all reasonable procedures sought to be 7 || pursued by the Designating Party whose Protected Material may be affected. 8 The Party served with the subpoena or court order shall not produce any 9 || information designated in this action as “CONFIDENTIAL” before a determination 10 || by the court from which the subpoena or order issued, unless the Party has obtained 11 || the Designating Party’s permission, or unless otherwise required by the law or court 12 || order. The Designating Party shall bear the burden and expense of seeking 13 || protection in that court of its confidential material and nothing in these provisions 14 || should be construed as authorizing or encouraging a Receiving Party in this Action 15 || to disobey a lawful directive from another court. 16/9. ANON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 17 PRODUCED IN THIS LITIGATION 18 (a) The terms of this Order are applicable to information produced 19 || by a Non-Party in this Action and designated as “CONFIDENTIAL.” Such 20 || information produced by Non-Parties in connection with this litigation is protected 21 || by the remedies and relief provided by this Order. Nothing in these provisions 22 || should be construed as prohibiting a Non-Party from seeking additional protections. 23 (b) In the event that a Party is required, by a valid discovery 24 || request, to produce a Non-Party’s confidential information in its possession, and the 25 || Party is subject to an agreement with the Non-Party not to produce the Non-Party’s 26 || confidential information, then the Party shall: 27 (1) promptly notify in writing the Requesting Party and the 28 || Non-Party that some or all of the information requested is subject to a LEP 4gys.9104-5344v1 LA #4863.9022-7530 -11- cise se PROPOSED STIPULATED

1 || confidentiality agreement with a Non-Party; 2 (2) promptly provide the Non-Party with a copy of the Order 3 || in this Action, the relevant discovery request(s), and a reasonably specific 4 || description of the information requested; and 5 (3) make the information requested available for inspection 6 || by the Non-Party, if requested. 7 (c) Ifthe Non-Party fails to seek a protective order from this Court 8 || within 14 days of receiving the notice and accompanying information, the 9 || Receiving Party may produce the Non-Party’s confidential information responsive 10 || to the discovery request. If the Non-Party timely seeks a protective order, the 11 || Receiving Party shall not produce any information in its possession or control that 12 || 1s subject to the confidentiality agreement with the Non-Party before a 13 || determination by the court. Absent a court order to the contrary, the Non-Party shall 14 || bear the burden and expense of seeking protection in this court of its Protected 15 || Material. 16 | 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 17 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 18 || Protected Material to any person or in any circumstance not authorized under this 19 || Order, the Receiving Party must immediately (a) notify in writing the Designating 20 || Party of the unauthorized disclosures, (b) use its best efforts to retrieve all 21 || unauthorized copies of the Protected Material, (c) inform the person or persons to 22 || whom unauthorized disclosures were made of all the terms of this Order, and (d) 23 || request such person or persons to execute the “Acknowledgment and Agreement to 24 || Be Bound” (Exhibit A). 25 || 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 26 PROTECTED MATERIAL 27 When a Producing Party gives notice to Receiving Parties that certain 28 || inadvertently produced material is subject to a claim of privilege or other LEP 4gys.9104-5344v1 LA #4863.9022-7530 -12- cise se PROPOSED STIPULATED

1 || protection, the obligations of the Receiving Parties are those set forth in Federal 2 || Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 3 || whatever procedure may be established in an e-discovery order that provides for 4 || production without prior privilege review. Pursuant to Federal Rule of Evidence 5 || 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure 6 || of a communication or information covered by the attorney-client privilege or work 7 || product protection, the parties may incorporate their agreement in the Order 8 || submitted to the court. 12. MISCELLANEOUS 10 12.1 Right to Further Relief. Nothing in this Order abridges the right of 11 || any person to seek its modification by the Court in the future. 12 12.2 Right to Assert Other Objections. By stipulating to the entry of this 13 || Protective Order, no Party waives any right it otherwise would have to object to 14 || disclosing or producing any information or item on any ground not addressed in 15 || this Order. Similarly, no Party waives any right to object on any ground to use in 16 || evidence of any of the material covered by this Protective Order. 17 12.3 Filing Protected Material. A Party that secks to file under seal any 18 || Protected Material must comply with Local Civil Rule 79-5. Protected Material 19 || may only be filed under seal pursuant to a court order authorizing the sealing of the 20 || specific Protected Material at issue. If a Party’s request to file Protected Material 21 || under seal is denied by the court, then the Receiving Party may file the information 22 || in the public record unless otherwise instructed by the court. 23 | 13. FINAL DISPOSITION 24 After the final disposition of this Action, as defined in paragraph 2.8, within 25 || 60 days of a written request by the Designating Party, each Receiving Party must 26 || return all Protected Material to the Producing Party or destroy such material. As 27 || used in this subdivision, “all Protected Material” includes all copies, abstracts, 28 || compilations, summaries, and any other format reproducing or capturing any of the LEP 4gys.9104-5344v1 LA #4863.9022-7530 -13- cise se PROPOSED STIPULATED

1 || Protected Material. Whether the Protected Material is returned or destroyed, the 2 || Receiving Party must submit a written certification to the Producing Party (and, if 3 || not the same person or entity, to the Designating Party) by the 60 day deadline that 4 || (1) identifies (by category, where appropriate) all the Protected Material that was 5 || returned or destroyed and (2) affirms that the Receiving Party has not retained any 6 || copies, abstracts, compilations, summaries or any other format reproducing or 7 || capturing any of the Protected Material. Notwithstanding this provision, Counsel 8 || are entitled to retain an archival copy of all pleadings, motion papers, trial, 9 || deposition, and hearing transcripts, legal memoranda, correspondence, deposition 10 || and trial exhibits, expert reports, attorney work product, and consultant and expert 11 || work product, even if such materials contain Protected Material. Any such archival 12 || copies that contain or constitute Protected Material remain subject to this Protective 13 || Order. 14} 14. VIOLATION 15 Any violation of this Order may be punished by appropriate measures 16 || including, without limitation, contempt proceedings and/or monetary sanctions. 17 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 18 19 || Dated: May 1, 2023 HADSELL STORMER RENICK & DAI LLP

21 By: _/s/ Hanna Chandoo 22 Dan Stormer 23 Attonaeye tor Plaintifis JONATHAN 24 GALLAGHER 25 26 27 28 LEP 4gys.9104-5344v1 LA #4863.9022-7530 -14- cise se PROPOSED STIPULATED

l Dated: May 1, 2023 BURKE, WILLIAMS & SORENSEN, 2 LLP 3 4 By:_/s/ Charles E. Slyngstad Charles E. Slyngstad 5 Brian S. Ginter Attorneys for Defendant CITY OF 6 LOS ANGELES 7 8 9 10 1] 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 |); ————— ' Filer attests that all signatories listed concur in the filing’s content and have 28 || authorized the filing pursuant to Local Rule 5-4.3.4(a)(2)(i). WILLIAMS CASE NO. 2:22-CV-03106-MWF-AGR 4895-2104-5344v1 LA #4863-3022-7530 v1 -15- PROPOSED STIPULATED

l Having considered the papers, the finding that good cause exists, the Parties’ 2 || Stipulated Protective Order is granted. 3 IT IS SO ORDERED. 4 5 lbini 1 Koning, g | Dae August 9 2029 UNITED STATES MAGISTRATE JUDGE 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 LEP 4gys.9104-5344v1 LA #4863.9022-7530 -16- cise se PROPOSED STIPULATED

l ATTACHMENT “A” 2 NONDISCLOSURE AGREEMENT 3 I, do solemnly swear that I am fully familiar with 4 || the terms of the Protective Order entered in Jonathan Peltz, et al. v. City of Los 5 || Angeles, et al., United States District Court for the Central District of California, 6 || Central Division, Case No. 2:22-CV-03106-MWF-AGR, and hereby agree to 7 || comply with and be bound by the terms and conditions of said Order. I hereby 8 || consent to the jurisdiction of the United States District Court for the Central District 9 || of California for purposes of enforcing this Order. 10 11 Dated: Signed: 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 LEP 4gys.9104-5344v1 LA #4863.9022-7530 -17- cise se PROPOSED STIPULATED