1 2 3 4 5 6 7 UNITED STATES DISTRICT COURT 8 CENTRAL DISTRICT OF CALIFORNIA 9 10 MARCO DIAZ, an individual, CASE NO. 2:23-cv-01916-SPG-MAA 11 [Assigned to Judge Sherilyn Garnett, 1st Cthse, Ctrm 5C; Plaintiff, Mag. Audero, USDC-Roybal Bldg, Ctrm 690] 12 v.

13 CITY OF LOS ANGELES, a [PROPOSED] STIPULATED 14 municipality; LAPD OFFICER PROTECTIVE ORDER KELEIGH EDWARDS (#40564), an

15 individual; LAPD OFFICER HERIBERTO CRISANTOS 16 GARCIA (#39541), an individual; and DOES 1-10, inclusive, 17 individuals,

18 Defendants.

19 20 1. PURPOSES AND LIMITATIONS 21 Discovery in this action is likely to involve production of confidential, 22 proprietary, or private information for which special protection from public 23 disclosure and from use for any purpose other than prosecuting this litigation may 24 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 25 enter the following Stipulated Protective Order. The parties acknowledge that this 26 Stipulated Protective Order does not confer blanket protections on all disclosures or 27 responses to discovery and that the protection it affords from public disclosure and 28 use extends only to the limited information or items that are entitled to confidential 1 treatment under the applicable legal principles. The parties further acknowledge, as 2 set forth in Section 13.3 below, that this Stipulated Protective Order does not entitle 3 them to file confidential information under seal; Local Rule 79-5 sets forth the 4 procedures that must be followed and the standards that will be applied when a 5 party seeks permission from the Court to file material under seal. 6 7 2. GOOD CAUSE STATEMENT 8 This action involves the City of Los Angeles and members of the Los Angeles 9 Police Department. Plaintiff is seeking materials and information that Defendants 10 the City of Los Angeles et al. (“City”) maintains as confidential, such as personnel 11 files of the police officers involved in this incident, Internal Affairs materials and 12 information, video recordings (including Body-Worn Video recordings and Digital 13 In-Car Video recordings), audio recordings, and information and other administrative 14 materials and information currently in the possession of the City and which the City believes need special protection from public disclosure and from use for any purpose 15 other than prosecuting this litigation. Plaintiff is also seeking official information 16 contained in the personnel files of the police officers involved in the subject incident, 17 which the City maintains as strictly confidential and which the City believes need 18 special protection from public disclosure and from use for any purpose other than 19 prosecuting this litigation. 20 The City asserts that the confidentiality of the materials and information sought 21 by Plaintiff is recognized by California and federal law, as evidenced inter alia by 22 California Penal Code section 832.7 and Kerr v. United States Dist. Ct. for N.D. Cal., 23

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

(1976). The City has not 24 publicly released the materials and information referenced above except under 25 protective order or pursuant to a court order, if at all. These materials and information 26 are of the type that has been used to initiate disciplinary action against Los Angeles 27 Police Department (“LAPD”) officers, and has been used as evidence in disciplinary 28 1 proceedings, where the officers’ conduct was considered to be contrary to LAPD 2 policy. 3 The City contends that absent a protective order delineating the responsibilities 4 of nondisclosure on the part of the parties hereto, there is a specific risk of 5 unnecessary and undue disclosure by one or more of the many attorneys, secretaries, 6 law clerks, paralegals and expert witnesses involved in this case, as well as the 7 corollary risk of embarrassment, harassment and professional and legal harm on the part of the LAPD officers referenced in the materials and information. 8 The City also contends that the unfettered disclosure of the materials and 9 information, absent a protective order, would allow the media to share this 10 information with potential jurors in the area, impacting the rights of the City herein 11 to receive a fair trial. 12 Accordingly, to expedite the flow of information, to facilitate the prompt 13 resolution of disputes over confidentiality of discovery materials, to adequately 14 protect information the parties are entitled to keep confidential, to ensure that the 15 parties are permitted reasonable necessary uses of such material in preparation for 16 and in the conduct of trial, to address their handling at the end of the litigation, and 17 serve the ends of justice, a protective order for such information is justified in this 18 matter. It is the intent of the parties that information will not be designated as 19 confidential for tactical reasons and that nothing be so designated without a good 20 faith belief that it has been maintained in a confidential, non-public manner, and there 21 is good cause why it should not be part of the public record of this case. 22 23 24 3. DEFINITIONS 25 3.1. Action: This pending federal lawsuit – Marco Diaz v. City of Los 26 Angeles, et al., Case No. 2:23-cv-01916-SPG-MAA. 27 3.2. Challenging Party: A Party or Nonparty that challenges the 28 designation of information or items under this Stipulated Protective 1 Order. 2 3.3. “CONFIDENTIAL” Information or Items: Information (regardless of 3 how it is generated, stored or maintained) or tangible things that 4 qualify for protection under Federal Rule of Civil Procedure 26(c), and 5 as specified above in the Good Cause Statement. 6 3.4. Counsel: Outside Counsel of Record and In-House Counsel (as well 7 as their support staff). 8 3.5. Designating Party: A Party or Nonparty that designates information or 9 items that it produces in disclosures or in responses to discovery as 10 “CONFIDENTIAL.” 11 3.6. Disclosure or Discovery Material: All items or information, regardless 12 of the medium or manner in which it is generated, stored, or 13 maintained (including, among other things, testimony, transcripts, and 14 tangible things), that is produced or generated in disclosures or 15 responses to discovery in this matter. 16 3.7. Expert: A person with specialized knowledge or experience in a 17 matter pertinent to the litigation who has been retained by a Party or its 18 counsel to serve as an expert witness or as a consultant in this Action. 19 3.8. In-House Counsel: Attorneys who are employees of a party to this 20 Action. In-House Counsel does not include Outside Counsel of 21 Record or any other outside counsel. 22 3.9. Nonparty: Any natural person, partnership, corporation, association, 23 or other legal entity not named as a Party to this action. 24 3.10. Outside Counsel of Record: Attorneys who are not employees of a 25 party to this Action but are retained to represent or advise a party to 26 this Action and have appeared in this Action on behalf of that party or 27 are affiliated with a law firm which has appeared on behalf of that 28 party, and includes support staff. 1 3.11. Party: Any party to this Action, including all of its officers, directors, 2 employees, consultants, retained experts, In-House Counsel, and 3 Outside Counsel of Record (and their support staffs). 4 3.12. Producing Party: A Party or Nonparty that produces Disclosure or 5 Discovery Material in this Action. 6 3.13. Professional Vendors: Persons or entities that provide litigation 7 support services (e.g., photocopying, videotaping, translating, 8 preparing exhibits or demonstrations, and organizing, storing, or 9 retrieving data in any form or medium) and their employees and 10 subcontractors. 11 3.14. Protected Material: Any Disclosure or Discovery Material that is 12 designated as “CONFIDENTIAL.” 13 3.15. Receiving Party: A Party that receives Disclosure or Discovery 14 Material from a Producing Party. 15 4. SCOPE 16 The protections conferred by this Stipulated Protective Order cover not only 17 Protected Material, but also (1) any information copied or extracted from Protected 18 Material; (2) all copies, excerpts, summaries, or compilations of Protected Material; 19 and (3) any testimony, conversations, or presentations by Parties or their Counsel 20 that might reveal Protected Material. 21 Any use of Protected Material at trial shall be governed by the orders of the 22 trial judge. This Stipulated Protective Order does not govern the use of Protected 23 Material at trial. 24 25 5. DURATION 26 Once a case proceeds to trial, all of the information that was designated as 27 confidential or maintained pursuant to this Stipulated Protective Order and that is 28 introduced or admitted as an exhibit at trial becomes public and presumptively will 1 be available to all members of the public, including the press, unless compelling 2 reasons supported by specific factual findings to proceed otherwise are made to the 3 trial judge in advance of the trial. See Kamakana v. City and County of Honolulu, 4

(9th Cir. 2006) (distinguishing “good cause” showing for 5 sealing documents produced in discovery from “compelling reasons” standard when 6 merits-related documents are part of court record). Accordingly, the terms of this 7 Stipulated Protective Order do not extend beyond the commencement of the trial as 8 to the CONFIDENTIAL information and materials introduced or admitted as an 9 exhibit at trial. 10 11 Even after final disposition of this litigation, the confidentiality obligations 12 imposed by this Stipulated Protective Order shall remain in effect until a 13 Designating Party agrees otherwise in writing or a court order otherwise directs. 14 Final disposition shall be deemed to be the later of (1) dismissal of all claims and 15 defenses in this Action, with or without prejudice; and (2) final judgment herein 16 after the completion and exhaustion of all appeals, rehearings, remands, trials, or 17 reviews of this Action, including the time limits for filing any motions or 18 applications for extension of time pursuant to applicable law. 19 20 6. DESIGNATING PROTECTED MATERIAL 21 6.1. Exercise of Restraint and Care in Designating Material for Protection. 22 Each Party or Nonparty that designates information or items for 23 protection under this Stipulated Protective Order must take care to 24 limit any such designation to specific material that qualifies under the 25 appropriate standards. The Designating Party must designate for 26 protection only those parts of material, documents, items, or oral or 27 written communications that qualify so that other portions of the 28 material, documents, items, or communications for which protection is 1 not warranted are not swept unjustifiably within the ambit of this 2 Stipulated Protective Order. 3 Mass, indiscriminate, or routinized designations are prohibited. 4 Designations that are shown to be clearly unjustified or that have been 5 made for an improper purpose (e.g., to unnecessarily encumber the 6 case development process or to impose unnecessary expenses and 7 burdens on other parties) may expose the Designating Party to 8 sanctions. 9 6.2. Manner and Timing of Designations. 10 Except as otherwise provided in this Stipulated Protective Order 11 (see, e.g., Section 6.2(a)), or as otherwise stipulated or ordered, 12 Disclosure or Discovery Material that qualifies for protection under 13 this Stipulated Protective Order must be clearly so designated before 14 the material is disclosed or produced. 15 Designation in conformity with this Stipulated Protective Order 16 requires the following: 17 (a) For information in documentary form (e.g., paper or electronic 18 documents, but excluding transcripts of depositions or other 19 pretrial or trial proceedings), that the Producing Party affix at a 20 minimum, the legend “CONFIDENTIAL” to each page that 21 contains protected material. If only a portion or portions of the 22 material on a page qualifies for protection, the Producing Party 23 also must clearly identify the protected portion(s) (e.g., by 24 making appropriate markings in the margins). 25 A Party or Nonparty that makes original documents 26 available for inspection need not designate them for protection 27 until after the inspecting Party has indicated which documents it 28 would like copied and produced. During the inspection and 1 before the designation, all of the material made available for 2 inspection shall be deemed “CONFIDENTIAL.” After the 3 inspecting Party has identified the documents it wants copied 4 and produced, the Producing Party must determine which 5 documents, or portions thereof, qualify for protection under this 6 Stipulated Protective Order. Then, before producing the 7 specified documents, the Producing Party must affix the legend 8 “CONFIDENTIAL” to each page that contains Protected 9 Material. If only a portion or portions of the material on a page 10 qualifies for protection, the Producing Party also must clearly 11 identify the protected portion(s) (e.g., by making appropriate 12 markings in the margins). 13 (b) For testimony given in depositions, that the Designating Party 14 identify the Disclosure or Discovery Material on the record, 15 before the close of the deposition, all protected testimony. 16 (c) For information produced in nondocumentary form, and for any 17 other tangible items, that the Producing Party affix in a 18 prominent place on the exterior of the container or containers in 19 which the information is stored the legend “CONFIDENTIAL.” 20 If only a portion or portions of the information warrants 21 protection, the Producing Party, to the extent practicable, shall 22 identify the protected portion(s). 23 6.3. Inadvertent Failure to Designate. 24 If timely corrected, an inadvertent failure to designate qualified 25 information or items does not, standing alone, waive the Designating 26 Party’s right to secure protection under this Stipulated Protective Order 27 for such material. Upon timely correction of a designation, the 28 Receiving Party must make reasonable efforts to assure that the 1 material is treated in accordance with the provisions of this Stipulated 2 Protective Order. 3 4 7. CHALLENGING CONFIDENTIALITY DESIGNATIONS 5 7.1. Timing of Challenges. 6 Any Party or Nonparty may challenge a designation of 7 confidentiality at any time that is consistent with the Court’s 8 Scheduling Order. 9 7.2. Meet and Confer. 10 The Challenging Party shall initiate the dispute resolution 11 process, which shall comply with Local Rule 37.1 et seq., and with 12 Section 4 of Judge Audero’s Procedures (“Mandatory Telephonic 13 Conference for Discovery Disputes”).1 14 7.3. Burden of Persuasion. 15 The burden of persuasion in any such challenge proceeding shall 16 be on the Designating Party. Frivolous challenges, and those made for 17 an improper purpose (e.g., to harass or impose unnecessary expenses 18 and burdens on other parties) may expose the Challenging Party to 19 sanctions. Unless the Designating Party has waived or withdrawn the 20 confidentiality designation, all parties shall continue to afford the 21 material in question the level of protection to which it is entitled under 22 the Producing Party’s designation until the Court rules on the 23 challenge. 24 25 8. ACCESS TO AND USE OF PROTECTED MATERIALS 26 27 1 Judge Audero’s Procedures are available at 28 https://www.cacd.uscourts.gov/honorable-maria-audero. 1 8.1. Basic Principles. 2 A Receiving Party may use Protected Material that is disclosed 3 or produced by another Party or by a Nonparty in connection with this 4 Action only for prosecuting, defending, or attempting to settle this 5 Action. Such Protected Material may be disclosed only to the 6 categories of persons and under the conditions described in this 7 Stipulated Protective Order. When the Action reaches a final 8 disposition, a Receiving Party must comply with the provisions of 9 Section 14 below. 10 Protected Material must be stored and maintained by a 11 Receiving Party at a location and in a secure manner that ensures that 12 access is limited to the persons authorized under this Stipulated 13 Protective Order. 14 8.2. Disclosure of “CONFIDENTIAL” Information or Items. 15 Unless otherwise ordered by the Court or permitted in writing 16 by the Designating Party, a Receiving Party may disclose any 17 information or item designated “CONFIDENTIAL” only to: 18 (a) The Receiving Party’s Outside Counsel of Record, as well as 19 employees of said Outside Counsel of Record to whom it is 20 reasonably necessary to disclose the information for this Action; 21 (b) The officers, directors, and employees (including In-House 22 Counsel) of the Receiving Party to whom disclosure is 23 reasonably necessary for this Action; 24 (c) Experts of the Receiving Party to whom disclosure is reasonably 25 necessary for this Action and who have signed the 26 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 27 (d) The Court and its personnel; 28 (e) Court reporters and their staff; 1 (f) Professional jury or trial consultants, mock jurors, and 2 Professional Vendors to whom disclosure is reasonably 3 necessary or this Action and who have signed the 4 “Acknowledgment and Agreement to be Bound” (Exhibit A); 5 (g) The author or recipient of a document containing the 6 information or a custodian or other person who otherwise 7 possessed or knew the information; 8 (h) During their depositions, witnesses, and attorneys for witnesses, 9 in the Action to whom disclosure is reasonably necessary 10 provided: (i) the deposing party requests that the witness sign 11 the “Acknowledgment and Agreement to Be Bound” (Exhibit 12 A); and (ii) the witness will not be permitted to keep any 13 confidential information unless they sign the “Acknowledgment 14 and Agreement to Be Bound,” unless otherwise agreed by the 15 Designating Party or ordered by the Court. Pages of transcribed 16 deposition testimony or exhibits to depositions that reveal 17 Protected Material may be separately bound by the court 18 reporter and may not be disclosed to anyone except as permitted 19 under this Stipulated Protective Order; and 20 (i) Any mediator or settlement officer, and their supporting 21 personnel, mutually agreed upon by any of the parties engaged 22 in settlement discussions. 23 8.3. Counsel making the disclosure to any qualified person described 24 herein shall retain the original executed copy of the Nondisclosure Agreement until 25 sixty (60) days after this litigation has become final, including any appellate review, 26 and monitoring of an injunction. Counsel for the Receiving Party shall maintain all 27 signed Nondisclosure Agreements and shall produce the original signature page 28 upon reasonable written notice from opposing counsel. If an issue arises regarding 1 a purported unauthorized disclosure of Confidential Information, upon noticed 2 motion of contempt filed by the Designating Party, counsel for the Receiving Party 3 may be required to file the signed Nondisclosure Agreements, as well as a list of the 4 disclosed materials, in camera with the Court having jurisdiction of the Stipulation. 5 9. PROTECTED MATERIAL SUBPOENAED OR ORDERED 6 PRODUCED IN OTHER LITIGATION 7 If a Party is served with a subpoena or a court order issued in other litigation 8 that compels disclosure of any information or items designated in this Action as 9 “CONFIDENTIAL,” that Party must: 10 (a) Promptly notify in writing the Designating Party. Such notification 11 shall include a copy of the subpoena or court order; 12 (b) Promptly notify in writing the party who caused the subpoena or order 13 to issue in the other litigation that some or all of the material covered 14 by the subpoena or order is subject to this Stipulated Protective Order. 15 Such notification shall include a copy of this Stipulated Protective 16 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 19 affected. 20 The Party served with the subpoena or court order shall not produce any 21 information designated in this action as “CONFIDENTIAL” before a determination 22 by the Court from which the subpoena or order issued, unless the Party has 23 obtained the Designating Party’s permission. The Designating Party shall bear the 24 burden and expense of seeking protection in that court of its confidential material 25 and nothing in these provisions should be construed as authorizing or encouraging a 26 Receiving Party in this Action to disobey a lawful directive from another court. 27 28 10. A NONPARTY’S PROTECTED MATERIAL SOUGHT TO BE 1 PRODUCED IN THIS LITIGATION 2 10.1. Application. 3 The terms of this Stipulated Protective Order are applicable to 4 information produced by a Nonparty in this Action and designated as 5 “CONFIDENTIAL.” Such information produced by Nonparties in 6 connection with this litigation is protected by the remedies and relief 7 provided by this Stipulated Protective Order. Nothing in these 8 provisions should be construed as prohibiting a Nonparty from seeking 9 additional protections. 10 10.2. Notification. 11 In the event that a Party is required, by a valid discovery 12 request, to produce a Nonparty’s confidential information in its 13 possession, and the Party is subject to an agreement with the Nonparty 14 not to produce the Nonparty’s confidential information, then the Party 15 shall: 16 (a) Promptly notify in writing the Requesting Party and the 17 Nonparty that some or all of the information requested is subject 18 to a confidentiality agreement with a Nonparty; 19 (b) Promptly provide the Nonparty with a copy of the Stipulated 20 Protective Order in this Action, the relevant discovery 21 request(s), and a reasonably specific description of the 22 information requested; and 23 (c) Make the information requested available for inspection by the 24 Nonparty, if requested. 25 10.3. Conditions of Production. 26 If the Nonparty fails to seek a protective order from this Court 27 within fourteen (14) days after receiving the notice and accompanying 28 information, the Receiving Party may produce the Nonparty’s 1 confidential information responsive to the discovery request. If the 2 Nonparty timely seeks a protective order, the Receiving Party shall not 3 produce any information in its possession or control that is subject to 4 the confidentiality agreement with the Nonparty before a 5 determination by the Court. Absent a court order to the contrary, the 6 Nonparty shall bear the burden and expense of seeking protection in 7 this Court of its Protected Material. 8 9 11. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 10 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 11 Protected Material to any person or in any circumstance not authorized under this 12 Stipulated Protective Order, the Receiving Party immediately must (1) notify in 13 writing the Designating Party of the unauthorized disclosures, (2) use its best 14 efforts to retrieve all unauthorized copies of the Protected Material, (3) inform the 15 person or persons to whom unauthorized disclosures were made of all the terms of 16 this Stipulated Protective Order, and (4) request such person or persons to execute 17 the “Acknowledgment and Agreement to be Bound” (Exhibit A). 18 12. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 19 PROTECTED MATERIAL 20 When a Producing Party gives notice to Receiving Parties that certain 21 inadvertently produced material is subject to a claim of privilege or other 22 protection, the obligations of the Receiving Parties are those set forth in Federal 23 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 24 whatever procedure may be established in an e-discovery order that provides for 25 production without prior privilege review. Pursuant to Federal Rule of Evidence 26 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure 27 of a communication or information covered by the attorney-client privilege or work 28 product protection, the parties may incorporate their agreement in the Stipulated 1 Protective Order submitted to the Court. 2 3 13. MISCELLANEOUS 4 13.1. Right to Further Relief. 5 Nothing in this Stipulated Protective Order abridges the right of 6 any person to seek its modification by the Court in the future. 7 13.2. Right to Assert Other Objections. 8 By stipulating to the entry of this Stipulated Protective Order, no 9 Party waives any right it otherwise would have to object to disclosing 10 or producing any information or item on any ground not addressed in 11 this Stipulated Protective Order. Similarly, no Party waives any right 12 to object on any ground to use in evidence of any of the material 13 covered by this Stipulated Protective Order. 14 13.3. Filing Protected Material. 15 A Party that seeks to file under seal any Protected Material must 16 comply with Local Rule 79-5. Protected Material may only be filed 17 under seal pursuant to a court order authorizing the sealing of the 18 specific Protected Material at issue. If a Party's request to file 19 Protected Material under seal is denied by the Court, then the 20 Receiving Party may file the information in the public record unless 21 otherwise instructed by the Court. 22 23 14. FINAL DISPOSITION 24 After the final disposition of this Action, as defined in Section 5, supra, 25 within sixty (60) days of a written request by the Designating Party, each Receiving 26 Party must return all Protected Material to the Producing Party or destroy such 27 material. As used in this subdivision, “all Protected Material” includes all copies, 28 abstracts, compilations, summaries, and any other format reproducing or capturing 1 any of the Protected Material. Whether the Protected Material is returned or 2 destroyed, the Receiving Party must submit a written certification to the Producing 3 Party (and, if not the same person or entity, to the Designating Party) by the 60-day 4 deadline that (1) identifies (by category, where appropriate) all the Protected 5 Material that was returned or destroyed and (2) affirms that the Receiving Party has 6 not retained any copies, abstracts, compilations, summaries or any other format 7 reproducing or capturing any of the Protected Material. Notwithstanding this 8 provision, Counsel is entitled to retain an archival copy of all pleadings; motion 9 papers; trial, deposition, and hearing transcripts; legal memoranda; correspondence; 10 deposition and trial exhibits; expert reports; attorney work product; and consultant 11 and expert work product, even if such materials contain Protected Material. Any 12 such archival copies that contain or constitute Protected Material remain subject to 13 this Stipulated Protective Order as set forth in Section 5. 14 15. VIOLATION 15 Any violation of this Stipulated Order may be punished by any and all 16 appropriate measures including, without limitation, contempt proceedings and/or 17 monetary sanctions. 18 19 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

20 Dated: LAW OFFICES OF CHRISTIAN CONTRERAS 21 A PROFESSIONAL LAW CORPORATION

22 By: /s/ Christian Contreras 23 CHRISTIAN CONTRERAS, ESQ. Attorneys for Plaintiffs 24 25 Dated: October 30, 2023 Respectfully submitted, 26 27 HYDEE FELDSTEIN SOTO, City Attorney DENISE C. MILLS, Chief Deputy City Attorney 28 1 SCOTT MARCUS, Chief Asst. City Attorney CORY M. BRENTE, Senior Assistant City Attorney 2 3 By: Ty A. Ford TY A. FORD, Deputy City Attorney 4 Attorneys for Defendants, CITY OF LOS ANGELES, 5 KELEIGH EDWARDS and HERIBERTO CRISANTOS GARCIA 6 7 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 8 November 1, 2023 9 Dated: Maria A. Audero 10 United States Magistrate Judge 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, [full name], of 4 [address], declare under penalty of perjury that I have read in its 5 entirety and understand the Stipulated Protective Order that was issued by the 6 United States District Court for the Central District of California on 7 [date] in the case of Marco Diaz v. City of Los Angeles, et al., Case No. 2:23-cv- 8 01916-SPG-MAA. I agree to comply with and to be bound by all the terms of this 9 Stipulated Protective Order, and I understand and acknowledge that failure to so 10 comply could expose me to sanctions and punishment in the nature of contempt. I 11 solemnly promise that I will not disclose in any manner any information or item 12 that is subject to this Stipulated Protective Order to any person or entity except in 13 strict compliance with the provisions of this Stipulated Protective Order. 14 I further agree to submit to the jurisdiction of the United States District Court 15 for the Central District of California for the purpose of enforcing the terms of this 16 Stipulated Protective Order, even if such enforcement proceedings occur after 17 termination of this action. I hereby appoint [full name] 18 of [address and telephone number] 19 as my California agent for service of process in connection with this action or any 20 proceedings related to enforcement of this Stipulated Protective Order. 21 22 Signature: 23 Printed Name: 24 Date: 25 City and State Where Sworn and Signed: 26 27 28