1 OLIVAREZ MADRUGA LAW ORGANIZATION, LLP Thomas M. Madruga – SBN 160421 2 [email protected] 3 Daniel Lee – SBN 236811 NOTE: CHANGES MADE BY THE COURT [email protected] 4 500 South Grand Avenue – 12th Floor Los Angeles, CA 90071 5 Tel: (213) 744-0099 6 Fax: (213) 744-0093

7 Attorneys for Defendant CITY OF INGLEWOOD

8 LAW OFFICES OF DALE K. GALIPO Dale K. Galipo (SBN 144074) 9 [email protected] 10 Cooper Alison-Mayne (SBN 343169) [email protected] 11 21800 Burbank Boulevard, Suite 310 Woodland Hills, CA 91367 12 Phone: (818) 347-3333

13 Attorneys for Plaintiff, PETRA MORA 14

15 UNITED STATES DISTRICT COURT

16 FOR THE CENTRAL DISTRICT OF CALIFORNIA

17

18 PETRA MORA, individually and as ) Case No.: 2:24-cv-02970-SB-JPR successor-in-interest to Ivan Mora, ) Hon. Stanley Blumenfeld, Jr. 19 ) Plaintiff, ) DISCOVERY MATTER 20 ) 21 ) STIPULATED PROTECTIVE ORDER v. ) GOVERNING PRODUCTION OF 22 ) “CONFIDENTIAL” INFORMATION ) 23 CITY OF INGLEWOOD; and DOES ) 24 1–10, ) [Discovery Document: Referred to ) Magistrate Judge Jean P. Rosenbluth] 25 Defendants. ) ) 26

27

28 1 PURPOSE AND LIMITATIONS 2 Discovery in this action is likely to involve production of confidential or private 3 {information for which special protection from public disclosure and from use for any 4 purpose other than prosecuting this action may be warranted. Accordingly, the parties 5 |{hereby stipulate to and petition the Court to enter the following [Proposed] Stipulated 6 || Protective Order (hereafter "this Order"). The parties acknowledge that this Order does 7 ||not confer blanket protections on all disclosures or responses to discovery; and that the 8 protection it affords from public disclosure and use extends only to the limited 9 || information or items that are entitled to confidential treatment under the applicable legal 10 || principles. 11 GOOD CAUSE STATEMENT 12 This action is likely to involve confidential information pertaining to personnel 13 ||records and other materials subject to privacy protections for which special protection 14 || from public disclosure and from use for any purpose other than prosecution of this action 15 || may be warranted. Limiting disclosure of these documents to the context of this litigation 16 ||as provided herein will, accordingly, further important law enforcement objectives and 17 || interests, including the safety of personnel and the public, as well as the privacy rights of 18 || plaintiff, the individual defendants, and third-party witnesses. Such confidential 19 ||materials and information may consist of, among other things, materials entitled to 20 || privileges and/or protections under the following: the United States Constitution, First 21 || Amendment; the California Constitution, Article I, Section 1; California Penal Code §§ 22 || 832.5, 832.7, and 832.8; California Evidence Code §§ 1040 and 1043, et seq.; the Privacy 23 || Act of 1974, 5 U.S.C. § 552a; Health Insurance Portability and Accountability Act of 24 || 1996 (HIPAA),

decisional law relating to such provisions; and 25 information otherwise generally unavailable to the public; or which may be privileged or 26 otherwise protected from disclosure under state or federal statutes, court rules, case 27 ||decisions, information consisting of materials entitled to the Official Information 28 || Privilege. Confidential Information with respect to the Defendants may include but is not

1 || limited to: personnel files; internal investigative files and documents; email and written 2 || correspondence records; and policies and procedures that are kept from the public in the 3 ||ordinary course of business; as well as other items subject to the Official Information 4 || Privilege and other privileges. Confidential Information with respect to the Plaintiff may 5 include but is not limited to: email and written correspondence records; law enforcement 6 ||records related to Plaintiff; and psychological and medical notes, evaluations, reports, 7 treatment plans. The parties reserve the right to challenge a designation of 8 ||confidentiality pursuant to the terms set forth under Paragraph 8 of this Order. 9 || Accordingly, to expedite the flow of information; to facilitate the prompt resolution of 10 || disputes over confidentiality of discovery materials; to adequately protect information the 11 ||parties are entitled to keep confidential; to ensure that the parties are permitted to 12 ||reasonably use such material in preparation for and in conduct of trial; to address their 13 || handling at the end of the litigation; and serve the ends of justice, a protective order for 14 information is justified in this matter. It 1s the intent of the parties that information 15 || will not be designated as confidential for tactical reasons and that nothing be so 16 || designated without a good faith belief that it has been maintained in a confidential, non- 17 || public manner; and there is good cause why it should not be part of the public record of 18 || this case. 19 | TT. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 20 The parties further acknowledge, as set forth in Section 14.3, below, that this Order 21 ||does not entitle them to file confidential information under seal; Local Civil Rule 79-5 22 ||sets forth the procedures that must be followed and the standards that will be applied 23 || when a party seeks permission from the court to file material under seal. 24 There is a strong presumption that the public has a right of access to judicial 25 || proceedings and records in civil cases. In connection with non-dispositive motions, good 26 ||cause must be shown to support a filing under seal. Kamakana v. City and County of 27 || Honolulu,

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

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

,

1 ||577 (E.D. Wis. 1999) (even stipulated protective orders require good cause showing, and 2 ||a specific showing of good cause or compelling reasons with proper evidentiary support 3 ||and legal justification, must be made with respect to material that a party seeks to file 4 || under seal). The parties’ mere designation of material as "CONFIDENTIAL" does not— 5 || without the submission of competent evidence by declaration, establishing that the 6 material sought to be filed under seal qualifies as confidential, privileged, or otherwise 7 || protectable— constitute good cause. Further, if a party request sealing related to a 8 || dispositive motion or trial, then compelling reasons, not only good cause, for the sealing 9 be shown, and the relief sought shall be narrowly tailored to serve the specific 10 || interest to be protected. See Pintos v. Pacific Creditors Ass’n,

(9th 11 || Cir. 2010). Any document that is not confidential, privileged, or otherwise protectable 12 |/in its entirety will not be filed under seal if the confidential portions can be redacted. If 13 documents can be redacted, then a redacted version for public viewing, omitting only the 14 || confidential, privileged, or otherwise protectable portions of the document, shall be filed. 15 || Any application that seeks to file documents under seal in their entirety should include 16 explanation of why redaction is not feasible. 17 DEFINITIONS 18 4.1 Action: Petra Mora v. City of Inglewood, Case No. 2:24-cv-02970. 19 4.2 Challenging Party: a Party or Non-Party that challenges the designation 20 4.3 "CONFIDENTIAL" Information or Items: Information (regardless of the 21 ||medium or manner in which it is generated, stored, or maintained) or tangible things that 22 || qualify for protection under Federal Rule of Civil Procedure 26(c), and as specified above 23 ||in the Good Cause Statement. 24 4.4 Counsel: General Counsel of Record and House Counsel (as well as their 25 || support staff). 26 4.5 Designating Party: a Party or Non-Party that designated information or items 27 ||that it produces in disclosures or in responses to discovery as "CONFIDENTIAL." 28

1 4.6 Disclosure or Discovery Material: all items or information, regardless of the 2 medium or manner in which it is generated, stored, or maintained (including, among other 3 things, testimony, transcripts, and tangible things), that are produced or generated in 4 disclosures or responses to discovery in this matter. 5 4.7 Expert: a person with specialized knowledge or experience in a matter pertinent 6 to the litigation who has been retained by a Party or its counsel to serve as an expert 7 witness or as a consultant in this Action. 8 4.8 House Counsel: attorneys who are employees of a party to this Action. House 9 Counsel does not include General Counsel of Record or any other outside Counsel. 10 4.9 Non-Party: any natural person, partnership, corporation, association, or other 11 legal entity not named as a Party to this action. 12 4.10 General Counsel of Record: attorneys who are not employees of a Party to 13 this Action but are retained to represent or advise a Party to this Action and have appeared 14 in this Action on behalf of that party or are affiliated with a law firm that has appeared 15 on behalf of that Party, as well as their support staff. 16 4.11 Party: any Party to this Action, including all of its officers, directors, 17 employees, consultants, retained experts, and General Counsel of Record (and their 18 support staffs). 19 4.12 Producing Party: a Party or Non-Party that makes a Disclosure or produces 20 Discovery Material in this Action. 21 4.13 Professional Vendors: persons or entities that provide litigation support 22 services (e.g., photocopying, videotaping, translating, preparing exhibits or 23 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 24 their employees and subcontractors. 25 4.14 Protected Material: any Disclosure or Discovery Material that is designated 26 as "CONFIDENTIAL." 27 4.15 Receiving Party: a Party that receives a Disclosure or Discovery Material from 28 a Producing Party. 1||V. SCOPE 2 The protections conferred by this Stipulation and Order cover not only Protected 3 || Material (as defined above), but also (1) any information copied or extracted from 4 ||Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 5 Material; and (3) any testimony, conversations, or presentations by Parties or their 6 || Counsel (as defined by Sections 4.8 and 4.10) that might reveal Protected Material. Any 7 of Protected Material at trial shall be governed by the orders of the trial judge. This 8 || Order does not govern the use of Protected Material at trial. 9 DURATION 10 The confidentiality obligations imposed by this Order shall remain in effect until 11 || Final Disposition of this case. "Final Disposition" shall be deemed to be the later of (1) 12 dismissal of all claims and defenses in this Action, with or without prejudice; and (2) 13 || final judgment herein after the completion and exhaustion of all appeals, rehearings, 14 || remands, trials, or reviews of this Action, including the time limits for filing any motions 15 || or applications for extension of time pursuant to applicable law. 16 || VH. DESIGNATING PROTECTED MATERIAL 17 7.1 Exercise of Restraint and Care in Designating Material for Protection. Each 18 || Party or Non-Party that designates information or items for protection under this Order 19 || must take care to limit any such designation to specific material that qualifies under the 20 appropriate standards. To the extent practicable, the Designating Party must designate 21 protection only those parts of material, documents, items or oral or written 22 ||communications that qualify so that other portions of the material, documents, items or 23 ||communications for which protection is not warranted are not swept unjustifiably within 24 ||the ambit of this Order. Indiscriminate or routinized designations are prohibited. 25 || Designations that are shown to be clearly unjustified or that have been made for an 26 ||improper purpose (e.g., to unnecessarily encumber the case development process or to 27 ||impose unnecessary expenses and burdens on other parties) may expose the Designating 28 || Party to sanctions. If it comes to a Designating Party's attention that information or items

1 that it designated for protection do not qualify for protection, that Designating Party must 2 promptly notify all other Parties that it is withdrawing the inapplicable designation. 3 7.2 Manner and Timing of Designations. Except as otherwise provided in this 4 Order (see, e.g., second paragraph of section 7.2(a) below), or as otherwise stipulated or 5 ordered, Disclosure or Discovery Material that qualifies for protection under this Order 6 must be clearly so designated before the material is disclosed or produced. 7 Designation in conformity with this Order requires: 8 (a) for information in documentary form (e.g., paper or electronic documents, but 9 excluding transcripts of depositions or other pretrial or trial proceedings), that the 10 Producing Party affix at a minimum, the legend "CONFIDENTIAL" (hereinafter 11 "CONFIDENTIAL legend"), to each page that contains protected material. 12 A Party or Non-Party that makes original documents available for inspection need 13 not designate them for protection until after the inspecting Party has indicated which 14 documents it would like copied and produced. During the inspection and before the 15 designation, all of the materials made available for inspection shall be deemed 16 "CONFIDENTIAL." After the inspecting Party has identified the documents it wants 17 copied and produced, the Producing Party must determine which documents, or portions 18 thereof, qualify for protection under this Order. Then, before producing the specified 19 documents, the Producing Party must affix the "CONFIDENTIAL legend" to each page 20 that contains Protected Material. If only a portion of the material on a page qualifies for 21 protection, the Producing Party also must clearly identify the protected portion(s) (e.g., 22 by making appropriate markings in the margins). 23 (b) for testimony given in depositions that the Designating Party identifies the 24 Disclosure or Discovery Material on the record, and before the close of the deposition all 25 protected testimony. 26 (c) for information produced in some form other than documentary and for any 27 other tangible items, that the Producing Party affix in a prominent place on the exterior 28 of the container or containers in which the information is stored the legend 1 ||"CONFIDENTIAL." If only a portion or portions of the information warrants protection, 2 Producing Party, to the extent practicable, shall identify the protected portion(s). 3 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to 4 || designate qualified information or items does not, standing alone, waive the Designating 5 Party's right to secure protection under this Order for such material. Upon timely 6 || correction of a designation, the Receiving Party must make reasonable efforts to assure 7 || that the material is treated in accordance with the provisions of this Order. 8 || VI. CHALLENGING CONFIDENTIALITY DESIGNATIONS 9 8.1 Timing of Challenges. Any Party or Non-Party may challenge a designation of 10 confidentiality at any time that is consistent with the Court’s Scheduling Order. 11 8.2 Meet and Confer. The Challenging Party shall initiate the meet and confer 12 || process outlined in Local Rule 37.1, et seq. 13 8.3 The burden of persuasion, in any such challenge proceeding, shall be on the 14 || Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., 15 harass or impose unnecessary expenses and burdens on other parties) may expose the 16 || Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn 17 || the confidentiality designation, all parties shall continue to afford the material in question 18 || the level of protection to which it is entitled under the Producing Party's designation until 19 || the Court rules on the challenge. 20 ACCESS TO AND USE OF PROTECTED MATERIAL 21 9.1 Basic Principles. A Receiving Party may use Protected Material that is 22 || disclosed or produced by another Party or by a Non-Party in connection with this Action 23 for prosecuting, defending or attempting to settle this Action. Such Protected 24 || Material may be disclosed only to the categories of persons and under the conditions 25 || described in this Order. When the Action has been terminated, a Receiving Party must 26 ||comply with the provisions of Section XV, infra. 27 28

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 9.2 Disclosure of "CONFIDENTIAL" Information or Items. Unless otherwise 5 ordered by the Court or permitted in writing by the Designating Party, a Receiving Party 6 may disclose any information or item designated “CONFIDENTIAL” to: 7 (a) the Receiving Party's General Counsel of Record in this Action, as well as 8 employees of said General Counsel of Record to whom it is reasonably necessary to 9 disclose the information for this Action; 10 (b) the officers, directors, and employees (including House Counsel) of the 11 Receiving Party to whom disclosure is reasonably necessary for this Action; 12 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure is 13 reasonably necessary for this Action and who have signed the "Acknowledgment and 14 Agreement to Be Bound," attached and hereafter referred to as "Exhibit A." 15 (d) the court and its personnel; 16 (e) court reporters and their staff; 17 (f) professional jury or trial consultants, mock jurors, and Professional Vendors to 18 whom disclosure is reasonably necessary for this Action and who have signed Exhibit A. 19 (g) the author or recipient of a document containing the information or a custodian 20 or other person who otherwise possessed or knew the information; 21 (h) during their depositions, witnesses, and attorneys for witnesses, in the Action 22 to whom disclosure is reasonably necessary provided: (1) the deposing party requests that 23 the witness sign Exhibit A; and (2) they will not be permitted to keep any confidential 24 information unless they sign Exhibit A, unless otherwise agreed by the Designating Party 25 or ordered by the Court. Pages of transcribed deposition testimony or exhibits to 26 depositions that reveal Protected Material may be separately bound by the court reporter 27 and may not be disclosed to anyone except as permitted under this Order; and, 28 1 (i) any mediator or settlement officer, and their supporting personnel, mutually 2 ||agreed upon by any of the parties engaged in settlement discussions or appointed by the 3 || Court. 4||X. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 5 IN OTHER LITIGATION 6 If a Party is served with a subpoena or a court order issued in other litigation that 7 |{compels disclosure of any information or items designated in this Action as 8 ||"CONFIDENTIAL," that Party must: 9 (a) promptly notify in writing the Designating Party. Such notification shall include 10 ||a copy of the subpoena or court order unless prohibited by law; 11 (b) promptly notify in writing the party who caused the subpoena or order to issue 12 ||1n the other litigation that some or all of the material covered by the subpoena or order is 13 |} subject to this Order. Such notification shall include a copy of this Order; and, 14 (c) cooperate with respect to all reasonable procedures sought to be pursued by the 15 || Designating Party whose Protected Material may be affected. If the Designating Party 16 || timely seeks a protective order, the Party served with the subpoena or court order shall 17 ||not produce any information designated in this action as "CONFIDENTIAL" before a 18 || determination by the relevant Court unless the Party has obtained the Designating Party’s 19 ||permission. The Designating Party shall bear the burden and expense of seeking 20 || protection in that court of its confidential material and nothing in these provisions should 21 construed as authorizing or encouraging a Receiving Party in this Action to disobey a 22 lawful directive from another court. 23 ||XI. A NON-PARTY'S PROTECTED MATERIAL SOUGHT TO BE 24 PRODUCED IN THIS LITIGATION 25 (a) The terms of this Order are applicable to information produced by a Non-Party 26 this Action and designated as "CONFIDENTIAL." Such information produced by 27 ||Non-Parties in connection with this litigation is protected by the remedies and relief 28

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

1 || were made of all the terms of this Order; and (d) request such person or persons to execute 2 || Exhibit A. 3 || XII. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 4 PROTECTED MATERIAL 5 When a Producing Party gives notice to Receiving Parties that certain inadvertently 6 || produced material is subject to a claim of privilege or other protection, the obligations of 7 Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). 8 || This provision is not intended to modify whatever procedure may be established in an e- 9 || discovery order that provides for production without prior privilege review. Pursuant to 10 || Federal Rule of Evidence 502(d) and (e), insofar as the Parties reach an agreement on the 11 effect of disclosure of a communication or information covered by the attorney-client 12 || privilege or work product protection, the Parties may incorporate their agreement in a 13 || subsequent stipulation to the Court provided the Court so approves. 14 || XIV. MISCELLANEOUS 15 14.1 Right to Further Relief. Nothing in this Order abridges the right of any person 16 || to seek its modification by the Court in the future. 17 14.2 Right to Assert Other Objections. By stipulating to the entry of this Order, no 18 || Party waives any right it otherwise would have to object to disclosing or producing any 19 information or item on any ground not addressed in this Order. Similarly, no Party waives 20 right to object on any ground to use in evidence of any of the material covered by 21 Order. 22 14.3 Filing Protected Material. A Party that seeks to file under seal any Protected 23 || Material must comply with Local Civil Rule 79-5. Protected Material may only be filed 24 under seal pursuant to a court order authorizing the sealing of the specific Protected 25 || Material at issue. If a Party's request to file Protected Material under seal is denied by 26 || the Court, then the Receiving Party may file the information in the public record unless 27 || otherwise instructed by the Court. 28

1 ||XV. FINAL DISPOSITION 2 Within 60 days of a written request by the Designating Party, each Receiving Party 3 || must return all Protected Material to the Producing Party or destroy such material, except 4 || those documents required to be maintained as part of the General Counsel’s file. As used 5 this subdivision, "all Protected Material" includes all copies, abstracts, compilations, 6 ||summaries, and any other format reproducing or capturing any of the Protected Material. 7 || Whether the Protected Material is returned or destroyed, the Receiving Party must submit 8 ||a written certification to the Producing Party (and, if not the same person or entity, to the 9 || Designating Party) by the 60 day deadline that (1) identifies (by category, where 10 || appropriate) all the Protected Material that was returned or destroyed and (2) affirms that 11 ||the Receiving Party has not retained any copies, abstracts, compilations, summaries or 12 other format reproducing or capturing any of the Protected □□□□□□□□□ 13 || Notwithstanding this provision, Counsel are entitled to retain an archival copy of all 14 pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda, 15 || correspondence, deposition and trial exhibits, expert reports, attorney work product, and 16 consultant and expert work product, even if such materials contain Protected Material. 17 || Any such archival copies that contain or constitute Protected Material remain subject to 18 Order as set forth in Section VI, supra. 19 XVI. VIOLATION 20 Any violation of this Order may be punished by appropriate measures including, 21 || without limitation, contempt proceedings and/or monetary sanctions. 22 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD. 23 54 Dated: June 7, 2024 LAW OFFICES OF DALE K. GALIPO

25 26 By: /s/ Cooper Alison-Mayne Cooper Alison-Mayne 27 Dale K. Galipo 28 Attorneys for Plaintiff PETRA MORA

1 Dated: June 7, 2024 OLIVAREZ MADRUGA LAW ORGANIZATION, LLP 2 3 By:__/s/Daniel Lee Daniel Lee 4 Attorneys for Defendant, CITY OF 5 INGLEWOOD 6 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED 7 g || Dated: June 12, 2024

10 By: 11 HON. JEAN P. ROSENBLUTH UNITED STATES MAGISTRATE JUDGE 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

1 2 EXHIBIT A 3 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 4 I,_________________________________ [print or type full name], of 5 ________________________________[print or type full address], declare under penalty of 6 perjury 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 in the 8 case of Petra Mora v. City of Inglewood, Case No. 2:24-cv-02970. I agree to comply with 9 and to be bound by all the terms of this Stipulated Protective Order and I understand and 10 acknowledge that failure to so comply could expose me to sanctions and punishment in the 11 nature of contempt. I solemnly promise that I will not disclose in any manner any 12 information or item that is subject to this Stipulated Protective Order to any person or entity 13 except in strict compliance with the provisions of this Order. I further agree to submit to the 14 jurisdiction of the United States District Court for the Central District of California for 15 enforcing the terms of this Stipulated Protective Order, even if such enforcement 16 proceedings occur after termination of this action. 17 Date:__________________________________ 18 City and State where sworn and signed:__________________________________ 19 Printed name:__________________________________ 20 Signature:______________________________________ 21 22 23 24 25 26 27 28 1 PROOF OF SERVICE > By Electronic Filing 3 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES 4 I am employed in the County of Los Angeles, State of California. I am over the age of eighteen years and am not a party to the within action. My business address is 500 South Grand 5 || Avenue - 12th Floor, Los Angeles, CA 90071. 6 On June 7, 2024, I served a true and correct copy of the foregoing document entitled: 7 STIPULATED [PROPOSED] PROTECTIVE ORDER GOVERNING g PRODUCTION OF “CONFIDENTIAL” INFORMATION 9 Notice of this filing will be sent to the following parties by operation of the Court’s electronic 10 filing system. Parties may access this filing through the Court’s system. Xx As Indicated on the following Service List, by Electronic Filing and Service Pursuant to 11 General Rule Order 10-07: I caused the document(s) listed above via the Court’s Electronic 12 Filing System which constitutes service, pursuant to General Rule Order 08-02 of the above- titled Court, upon the counsel on service the list. 13 14 Dale K. Galipo, Esq. Attorneys for Plaintiff LAW OFFICES OF DALE K. GALIPO Tel: (818) 347-3333 15 21800 Burbank Boulevard, Suite 310 [email protected] 16 Woodland Hills, CA 91367 [email protected] 17 DX] (Federal) I declare that I am employed in the office of a member of the bar of this court at whose discretion the service was made. I declare under penalty of perjury that the above is 18 true and correct. 19 || Executed on June 7, 2024, at Los Angeles, CA. te \ . 20 |! Eniko Weinberger KWL KO \O Vv whoe rg ur 41 || Printed Name Signature ,

22 23 24 25 26 27 28