1 || Eugene P. Ramirez (State Bar No. 134865) eugene, [email protected] 2 || Kayleigh Andersen (State Bar No. 306442) kayleigh [email protected] 3 || David Fleck (State Bar No. 192912) NOTE: CHANGES MADE BY THE COURT [email protected] 4||MANNING & KASS ELLROD, RAMIREZ, TRESTER LLP 5||801 S. Figueroa St, 15" Floor Los Angeles, California 90017-3012 6 || Telephone: Gb) 624-6900 Facsimile: (213) 624-6999 7 Attorneys for Defendants, COUNTY OF 8 RIVERSIDE, RIVERSIDE COUNTY SHERIFF’S DEPARTMENT, SHERIFF 9 || CHAD BIANCO, EDWARD DELGADO, JAMES KRACHMER, and VICTORIA 10 || VARISCO-FLORES 2 11 UNITED STATES DISTRICT COURT 2 CENTRAL DISTRICT OF CALIFORNIA, EASTERN DIVISION © =z 13 14 || ESTATE OF DAMON BEITZ; LISA Case No. 5:24-cv-02084-SSS-JPR <x PERRY, individually and as successor = 15 || 1n interest to DAMON BEITZ, District Judge. Sunshine Suzanne Sykes Magistrate Judge, Jean P. Rosenbluth 16 Plaintiffs, 17 V. STIPULATED PROTECTIVE ORDER 18 || RIVERSIDE POLICE DEPARTMENT, a public entity; CITY OF RIVERSIDE, 19|\a public entity: RIVERSIDE COUNTY SHERIFF’S DEPARTMENT, a public 20 || entity; COUNTY OF RIVERSIDE, a public entity; SHERIFF CHAD 21 || BIANCO, an individual; EDWARD DELGADO, individually; JAMES 22 || KRACHMER, individually; Filed Dated; 09/27/2024 VICTORIA VARISCO-FLORES, Trial Date: 03/09/2026 23 || individually; and DOES 1 through 20, inclusive, 24 Defendants. 25 26/1. INTRODUCTION 27 A. PURPOSES AND LIMITATIONS 28 Discovery in this action is likely to involve production of confidential,

1 || proprietary, or private information for which special protection from public disclosure 2 || and from use for any purpose other than prosecuting this litigation may be warranted. 3 || Accordingly, the parties hereby stipulate to and petition the Court to enter the 4 || following Stipulated Protective Order. The parties acknowledge that this Order does 5 ||not confer blanket protections on all disclosures or responses to discovery and that 6 || the protection it affords from public disclosure and use extends only to the limited 7 ||information or items that are entitled to confidential treatment under the applicable 8 || legal principles. The parties further acknowledge, as set forth in Section 12.3, below, 9||that this Stipulated Protective Order does not entitle them to file confidential 10 || information under seal; Civil Local Rule 79-5 sets forth the procedures that must be 2 11 || followed and the standards that will be applied when a party seeks permission from x 12 || the court to file material under seal. 13 B. GOOD CAUSE STATEMENT Ss 14 This action is likely to involve medical records, sensitive and confidential 15 ||documents related to police reporting and practices, documents containing private 16 || information from third parties, police investigation procedures and tactics, and other 17|| confidential and private information for which special protection from public 18 || disclosure and from use for any purpose other than prosecution of this action is 19 || warranted. Such confidential and proprietary materials and information may consist ||of, among other things, confidential personal information of non-parties, private 21||medical and autopsy records, internal police reviews and procedures, and other 22 || confidential and sensitive information otherwise generally unavailable to the public, 23 ||}or which may be privileged or otherwise protected from disclosure under state or 24 || federal statutes, court rules, case decisions, or common law. Defendants contend that 25 ||there is good cause for a protective order to maintain the confidentiality of peace 26 || officer personnel records. They emphasize that releasing these records, which include ||internal analyses and legal communications, could hinder law enforcement 28 || investigations.

1 Accordingly, to expedite the flow of information, to facilitate the prompt 2 ||resolution of disputes over confidentiality of discovery materials, to adequately 3 || protect information the parties are entitled to keep confidential, to ensure that the 4 || parties are permitted reasonable necessary uses of such material in preparation for and 5 ||in the conduct of trial, to address their handling at the end of the litigation, and serve 6 || the ends of justice, a protective order for such information is justified in this matter. 7 || It is the intent of the parties that information will not be designated as confidential for 8 || tactical reasons and that nothing be so designated without a good faith belief that it 9 ||has been maintained in a confidential, non-public manner, and there is good cause 10 || why it should not be part of the public record of this case. 11/2. DEFINITIONS x 12 2.1 Action: this pending federal lawsuit. 13 2.2 Challenging Party: a Party or Non-Party that challenges the designation of Ss 14 || information or items under this Order. 15 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how 16||it 1s generated, stored or maintained) or tangible things that qualify for protection ||}under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 18 || Cause Statement. 19 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 20 || support staff). 21 2.5 Designating Party: a Party or Non-Party that designates information or 22 ||items that it produces in disclosures or in responses to discovery as 23 || “CONFIDENTIAL.” 24 2.6 Disclosure or Discovery Material: all items or information, regardless of 25 ||the medium or manner in which it is generated, stored, or maintained (including, 26 || among other things, testimony, transcripts, and tangible things), that are produced or 27 || generated in disclosures or responses to discovery in this matter. 28 2.7 Expert: a person with specialized knowledge or experience in a matter

1 || pertinent to the litigation who has been retained by a Party or its counsel to serve as 2 || an expert witness or as a consultant in this Action. 3 2.8 House Counsel: attorneys who are employees of a party to this Action. 4 ||House Counsel does not include Outside Counsel of Record or any other outside 5 || counsel. 6 2.9 Non-Party: any natural person, partnership, corporation, association, or 7 || other legal entity not named as a Party to this action. 8 2.10 Outside Counsel of Record: attorneys who are not employees of a party to 9 ||this Action but are retained to represent or advise a party to this Action and have 10 || appeared in this Action on behalf of that party or are affiliated with a law firm which 2 11 || has appeared on behalf of that party, and includes support staff. 12 2.11 Party: any party to this Action, including all of its officers, directors, 13 employees, consultants, retained experts, and Outside Counsel of Record (and their S$ 14 || support staffs). 15 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 16 || Discovery Material in this Action. 17 2.13 Professional Vendors: persons or entities that provide litigation support services (e.g., photocopying, videotaping, translating, preparing exhibits or 19 || demonstrations, and organizing, storing, or retrieving data in any form or medium) 20 || and their employees and subcontractors. 21 2.14 Protected Material: any Disclosure or Discovery Material that is 22 || designated as “CONFIDENTIAL.” 23 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 24 || from a Producing Party. 25 ||3. SCOPE 26 The protections conferred by this Stipulation and Order cover not only 27 || Protected Material (as defined above) but also any information copied or extracted 28 || from Protected Material; all copies, excerpts, summaries, or compilations of Protected

1 || Material; and any testimony, conversations, or presentations by Parties or their 2 || Counsel that might reveal Protected Material. 3 Any use of Protected Material at trial will be governed by the orders of the 4 || trial judge. This Order does not govern the use of Protected Material at trial. 5/14. DURATION 6 Once a case proceeds to trial, all of the information that was designated as 7 ||confidential or maintained pursuant to this protective order used or introduced as 8 || an exhibit at trial becomes public and will be presumptively available to all member 9 || of the public, including the press, unless compelling reasons supported by specific 10 || factual findings to proceed otherwise are made to the trial judge in advance of the 2 11 || trial. See Kamakana v. City and County of Honolulu,

(9° 2 Cir. 2006) (distinguishing “good cause” showing for sealing documents produced in 13 || discovery from “compelling reasons” standard when merits-related documents are S$ 14 || part of court record). Accordingly, the terms of this protective order do not extend 15 || beyond the commencement of the trial. 16||5. DESIGNATION OF PROTECTED MATERIAL 17 5.1. Each Party or non-party that designates information or items for 18 || protection under this Stipulation and its associated Order must take care to limit any 19 || such designation to specific material that qualifies under the appropriate standards. A 20 || Designating Party must take care to designate for protection only those parts of 21 || material, documents, items, or oral or written communications that qualify — so that 22||other portions of the material, documents, items or communications for which 23 || protection is not warranted are not swept unjustifiably within the ambit of this Order. 24 Mass, indiscriminate, or routine designations are prohibited. Designations that 25 || are shown to be clearly unjustified, or that have been made for an improper purpose 26 || (e.g., to unnecessarily encumber or retard the case development process, or to impose 27 || unnecessary expenses and burdens on other parties), expose the Designating Party to 28 || sanctions.

1 If it comes to a Designating Party’s attention that information or items that it 2 || designated for protection do not qualify for protection, that Designating Party must 3 || promptly notify all other Parties that it is withdrawing the inapplicable designation. 4 5.2. Except as otherwise provided in this Order, or as otherwise stipulated or 5 □□ ordered, material that qualifies for protection under this Order must be clearly so 6 || designated before the material is disclosed or produced. 7 Designation in conformity with this Order requires the following: 8 (a) for information in documentary form (apart from transcripts of 9 || depositions or other pretrial or trial proceedings, and regardless of whether produced 10|}in hardcopy or electronic form), that the Producing Party affix the legend 2 11 || “CONFIDENTIAL” to each page that contains Protected Material. If only a portion x 12 || or portions of the material on a page qualifies for protection, the Producing Party also 13 || must clearly identify the protected portion(s) (e.g., by making appropriate markings S$ 14 || in the margins). 15 A Party or Non-Party that makes original documents or materials available for 16 || inspection need not designate them for protection until after the inspecting Party has 17 || indicated which material it would like copied and produced. During the inspection 18 || and before the designation, all of the material made available for inspection shall be 19 || deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents 20 || 1t wants copied and produced, the Producing Party must determine which documents, 21 || or portions thereof, qualify for protection under this Order. Then, before producing 22 ||the specified documents, the Producing Party must affix the “CONFIDENTIAL” 23 || legend to each page that contains Protected Material. If only a portion or portions of 24 || the material on a page qualifies for protection, the Producing Party also must clearly 25 |lidentify the protected portion(s) (e.g., by making appropriate markings in the 26 || margins). 27 (b) for testimony given in depositions, the Designating Party must identify 28 || the Disclosure or Discovery Material on the record, before the close of the deposition

1 || all protected testimony. 2 (c) for information produced in some form other than documentary, and for 3 || any other tangible items, the Producing Party must affix in a prominent place on the 4 || exterior of the container or containers in which the information or item is stored the 5 ||legend “CONFIDENTIAL.” If only portions of the information or item warrant 6 || protection, the Producing Party, to the extent practicable, shall identify the protected 7 || portions, specifying the material as “CONFIDENTIAL.” 8 5.3. If timely corrected, an inadvertent failure to designate qualified 9 || information or items does not, standing alone, waive the Designating Party’s right to 10||secure protection under this Order for that material. On timely correction of a 2 11 || designation, the Receiving Party must make reasonable efforts to assure that the x 12 || material is treated in accordance with the provisions of this Order. 13 || 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS. S$ 14 6.1. Any Party or Non-Party may challenge a designation of confidentiality 15 || at any time that is consistent with the Court's Scheduling Order. 16 6.2. The Challenging Party shall initiate the dispute resolution process under 17 || Local Rule 37.1 et seq. 18 6.3. The burden of persuasion in any such challenge proceeding shall be on 19 || the Designating Party. Frivolous challenges, and those made for an improper purpose 20 || (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 21 || expose the Challenging Party to sanctions. Unless the Designating Party has waived 22 || or withdrawn the confidentiality designation, all parties shall continue to afford the 23 || material in question the level of protection to which it is entitled under the Producing 24 || Party’s designation until the Court rules on the challenge. 25||7. ACCESS TO AND USE OF PROTECTED MATERIAL. 26 7.1. A Receiving Party may use Protected Material that is disclosed or 27 || produced by another Party or by a non-party in connection with this case only for 28 || preparing, prosecuting, defending, or attempting to settle this litigation — up to and

1 |jincluding final disposition of the above-entitled action — and not for any other 2 || purpose, including any other litigation or dispute outside the scope of this action. 3 || Such Protected Material may be disclosed only to the categories of persons and under 4 || the conditions described in this Stipulation and its associated Order. When the above 5 |/entitled litigation has been terminated, a Receiving Party must comply with the 6 || provisions of section 13, below (FINAL DISPOSITION). 7 Protected Material must be stored and maintained by a Receiving Party at a 8 || location and in a secure manner that ensures that access is limited to the persons 9 || authorized under this Stipulation and its Order. 10 7.2. Unless otherwise ordered by the Court or permitted in writing by the 2 11 || Designating Party, a Receiving Party may disclose any information or item designated x 12 || CONFIDENTIAL only to the following people: 13 (a) the Receiving Party’s Outside Counsel of record in this action, as well 14||}as employees of such Counsel to whom it is reasonably necessary to disclose the 15 || information for this Action; 16 (b) the officers, directors, and employees (including House Counsel) of the 17 || Receiving Party to whom disclosure is reasonably necessary for this litigation; 18 (c) Experts (as defined in this Stipulation and Order) of the Receiving Party 19 ||to whom disclosure is reasonably necessary for this litigation and who have signed 20 || the "Acknowledgement and Agreement to Be Bound" (Exhibit A); 21 (d) the Court and its personnel; 22 (e) court reporters and their staff; 23 (f) professional jury or trial consultants, mock jurors, and Professional 24 || Vendors to whom disclosure is reasonably necessary for this Action and who have 25 || signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 26 (g) the author or recipient of a document containing the information or a 27 || custodian or other person who otherwise possessed or knew the information; 28 (h) during their depositions, witnesses and attorneys for witnesses to whom

1 || disclosure is reasonably necessary, provided that the deposing party requests that the 2 || witness sign the form attached as Exhibit A hereto and the witnesses will not be 3 permitted to keep any confidential information unless they sign the form, unless 4|/otherwise agreed by the Designating Party or ordered by the Court. Pages of 5 ||transcribed deposition testimony or exhibits to depositions that reveal Protected 6 || Material may be separately bound by the court reporter and may not be disclosed to 7 || anyone except as permitted under this Order; and 8 (i) any mediator or settlement officer, and their supporting personnel, 9||mutually agreed on by any of the Parties engaged in settlement discussions or 10 || appointed by the Court. PROTECEE ny SIAERMcafIBNOPMAED OF ORDERED 1 13 If a Party is served with a subpoena or a court order issued in other litigation 14||that compels disclosure of any information or items designated in this action as 15 || “CONFIDENTIAL,” that Party must: 16 (a) promptly notify in writing the Designating Party, preferably (though not 17 || necessarily) by facsimile or electronic mail. Such notification shall include a copy of 18 || the subpoena or court order at issue unless prohibited by law; 19 (b) promptly notify in writing the party who caused the subpoena or order to 20 || issue in the other litigation that some or all of the material covered by the subpoena 21 || or order is subject to this Stipulation and its Protective Order. Such notification shall 22 || include a copy of this Stipulation and its Protective Order; and 23 (c) cooperate with respect to all reasonable procedures sought to be pursued 24 || by all sides in any such situation, while adhering to the terms of this Stipulation and 25 its Order. 26 If the Designating Party timely seeks a protective order, the Party served with 27 || the subpoena or court order shall not produce any information designated in this action 28 ||as “CONFIDENTIAL” before a determination by the relevant court unless the Party

1 || has obtained the Designating Party’s permission. The Designating Party shall bear the 2 || burden and expense of seeking protection in that court of its confidential material - 3 || and nothing in these provisions should be construed as authorizing or encouraging a 4 || Receiving Party in this action to disobey a lawful directive from another court. 519. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS LITIGATION ° (a) The terms of this Order are applicable to information produced by a Non- ’ Party in this Action and designated as “CONFIDENTIAL.” Such information produced by Non-Parties in connection with this litigation is protected by the ° remedies and relief provided by this Order. Nothing in these provisions should be construed as prohibiting a Non-Party from seeking additional protections. <= 1D (b) In the event that a Party is required, by a valid discovery request, to © produce a Non-Party’s confidential information in its possession, and the Party is subject to an agreement with the Non-Party not to produce the Non-Party’s < confidential information, then the Party must: = (1) promptly notify in writing the Requesting Party and the Nonparty that some or all of the information requested is subject to a confidentiality agreement with a Nonparty; (2) promptly provide the Nonparty with a copy of this Order, the

50 relevant discovery request(s), and a _ reasonably specific description of the information requested; and (3) make the information requested available for inspection by the Non-Party, if requested. (c) Ifthe Non-Party fails to seek a protective order from this court within 21 days of receiving the notice and accompanying information, the Receiving Party may > produce the Non-Party’s confidential information responsive to the discovery request. *6 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce any information in its possession or control that is subject to the confidentiality

1 □□ agreement with the Non-Party before a determination by the court. Absent a court 2 ||order to the contrary, the Non-Party shall bear the burden and expense of seeking 3 || protection in this court of its Protected Material. 4|}10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL. 5 If a Receiving Party learns that by inadvertence or otherwise, it has disclosed 6 || Protected Material to any person or in any circumstance not authorized under this 7 || Order, the Receiving Party must immediately notify the Designating Party in writing 8 || of the unauthorized disclosures, use its best efforts to retrieve all unauthorized copies 9 ||of the Protected Material, inform the person or people to whom unauthorized 10 || disclosures were made of the terms of this Order, and ask that person or people to 2 11 || execute the “Acknowledgment and Agreement to Be Bound” that is attached hereto |Ias Exhibit A. S 13/}11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE Zz 4 PROTECTED MATERIAL.

15 When a Producing Party gives notice to Receiving Parties that certain 16 || inadvertently produced material is subject to a claim of privilege or other protection, 17||the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 18 || Procedure 26(b)(5)(B). 19/}12. MISCELLANEOUS. 20 12.1 Nothing in this Order abridges the right of any person to seek its 21 || modification by the Court in the future. 22 12.2 By stipulating to the entry of this Protective Order no Party waives any 23 || right it otherwise would have to object to disclosing or producing any information or 24 || item on any ground not addressed in this Stipulated Protective Order. Similarly, no 25 || Party waives any right to object on any ground to use in evidence of any of the 26 || material covered by this Protective Order. 27 12.3 A Party that seeks to file under seal any Protected Material must comply 28 || with Civil Local Rule 79-5. Protected Material may only be filed under seal pursuant

1 || to a court order authorizing the sealing of the specific Protected Material at issue. Ifa 2 || Party's request to file Protected Material under seal is denied by the court, then the 3 ||Receiving Party may file the information in the public record unless otherwise 4 || 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 this 9 || subdivision, “all Protected Material” includes all copies, abstracts, compilations, 10|}summaries, and any other format reproducing or capturing any of the Protected 2 11 || Material. Whether the Protected Material is returned or destroyed, the Receiving Party x 12 || must submit a written certification to the Producing Party (and, if not the same person 13 || or entity, to the Designating Party) by the 60-day deadline that identifies (by category, S$ || when appropriate) all the Protected Material that was returned or destroyed and 15 || affirms that the Receiving Party has not retained any copies, abstracts, compilations, 16||}summaries, or any other format reproducing or capturing any of the Protected 17 || Material. Notwithstanding this provision, Counsel are entitled to retain an archival 18 || copy of all pleadings; motion papers; trial, deposition, and hearing transcripts; legal 19 || memoranda; correspondence; deposition and trial exhibits; expert reports; attorney 20 || work product; and consultant and expert work product even if such materials contain 21 || Protected Material. Any such archival copies that contain or constitute Protected 22 || Material remain subject to this Order as set forth in Section 4 (DURATION). 23|}14. SANCTIONS. 24 Any willful violation of this Order may be punished by civil or criminal 25 || contempt, financial or evidentiary sanctions, reference to disciplinary authorities, or 26 || other appropriate action at the discretion of the Court. 27 28 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

1|}DATED: March 28, 2025 MANNING & KASS > ELLROD, RAMIREZ, TRESTER LLP 3 4 . . By: /s/ Kayleigh A. Andersen 5 Eugene P. Ramirez 6 Kayleigh Andersen David Fleck 7 Attorneys for Defendants, COUNTY OF 3 RIVERSIDE, et al.

9 DATED: March 28, 2025 OFFICE OF THE CITY ATTORNEY — 10 CITY OF RIVERSIDE WwW < 11 12 © By: /s/ Jessica E. Rico-Zuber > Jessica E. Rico-Zuber z 14 Attorneys for Defendants, CITY OF < > 15 RIVERSIDE, et al. 16 DATED: March 28, 2025 LAW OFFICES OF CHRISTIAN 12 CONTRERAS

19 20 By: /s/ Christian Contreras 21 Christian Contreras 9 Attorneys for Plaintiffs 23 24 25 26 27 28

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, [print or type full 4 ||name], of [print or type full address], declare 5 || under penalty of perjury that I have read in its entirety and understand the Stipulated 6 || Protective Order that was issued by the United States District Court for the Central 7 || District of California on [date] in the case of ESTATE OF DAMON 8 || BEITZ, et al. v. RIVERSIDE POLICE DEPARTMENT, et al., Case No. 5:24- 9 || cv-02084-SSS-JPR. I agree to comply with and to be bound by all the terms of this 10 || Stipulated Protective Order and I understand and acknowledge that failure to so 2 11 || comply could expose me to sanctions and punishment in the nature of contempt. I x 12 || solemnly promise that I will not disclose in any manner any information or item that 13 || is subject to this Stipulated Protective Order to any person or entity except in strict 14 || compliance with the provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District Court 16 || for the Central District of California for the purpose of enforcing the terms of this 17 || Stipulated Protective Order, even if such enforcement proceedings occur after 18 || termination of this action. I hereby appoint [print 19 || or type full name] of [print or type 20 || full address and telephone number] as my California agent for service of process 21 ||in connection with this action or any proceedings related to enforcement of this 22 || Stipulated Protective Order. 23 || Date: 24 || City and State where sworn and signed: 25 || Printed name: 26 || Signature: 27 28

1 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 2 3 || DATED: 4/2/2025 4 ° fe RreMutlr 6 7 || Hon. JEAN P. ROSENBLUTH United States Magistrate Judge 10 < 11 — 12 2 13 S 14 Ss 16

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