1 HYDEE FELDSTEIN SOTO, City Attorney (SBN 106866) DENISE C. MILLS, Chief Deputy City Attorney (SBN 191992) 2 KATHLEEN KENEALY, Chief Assistant City Attorney (SBN 212289) CORY M. BRENTE, Senior Assistant City Attorney (SBN 115453) 3 IRVING ESTRADA, Deputy City Attorney (SBN 314785) 200 North Main Street, 6th Floor, City Hall East 4 Los Angeles, CA 90012 5 Phone No.: (213) 978-2247 | Fax No.: (213) 978-8785 Email: [email protected] 6 Attorneys for Defendants, CITY OF LOS ANGELES and LOS ANGELES POLICE 7 DEPARTMENT

8 [Additional Counsel continued on next page] 9

10 UNITED STATES DISTRICT COURT 11 CENTRAL DISTRICT OF CALIFORNIA 12

13 JOSHUA HATFIELD, an individual, CASE NO. 2:24-cv-05076-SRM-AGR 14 Hon. Serene R. Murillo; Santa Ana - Ctrm. 9B Plaintiff, Hon. Mag. Alicia G. Rosenberg; Roybal – Ctrm. 15 550

16 v.

STIPULATED PROTECTIVE ORDER 17 LOS ANGELES POLICE

18 DEPARTMENT, a public entity; CITY OF LOS ANGELES, a public entity; 19 JUSTIN FREUND, an individual;

20 JENNIFER ALVAREZ, and DOE 1 through 10, individually; 21 22 Defendants.

23

24

25 26 27 1 [Additional Counsel from previous page] 2 Christian Contreras, Esq. (SBN 330269) 3 E-Mail: [email protected] 4 Edwin S. Salguero, Esq. (SBN 344820) E-Mail: [email protected] 5 LAW OFFICES OF CHRISTIAN CONTRERAS 6 PROFESSIONAL LAW CORPORATION 360 E. 2nd St., 8th Floor 7 Los Angeles, Ca 90012 8 Telephone: (323) 435-8000

9 Humberto M. Guizar, Esq., (SBN 125769) 10 E-Mail: [email protected] LAW OFFICES OF HUMBERTO GUIZAR 11 3500 West Beverly Boulevard 12 Montebello CA 90640 Tel: (323) 725-1151; Fax.: (323) 597 0101 13

14 Attorneys for Plaintiff, JOSHUA HATFIELD

15

16 Brian Chu (SBN 161900) Serviam by Wright LLP 17 3 Corporate Park, Suite 100 18 Irvine, CA 92606 Tel.: (949) 590-4990 19 Email: [email protected] 20 Attorney for Defendant, JUSTIN FREUND 21

22 Janine K. Jeffery (SBN 112639) 23 Reily & Jeffery Inc. 24 5850 Canoga Ave., Suite 400 Woodland Hills, CA 91367 25 Tel.: (818) 350-6282 26 Email: [email protected]

27 Attorney for Defendant, JENNIFER ALVAREZ 1 1. A. PURPOSES AND LIMITATIONS 2 3 Discovery in this action is likely to involve production of confidential, 4 proprietary, or private information for which special protection from public disclosure 5 and from use for any purpose other than prosecuting this litigation may be warranted. 6 Accordingly, the parties hereby stipulate to and petition the Court to enter the following 7 Stipulated Protective Order. The parties acknowledge that this Order does not confer 8 blanket protections on all disclosures or responses to discovery and that the protection it 9 affords from public disclosure and use extends only to the limited information or items 10 that are entitled to confidential treatment under the applicable legal principles. The 11 parties further acknowledge, as set forth in Section 12.3, below, that this Stipulated 12 Protective Order does not entitle them to file confidential information under seal; Civil 13 Local Rule 79-5 sets forth the procedures that must be followed and the standards that 14 will be applied when a party seeks permission from the court to file material under seal. 15 16 B. GOOD CAUSE STATEMENT 17 18 This action is likely to involve confidential information pertaining to personnel 19 records and other materials subject to privacy protections for which special protection 20 from public disclosure and from use for any purpose other than prosecution of this 21 action is warranted. Limiting disclosure of these documents to the context of this 22 litigation as provided herein will, accordingly, further important law enforcement 23 objections and interests, including the safety of personnel and the public, as well as 24 individual privacy rights of plaintiffs, the individual defendants, and third parties. Such 25 confidential materials and information consist of, among other things, materials entitled 26 to privileges and/or protections under the following: United States Constitution, First 27 Amendment; the California Constitution, Article I, Section 1; California Penal Code §§ 1 Act of 1974,

; Health Insurance Portability and Accountability Act of 2 1996 (HIPPA); the right to privacy; decisional law relating to such provisions; and 3 information otherwise generally unavailable to the public, or which may be privileged 4 or otherwise protected from disclosure under state or federal statutes, court rules, case 5 decisions, or common law. Defendant also contends that such confidential materials and 6 information consist of materials entitled to the Official Information Privilege. 7 Confidential information with respect to the Defendant and/or its employees may 8 include but is not limited to: personnel files; internal investigative files and documents; 9 email and written correspondence records; and policies and procedures that are kept 10 from the public in the ordinary course of business, as well as other information that is 11 not generally available to the public and is subject to the Official Information Privilege 12 and other privileges. Confidential information with financial records; email and written 13 correspondence records; video footage and/or photographs of the incident; and 14 psychological and medical notes, evaluations, reports, and treatment plans. 15 Testimony taken at a deposition may be designated as Confidential by making a 16 statement to that effect on the record at the deposition. Arrangements shall be made 17 with the court reporter transcribing the deposition to separately bind such portions of 18 the transcript containing information designated as Confidential, and to label such 19 portions appropriately. Confidential photographs, video or audio footage obtained 20 through the course of discovery or otherwise may not be used for any purpose other 21 than litigating this lawsuit. The parties agree to refrain from directly or indirectly 22 disclosing or publicly disseminating confidential deposition testimony, and/or 23 photographs, video or audio footage obtained through the course of discovery or 24 otherwise, specifically including, but not limited to, dissemination via billboard 25 advertisements, print and online media organizations, or any other internet posting or 26 social media. If any party intends to use such confidential materials for any purpose 27 other than litigating this lawsuit, the party seeking public disclosure must first seek 1 In light of the nature of the claims and allegations in this case and the parties’ 2 representations that discovery in this case will involve the production of confidential 3 records, and in order to expedite the flow of information, to facilitate the prompt 4 resolution of disputes over confidentiality of discovery materials, to adequately protect 5 information the parties are entitled to keep confidential, to ensure that the parties are 6 permitted reasonable necessary uses of such material in connection with this action, to 7 address their handling of such material at the end of the litigation, and to serve the ends 8 of justice, a protective order for such information is justified in this matter. The parties 9 shall not designate any information/documents as confidential without a good faith 10 belief that such information/documents have been maintained in a confidential, non- 11 public manner, and that there is good cause or a compelling reason why it should not be 12 part of the public record of this case. 13 14 2. DEFINITIONS 15 2.1 Action: Joshua Hatfield v. City of Los Angeles, et al.; United States Central 16 District Court Case No.: 2:24-cv-05076-SRM-AGR. 17 2.2 Challenging Party: a Party or Non-Party that challenges the designation of 18 information or items under this Order. 19 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how it 20 is generated, stored or maintained) or tangible things that qualify for protection under 21 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 22 Statement. 23 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 24 support staff). 25 2.5 Designating Party: a Party or Non-Party that designates information or 26 items that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 27 2.6 Disclosure or Discovery Material: all items or information, regardless of the 1 other things, testimony, transcripts, and tangible things), that are produced or generated 2 in disclosures or responses to discovery in this matter. 3 2.7 Expert: a person with specialized knowledge or experience in a matter 4 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 5 expert witness or as a consultant in this Action. 6 2.8 House Counsel: attorneys who are employees of a party to this Action. 7 House Counsel does not include Outside Counsel of Record or any other outside 8 counsel. 9 2.9 Non-Party: any natural person, partnership, corporation, association, or 10 other legal entity not named as a Party to this action. 11 2.10 Outside Counsel of Record: attorneys who are not employees of a party to 12 this Action but are retained to represent or advise a party to this Action and have 13 appeared in this Action on behalf of that party or are affiliated with a law firm which has 14 appeared on behalf of that party, and includes support staff. 15 2.11 Party: any party to this Action, including all of its officers, directors, 16 employees, consultants, retained experts, and Outside Counsel of Record (and their 17 support staffs). 18 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 19 Discovery Material in this Action. 20 2.13 Professional Vendors: persons or entities that provide litigation support 21 services (e.g., photocopying, videotaping, translating, preparing exhibits or 22 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 23 their employees and subcontractors. 24 2.14 Protected Material: any Disclosure or Discovery Material that is designated 25 as “CONFIDENTIAL.” 26 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 27 from a Producing Party. 1 3. 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 that might reveal Protected Material. 7 Any use of Protected Material at trial shall be governed by the orders of the trial 8 judge. This Order does not govern the use of Protected Material at trial. 9 10 4. DURATION 11 Once a case proceeds to trial, any information that was designated as confidential 12 or privileged pursuant to this protective order which is published or admitted at trial, 13 becomes public and will be presumptively available to all members of the public, 14 including the press, unless compelling reasons supported by specific factual findings to 15 proceed otherwise are made to the trial judge in advance of the trial. See Kamakana v. 16 City and County of Honolulu,

(9th Cir. 2006) (distinguishing 17 “good cause” showing for sealing documents produced in discovery from “compelling 18 reasons” standard when merits-related documents are part of court record). Accordingly, 19 the terms and protections of this protective order extend beyond the commencement of 20 the trial only as to any confidential information or privileged information that was not 21 published or disclosed at trial. For all items not published or admitted at trial, the 22 confidentiality obligations imposed by this Order shall remain in effect until a 23 Designating Party agrees otherwise in writing or a court order otherwise directs. 24 25 5. DESIGNATING PROTECTED MATERIAL 26 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each 27 Party or Non-Party that designates information or items for protection under this Order 1 appropriate standards. The Designating Party must designate for protection only those 2 parts of material, documents, items, or oral or written communications that qualify so 3 that other portions of the material, documents, items, or communications for which 4 protection is not warranted are not swept unjustifiably within the ambit of this Order. 5 Mass, indiscriminate, or routinized designations are prohibited. Designations that 6 are shown to be clearly unjustified or that have been made for an improper purpose (e.g., 7 to unnecessarily encumber the case development process or to impose unnecessary 8 expenses and burdens on other parties) may expose the Designating Party to sanctions. 9 If it comes to a Designating Party’s attention that information or items that it 10 designated for protection do not qualify for protection, that Designating Party must 11 promptly notify all other Parties that it is withdrawing the inapplicable designation. 12 5.2 Manner and Timing of Designations. Except as otherwise provided in this 13 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or 14 ordered, Disclosure or Discovery Material that qualifies for protection under this Order 15 must be clearly so designated before the material is disclosed or produced. 16 Designation in conformity with this Order requires: 17 (a) for information in documentary form (e.g., paper or electronic documents, 18 but excluding transcripts of depositions or other pretrial or trial proceedings), that the 19 Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 20 “CONFIDENTIAL legend”), to each page that contains protected material. If only a 21 portion or portions of the material on a page qualifies for protection, the Producing Party 22 also must clearly identify the protected portion(s) (e.g., by making appropriate markings 23 in the margins). 24 A Party or Non-Party that makes original documents available for inspection need 25 not designate them for protection until after the inspecting Party has indicated which 26 documents it would like copied and produced. During the inspection and before the 27 designation, all of the material made available for inspection shall be deemed 1 copied and produced, the Producing Party must determine which documents, or portions 2 thereof, qualify for protection under this Order. Then, before producing the specified 3 documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page 4 that contains Protected Material. If only a portion or portions of the material on a page 5 qualifies for protection, the Producing Party also must clearly identify the protected 6 portion(s) (e.g., by making appropriate markings in the margins). 7 (b) for testimony given in depositions that the Designating Party identify the 8 Disclosure or Discovery Material on the record, before the close of the deposition all 9 protected testimony. 10 (c) for information produced in some form other than documentary and for any 11 other tangible items, that the Producing Party affix in a prominent place on the exterior 12 of the container or containers in which the information is stored the legend 13 “CONFIDENTIAL.” If only a portion or portions of the information warrants protection, 14 the Producing Party, to the extent practicable, shall identify the protected portion(s). 15 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure 16 to designate qualified information or items does not, standing alone, waive the 17 Designating Party’s right to secure protection under this Order for such material. Upon 18 timely correction of a designation, the Receiving Party must make reasonable efforts to 19 assure that the material is treated in accordance with the provisions of this Order. 20 21 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 22 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation 23 of confidentiality at any time that is consistent with the Court’s Scheduling Order. 24 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 25 resolution process under Local Rule 37.1 et seq. 26 6.3 The burden of persuasion in any such challenge proceeding shall be on the 27 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., 1 Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn 2 the confidentiality designation, all parties shall continue to afford the material in 3 question the level of protection to which it is entitled under the Producing Party’s 4 designation until the Court rules on the challenge. 5 6 7. ACCESS TO AND USE OF PROTECTED MATERIAL 7 7.1 Basic Principles. A Receiving Party may use Protected Material that is 8 disclosed or produced by another Party or by a Non-Party in connection with this Action 9 only for prosecuting, defending, or attempting to settle this Action. Such Protected 10 Material may be disclosed only to the categories of persons and under the conditions 11 described in this Order. When the Action has been terminated, a Receiving Party must 12 comply with the provisions of section 13 below (FINAL DISPOSITION). 13 Protected Material must be stored and maintained by a Receiving Party at a location and 14 in a secure manner that ensures that access is limited to the persons authorized under this 15 Order. 16 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise 17 ordered by the court or permitted in writing by the Designating Party, a Receiving Party 18 may disclose any information or item designated “CONFIDENTIAL” only to: 19 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as 20 employees of said Outside Counsel of Record to whom it is reasonably necessary to 21 disclose the information for this Action; 22 (b) the officers, directors, and employees (including House Counsel) of the 23 Receiving Party to whom disclosure is reasonably necessary for this Action; 24 (c) Experts (as defined in this Order) of the Receiving Party to whom 25 disclosure is reasonably 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; 1 (f) professional jury or trial consultants, mock jurors, and Professional Vendors 2 to whom disclosure is reasonably necessary for this Action and who have signed the 3 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 4 (g) the author or recipient of a document containing the information or a 5 custodian or other person who otherwise possessed or knew the information; 6 (h) during their depositions, witnesses, and attorneys for witnesses, in the 7 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 8 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will not 9 be permitted to keep any confidential information unless they sign the 10 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed 11 by the Designating Party or ordered by the court. Pages of transcribed deposition 12 testimony or exhibits to depositions that reveal Protected Material may be separately 13 bound by the court reporter and may not be disclosed to anyone except as permitted 14 under this Stipulated Protective Order; and 15 (i) any mediator or settlement officer, and their supporting personnel, mutually 16 agreed upon by any of the parties engaged in settlement discussions. 17 18 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 19 OTHER LITIGATION 20 If a Party is served with a subpoena or a court order issued in other litigation that 21 compels disclosure of any information or items designated in this Action as 22 “CONFIDENTIAL,” that Party must: 23 (a) promptly notify in writing the Designating Party. Such notification shall 24 include a copy of the subpoena or court order; 25 (b) promptly notify in writing the party who caused the subpoena or order to 26 issue in the other litigation that some or all of the material covered by the subpoena or 27 order is subject to this Protective Order. Such notification shall include a copy of this 1 (c) cooperate with respect to all reasonable procedures sought to be pursued by 2 the Designating Party whose Protected Material may be affected. 3 If the Designating Party timely seeks a protective order, the Party served with the 4 subpoena or court order shall not produce any information designated in this action as 5 “CONFIDENTIAL” before a determination by the court from which the subpoena or 6 order issued, unless the Party has obtained the Designating Party’s permission. The 7 Designating Party shall bear the burden and expense of seeking protection in that court 8 of its confidential material and nothing in these provisions should be construed as 9 authorizing or encouraging a Receiving Party in this Action to disobey a lawful directive 10 from another court. 11 12 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO 13 BE PRODUCED IN THIS LITIGATION 14 (a) The terms of this Order are applicable to information produced by a Non- 15 Party in this Action and designated as “CONFIDENTIAL.” Such information produced 16 by Non-Parties in connection with this litigation is protected by the remedies and relief 17 provided by this Order. Nothing in these provisions should be construed as prohibiting a 18 Non-Party from seeking additional protections. 19 (b) In the event that a Party is required, by a valid discovery request, to produce 20 a Non-Party’s confidential information in its possession, and the Party is subject to an 21 agreement with the Non-Party not to produce the Non-Party’s confidential information, 22 then the Party shall: 23 (1) promptly notify in writing the Requesting Party and the Non-Party 24 that some or all of the information requested is subject to a confidentiality agreement 25 with a Non-Party; 26 (2) promptly provide the Non-Party with a copy of the Stipulated 27 Protective Order in this Action, the relevant discovery request(s), and a reasonably 1 (3) make the information requested available for inspection by the Non- 2 Party, if requested. 3 (c) If the Non-Party fails to seek a protective order from this court within 14 4 days of receiving the notice and accompanying information, the Receiving Party may 5 produce the Non-Party’s confidential information responsive to the discovery request. If 6 the Non-Party timely seeks a protective order, the Receiving Party shall not produce any 7 information in its possession or control that is subject to the confidentiality agreement 8 with the Non-Party before a determination by the court. Absent a court order to the 9 contrary, the Non-Party shall bear the burden and expense of seeking protection in this 10 court of its Protected Material. 11 12 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 13 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 14 Protected Material to any person or in any circumstance not authorized under this 15 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 16 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 17 all unauthorized copies of the Protected Material, (c) inform the person or persons to 18 whom unauthorized disclosures were made of all the terms of this Order, and (d) request 19 such person or persons to execute the “Acknowledgment and Agreement to Be Bound” 20 that is attached hereto as Exhibit A. 21 22 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 23 PROTECTED MATERIAL 24 When a Producing Party gives notice to Receiving Parties that certain 25 inadvertently produced material is subject to a claim of privilege or other protection, the 26 obligations of the Receiving Parties are those set forth in Federal Rule of Civil 27 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 1 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 2 parties reach an agreement on the effect of disclosure of a communication or information 3 covered by the attorney-client privilege or work product protection, the parties may 4 incorporate their agreement in the stipulated protective order submitted to the court. 5 6 12. MISCELLANEOUS 7 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 8 person to seek its modification by the Court in the future. 9 12.2 Right to Assert Other Objections. By stipulating to the entry of this 10 Protective Order no Party waives any right it otherwise would have to object to 11 disclosing or producing any information or item on any ground not addressed in this 12 Stipulated Protective Order. Similarly, no Party waives any right to object on any ground 13 to use in evidence of any of the material covered by this Protective Order. 14 12.3 Filing Protected Material. A Party that seeks to file under seal any Protected 15 Material must comply with Civil Local Rule 79-5. Protected Material may only be filed 16 under seal pursuant to a court order authorizing the sealing of the specific Protected 17 Material at issue. If a Party's request to file Protected Material under seal is denied by 18 the court, then the Receiving Party may file the information in the public record unless 19 otherwise instructed by the court. 20 21 13. FINAL DISPOSITION 22 After the final disposition of this Action, as defined in paragraph 4, within 60 days 23 of a written request by the Designating Party, each Receiving Party must return all 24 Protected Material to the Producing Party or destroy such material. As used in this 25 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 26 summaries, and any other format reproducing or capturing any of the Protected Material. 27 Whether the Protected Material is returned or destroyed, the Receiving Party must 1 entity, to the Designating Party) by the 60 day deadline that (1) identifies (by category, 2 where appropriate) all the Protected Material that was returned or destroyed and 3 (2)affirms that the Receiving Party has not retained any copies, abstracts, compilations, 4 summaries or any other format reproducing or capturing any of the Protected Material. 5 Notwithstanding this provision, Counsel are entitled to retain an archival copy of all 6 pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda, 7 correspondence, deposition and trial exhibits, expert reports, attorney work product, and 8 consultant and expert work product, even if such materials contain Protected Material. 9 Any such archival copies that contain or constitute Protected Material remain subject to 10 this Protective Order as set forth in Section 4 (DURATION). 11 12 14. Any violation of this Order may be punished by any and all appropriate measures 13 including, without limitation, contempt proceedings and/or monetary sanctions. 14 15 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 16 17 DATED: April 2, 2025 LAW OFFICES OF HUMBERTO GUIZAR

18 By: /s/ 19 Humberto Guizar 20 Attorney for Plaintiff, JOSHUA HATFIELD

21 DATED: April 2, 2025 LAW OFFICES OF CHRISTIAN 22 CONTRERAS 23 A PROFESSIONAL LAW CORPORATION

24 By: /s/ 25 Christian Contreras, Esq. Attorney for Plaintiff, JOSHUA HATFIELD 26 / / / 27 1 || DATED: April 2, 2025 HYDEE FELDSTEIN SOTO, City Attomey 5 CORY M. BRENTE, Senior Asst. City Attorney 3 By: Lele 4 IRVING ESTRADA, Deputy City Atty.’ Attorneys for Defendants, CITY OF LOS 5 ANGELES and LOS ANGELES POLICE 6 DEPARTMENT 7 g DATED: April 2, 2025 REILY & JEFFERY, INC ? By: __/s/ 10 Janine K. Jeffery, Esq. Attorney for Defendant, JENNIFER ALVAREZ 12 13 DATED: April 2, 2025 SERVIAM by WRIGHT LLC 14 15 By: __/s/ 16 Brian T. Chu, Esq. Attorney for Defendant, JUSTIN FREUND 17 18 19 |} FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 20 21 |} DATED: _ April 14, 2025 HONORABLE ALICIA G. ROSENBERG United States Magistrate Judge 23 24 25 26 ' Pursuant to L.R. 5-4.3.4(a)(2)(i), I hereby attest that all signatories listed, and on 27 || whose behalf the filing is submitted, concur in this filing’s content and have authorized 28 || this filing.

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 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 on 8 [date] in the case of [insert formal name of the case and the 9 number and initials assigned to it by the court]. I agree to comply with and to be 10 bound by all the terms of this Stipulated Protective Order and I understand and 11 acknowledge that failure to so comply could expose me to sanctions and punishment in 12 the nature of contempt. I solemnly promise that I will not disclose in any manner any 13 information or item that is subject to this Stipulated Protective Order to any person or 14 entity except in strict compliance with the provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District Court for the 16 Central District of California for the purpose of enforcing the terms of this Stipulated 17 Protective Order, even if such enforcement proceedings occur after termination of this 18 action. I hereby appoint [print or type full 19 name] of [print or type full address and 20 telephone number] as my California agent for service of process in connection with this 21 action or any proceedings related to enforcement of this Stipulated Protective Order. 22 Date: 23 City and State where sworn and signed: 24 25 Printed name: 26 27 Signature: