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7 UNITED STATES DISTRICT COURT 8 CENTRAL DISTRICT OF CALIFORNIA 9

10 TERRENCE JOHNSON, Case No.: 5:25-cv-00738-RGK (SHKx) 11 12 STIPULATED PROTECTIVE ORDER Plaintiff, 13 Action Filed: March 21, 2025 14 Pretrial Conference: XXX v. Trial Date: XXX 15

16 Assigned to: COUNTY OF RIVERSIDE; and DOE Hon. R. Gary Klausner 17 DEPUTIES 1 – 10, U.S. District Court Judge 18 Courtroom 850

19 Defendants. 20 21 22 1. A. PURPOSES AND LIMITATIONS 23 Discovery in this action is likely to involve production of confidential, 24 proprietary, or private information for which special protection from public 25 disclosure and from use for any purpose other than prosecuting this litigation may be 26 warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter the 27 following Stipulated Protective Order. The parties acknowledge that this file 28 confidential information under seal; Civil Local Rule 79-5 sets forth the procedures 1 that must be followed and the standards that will be applied when a party seeks 2 permission from the court to file material under seal Order does not confer blanket 3 protections on all disclosures or responses to discovery and that the protection it 4 affords from public disclosure and use extends only to the limited information or items 5 that are entitled to confidential treatment under the applicable legal principles. The 6 parties further acknowledge, as set forth in Section 12.3, below, that this Stipulated 7 Protective Order does not entitle them to file confidential information under seal; 8 Civil Local Rule 79-5 sets forth the procedures that must be followed and the 9 standards that will be applied when a party seeks permission from the court to file 10 material under seal. 11 12 B. GOOD CAUSE STATEMENT 13 In light of the nature of the claims and allegations in this case and the parties' 14 representations that discovery in this case will involve the production of confidential 15 records (including but not limited to employment/personnel records and information of 16 individually named Defendants and/or other employees of the County). In addition, 17 Defendants anticipate conducting discovery as to any potential criminal history of 18 Plaintiff and law enforcement interactions, which may include disclosure of sealed , 19 confidential or otherwise sensitive information. In order to expedite the flow of 20 information, to facilitate the prompt resolution of disputes over confidentiality of 21 discovery materials, to adequately protect information the parties are entitled to keep 22 confidential, to ensure that the parties are permitted reasonable necessary uses of such 23 material in connection with this action, to address their handling of such material at the 24 end of the litigation, and to serve the ends of justice, a protective order for such 25 information is justified in this matter. The parties shall not designate any 26 information/documents as confidential without a good faith belief that such 27 information/documents have been maintained in a confidential, non-public manner, and 28 that there is good cause or a compelling reason why it should not be part of the public 1 record of this case. 2 2. DEFINITIONS 3 2.1 Action: Terrence Johnson v, County of Riverside, et al., USDC Case 4 Number 5:25-cv-00738-RGK (SHKx). 5 2.2 Challenging Party: a Party or Non-Party that challenges the designation of 6 information or items under this Order. 7 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how 8 it is generated, stored or maintained) or tangible things that qualify for protection 9 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 10 Statement. 11 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 12 support staff). 13 2.5 Designating Party: a Party or Non-Party that designates information or 14 items that it produces in disclosures or in responses to discovery as 15 “CONFIDENTIAL.” 16 2.6 Disclosure or Discovery Material: all items or information, regardless 17 of the medium or manner in which it is generated, stored, or maintained (including, 18 among other things, testimony, transcripts, and tangible things), that are produced or 19 generated in disclosures or responses to discovery in this matter. 20 2.7 Expert: a person with specialized knowledge or experience in a matter 21 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 22 expert witness or as a consultant in this Action. 23 2.8 House Counsel: attorneys who are employees of a party to this Action. 24 House Counsel does not include Outside Counsel of Record or any other outside 25 counsel. 26 2.9 Non-Party: any natural person, partnership, corporation, association, or 27 other legal entity not named as a Party to this action. 28 2.10 Outside Counsel of Record: attorneys who are not employees of a party 1 to this Action but are retained to represent or advise a party to this Action and have 2 appeared in this Action on behalf of that party or are affiliated with a law firm which has 3 appeared on behalf of that party, and includes support staff. 4 2.11 Party: any party to this Action, including all of its officers, directors, 5 employees, consultants, retained experts, and Outside Counsel of Record (and their 6 support staffs). 7 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 8 Discovery Material in this Action. 9 2.13 Professional Vendors: persons or entities that provide litigation support 10 services (e.g., photocopying, videotaping, translating, preparing exhibits or 11 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 12 their employees and subcontractors. 13 2.14 Protected Material: any Disclosure or Discovery Material that is 14 designated as “CONFIDENTIAL.” 15 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 16 from a Producing Party. 17 18 3. SCOPE 19 The protections conferred by this Stipulation and Order cover not only 20 Protected Material (as defined above), but also (1) any information copied or 21 extracted from Protected Material; (2) all copies, excerpts, summaries, or compilations 22 of Protected Material; and (3) any testimony, conversations, or presentations by 23 Parties or their Counsel that might reveal Protected Material. 24 Any use of Protected Material at trial shall be governed by the orders of the trial 25 judge. This Order does not govern the use of Protected Material at trial. 26 /// 27 /// 28 1 4. DURATION 2 Once a case proceeds to trial, all of the information that was designated as 3 confidential or maintained pursuant to this protective order becomes public and will 4 be presumptively available to all members of the public, including the press, unless 5 compelling reasons supported by specific factual findings to proceed otherwise are made 6 to the trial judge in advance of the trial. See Kamakana v. City and County of Honolulu, 7

(9th 8 Cir. 2006) (distinguishing “good cause” showing for 8 sealing documents produced in discovery from “compelling reasons” standard when 9 merits-related documents are part of court record). Accordingly, the terms of this 10 protective order do not extend beyond the commencement of the trial. 11 Even after final disposition of this litigation, the confidentiality obligations 12 imposed by this Order shall remain in effect until a Designating Party agrees 13 otherwise in writing or a court order otherwise directs. Final disposition shall be 14 deemed to be the later of (1) dismissal of all claims and defenses in this Action, with or 15 without prejudice; and (2) final judgment herein after the completion and exhaustion 16 of all appeals, rehearings, remands, trials, or reviews of this Action, including the time 17 limits for filing any motions or applications for extension of time pursuant to applicable 18 law. 19 5. DESIGNATING PROTECTED MATERIAL 20 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each 21 Party or Non-Party that designates information or items for protection under this Order 22 must take care to limit any such designation to specific material that qualifies under 23 the appropriate standards. The Designating Party must designate for items, or 24 communications for which protection is not warranted are not swept unjustifiably 25 within the ambit of this Order. 26 Mass, indiscriminate, or routinized designations are prohibited. Designations that 27 are shown to be clearly unjustified or that have been made for an improper purpose (e.g., 28 to unnecessarily encumber the case development process or to impose unnecessary 1 expenses and burdens on other parties) may expose the Designating Party to sanctions. 2 If it comes to a Designating Party’s attention that information or items that it 3 designated for protection do not qualify for protection, that Designating Party must 4 promptly notify all other Parties that it is withdrawing the inapplicable designation. 5 5.2 Manner and Timing of Designations. Except as otherwise provided in this 6 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or 7 ordered, Disclosure or Discovery Material that qualifies for protection under this Order 8 must be clearly so designated before the material is disclosed or produced. 9 Designation in conformity with this Order requires: 10 (a) for information in documentary form (e.g., paper or electronic 11 documents, but excluding transcripts of depositions or other pretrial or trial 12 proceedings), that the Producing Party affix at a minimum, the legend 13 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 14 contains protected material. If only a portion or portions of the material on a page 15 qualifies for protection, the Producing Party also must clearly identify the protected 16 portion(s) (e.g., by making appropriate markings in the margins). 17 A Party or Non-Party that makes original documents available for inspection need 18 not designate them for protection until after the inspecting Party has indicated which 19 documents it would like copied and produced. During the inspection and before the 20 designation, all of the material made available for inspection shall be deemed 21 “CONFIDENTIAL.” After the inspecting Party has identified the protection only those 22 parts of material, documents, items, or oral or written communications that qualify 23 so that other portions of the material, documents, documents it wants copied and 24 produced, the Producing Party must determine which documents, or portions thereof, 25 qualify for protection under this Order. Then, before producing the specified documents 26 the Producing Party must affix the “CONFIDENTIAL legend” to each page that contains 27 Protected Material. If only a portion or portions of the material on a page qualifies for 28 protection, the Producing Party also must clearly identify the protected portion(s) (e.g., 1 by making appropriate markings in the margins). 2 (b) for testimony given in depositions that the Designating Party identify 3 the Disclosure or Discovery Material on the record, before the close of the 4 deposition all protected testimony. 5 (c) for information produced in some form other than documentary and 6 for any other tangible items, that the Producing Party affix in a prominent place on the 7 exterior of the container or containers in which the information is stored the legend 8 “CONFIDENTIAL.” If only a portion or portions of the information warrants 9 protection, the Producing Party, to the extent practicable, shall identify the protected 10 portion(s). 11 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure 12 to designate qualified information or items does not, standing alone, waive the 13 Designating Party’s right to secure protection under this Order for such material. Upon 14 timely correction of a designation, the Receiving Party must make reasonable efforts to 15 assure that the material is treated in accordance with the provisions of this Order. 16 17 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 18 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 19 designation of confidentiality at any time that is consistent with the Court’s 20 Scheduling Order. 21 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 22 resolution process under Local Rule 37.1 et seq. 23 6.3 The burden of persuasion in any such challenge proceeding shall be on the 24 Designating Party. Frivolous challenges, and those made for an improper purpose 25 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 26 expose the Challenging Party to sanctions. Unless the Designating Party has waived or 27 withdrawn the confidentiality designation, all parties shall continue to afford the 28 material in question the level of protection to which it is entitled under the 1 Producing Party’s designation until the Court rules on the challenge. 2 3 7. ACCESS TO AND USE OF PROTECTED MATERIAL 4 7.1 Basic Principles. A Receiving Party may use Protected Material that is 5 disclosed or produced by another Party or by a Non-Party in connection with this Action 6 only for prosecuting, defending, or attempting to settle this Action. Such Protected 7 Material may be disclosed only to the categories of persons and under the conditions 8 described in this Order. When the Action has been terminated, a Receiving Party 9 must comply with the provisions of section 13 below (FINAL DISPOSITION). 10 Protected Material must be stored and maintained by a Receiving Party at a 11 location and in a secure manner that ensures that access is limited to the persons 12 authorized under this Order. 13 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise 14 ordered by the court or permitted in writing by the Designating Party, a Receiving Party 15 may disclose any information or item designated “CONFIDENTIAL” only to: 16 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 17 well as employees of said Outside Counsel of Record to whom it is reasonably necessary 18 to disclose the information for this Action; 19 (b) the officers, directors, and employees (including House Counsel) of 20 the Receiving Party to whom disclosure is reasonably necessary for this Action; 21 (c) Experts (as defined in this Order) of the Receiving Party to whom 22 disclosure is reasonably necessary for this Action and who have signed the 23 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 24 (d) the court and its personnel; 25 (e) court reporters and their staff; 26 (f) professional jury or trial consultants, mock jurors, and Professional 27 Vendors to whom disclosure is reasonably necessary for this Action and who have 28 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 1 (g) the author or recipient of a document containing the information or a 2 custodian or other person who otherwise possessed or knew the information; 3 (h) during their depositions, witnesses ,and attorneys for witnesses, in the 4 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 5 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will not 6 be permitted to keep any confidential information unless they sign the 7 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 8 agreed by the Designating Party or ordered by the court. Pages of transcribed 9 deposition testimony or exhibits to depositions that reveal Protected Material may be 10 separately bound by the court reporter and may not be disclosed to anyone except s 11 permitted under this Stipulated Protective Order; and 12 (i) any mediator or settlement officer, and their supporting 13 personnel, mutually agreed upon by any of the parties engaged in settlement discussions. 14 15 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 16 OTHER LITIGATION 17 If a Party is served with a subpoena or a court order issued in other litigation that 18 compels disclosure of any information or items designated in this Action as 19 “CONFIDENTIAL,” that Party must: 20 (a) promptly notify in writing the Designating Party. Such notification 21 shall include a copy of the subpoena or court order; 22 (b) promptly notify in writing the party who caused the subpoena or order 23 to issue in the other litigation that some or all of the material covered by the 24 subpoena or order is subject to this Protective Order. Such notification shall include a 25 copy of this Stipulated Protective Order; and 26 (c) cooperate with respect to all reasonable procedures sought to be 27 pursued by the Designating Party whose Protected Material may be affected. 28 If the Designating Party timely seeks a protective order, the Party served with the 1 subpoena or court order shall not produce any information designated in this action as 2 “CONFIDENTIAL” before a determination by the court from which the subpoena or 3 order issued, unless the Party has obtained the Designating Party’s permission. The 4 Designating Party shall bear the burden and expense of seeking protection in that court 5 of its confidential material and nothing in these provisions should be construed as 6 authorizing or encouraging a Receiving Party in this Action to disobey a lawful directive 7 from another court. 8 9 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED 10 IN THIS LITIGATION 11 (a) The terms of this Order are applicable to information produced by a 12 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 13 produced by Non-Parties in connection with this litigation is protected by the 14 remedies and relief provided by this Order. Nothing in these provisions should be 15 construed as prohibiting a Non-Party from seeking additional protections. 16 (b) In the event that a Party is required, by a valid discovery request, to 17 produce a Non-Party’s confidential information in its possession, and the Party is 18 subject to an agreement with the Non-Party not to produce the Non-Party’s 19 confidential information, then the Party shall: 20 (1) promptly notify in writing the Requesting Party and the Non-Party 21 that some or all of the information requested is subject to a confidentiality 22 agreement with a Non-Party; 23 (2) promptly provide the Non-Party with a copy of the Stipulated 24 Protective Order in this Action, the relevant discovery request(s), and a reasonably 25 specific description of the information requested; and 26 (3) make the information requested available for inspection by the 27 Non-Party, if requested. 28 (c) If the Non-Party fails to seek a protective order from this court within 1 14 days of receiving the notice and accompanying information, the Receiving Party may 2 produce the Non-Party’s confidential information responsive to the discovery request. If 3 the Non-Party timely seeks a protective order, the Receiving Party shall not produce any 4 information in its possession or control that is subject to the confidentiality 5 agreement with the Non-Party before a determination by the court. Absent a court 6 order to the contrary, the Non-Party shall bear the burden and expense of seeking 7 protection in this court of its Protected Material. 8 9 10. 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 must immediately (a) notify in 13 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts to 14 retrieve all unauthorized copies of the Protected Material, (c) inform the person or 15 persons to whom unauthorized disclosures were made of all the terms of this Order, and 16 (d) request such person or persons to execute the “Acknowledgment and 17 Agreement to Be Bound” that is attached hereto as Exhibit A. 18 19 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 20 PROTECTED MATERIAL 21 When a Producing Party gives notice to Receiving Parties that certain 22 inadvertently produced material is subject to a claim of privilege or other protection, the 23 obligations of the Receiving Parties are those set forth in Federal Rule of Civil Procedure 24 26(b)(5)(B). This provision is not intended to modify whatever procedure may be 25 established in an e-discovery order that provides for production without prior 26 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 27 parties reach an agreement on the effect of disclosure of a communication or information 28 covered by the attorney-client privilege or work product protection, the parties may 1 incorporate their agreement in the stipulated protective order submitted to the court. 2 3 12. MISCELLANEOUS 4 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 5 person to seek its modification by the Court in the future. 6 12.2 Right to Assert Other Objections. By stipulating to the entry of this 7 Protective Order no Party waives any right it otherwise would have to object to 8 disclosing or producing any information or item on any ground not addressed in this 9 Stipulated Protective Order. Similarly, no Party waives any right to object on any ground 10 to use in evidence of any of the material covered by this Protective Order. 11 12.3 Filing Protected Material. A Party that seeks to file under seal any 12 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 13 only be filed under seal pursuant to a court order authorizing the sealing of the 14 specific Protected Material at issue. If a Party's request to file Protected Material under 15 seal is denied by the court, then the Receiving Party may file the information in the 16 public record unless otherwise instructed by the court. 17 18 13. FINAL DISPOSITION 19 After the final disposition of this Action, as defined in paragraph 4, within 60 20 days of a written request by the Designating Party, each Receiving Party must return all 21 Protected Material to the Producing Party or destroy such material. As used in this 22 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 23 summaries, and any other format reproducing or capturing any of the Protected 24 Material. Whether the Protected Material is returned or destroyed, the Receiving Party 25 must submit a written certification to the Producing Party (and, if not the same person or 26 entity, to the Designating Party) by the 60 day deadline that (1) identifies (by category, 27 where appropriate) all the Protected Material that was returned or destroyed and (2) 28 affirms that the Receiving Party has not retained any copies, abstracts, 1 || compilations, summaries or any other format reproducing or capturing any of the 2 || Protected Material. Notwithstanding this provision, Counsel are entitled to retain an 3 || archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, 4 || legal memoranda, correspondence, deposition and trial exhibits, expert reports, attorne 5 || work product, and consultant and expert work product, even if such materials contain 6 ||Protected Material. Any such archival copies that contain or constitute Protected 7 || Material remain subject to this Protective Order as set forth in Section 4 (DURATION: 8 ||/14. Any violation of this Order may be punished by any and all appropriate 9 ||measures including, without limitation, contempt proceedings and/or monetary 10 || sanctions. 11 12 || IT ISSO STIPULATED, THROUGH COUNSEL OF RECORD. 13 14 || DATED: _ May 8, 2025 15 /s/ Greg _L. Kirakosian 16 || Attorneys for Plaintiff(s) 17 18 || DATED: _ May 8, 2025 19 /s/ Molshree Gupta 20 Attorneys for Defendant(s) 21 22 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

DATED: May 9: 2025

25 Wes 26 || Honorable Shashi H. Kewalramani 27 || United States Brstrtet/Magistrate Judge 28

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, [print or type full name], of 4 [print or type full address], declare under penalty of perjury 5 that I have read in its entirety and understand the Stipulated Protective Order that 6 was issued by the United States District Court for the Central District of California on 7 [date] in the case of Terrence Johnson v, County of Riverside, et al., USDC Case 8 Number 5:25-cv-00738-RGK (SHKx). I agree to comply with and to be bound by all the 9 terms of this Stipulated Protective Order and I understand and acknowledge that failure 10 to so 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 that is 12 subject to this Stipulated Protective Order to any person or entity except in strict 13 compliance with the provisions of this Order. I further agree to submit to the jurisdiction 14 of the United States District Court for the Central District of California for the 15 purpose of enforcing the terms of this Stipulated Protective Order, even if such 16 enforcement proceedings occur after termination of this action. I hereby appoint 17 [print or type full name] of 18 [print or type full address and telephone number] as my California 19 agent for service of process in connection with this action or any proceedings related 20 to enforcement of this Stipulated Protective Order. 21 Date: 22 City and State where sworn and signed: 23 Printed name: 24 Signature: 25 26 27 28 CERTIFICATE OF SERVICE 1

2 I am employed in the County of Los Angeles, State of California; I am over the age of eighteen years and not a party to the within action; my business address is 841 3 Apollo Street, Suite 100, El Segundo, California 90245. 4 5 On May 8, 2025, I served the foregoing document described as STIPULATED PROTECTIVE ORDER on all interested parties in this action by placing a true copy 6 thereof in a sealed envelope addressed as follows: 7 SEE ATTACHED SERVICE LIST 8

9 By Mail I caused such envelope(s) to be deposited in the mail at El Segundo, 10 California. The envelope was mailed with postage thereon fully prepaid and 11 addressed to the parties listed on the Service List. I am “readily familiar” with the 12 firm’s practice of collection and processing correspondence for mailing. It is deposited with U.S. postal service on that same day in the ordinary course of 13 business. I am aware that on motion of party served, service is presumed invalid 14 if postal cancellation date or postage meter date is more than 1 day after date of deposit for mailing in affidavit. 15

16 XX By Email Based upon a court order or an agreement of the parties to accept electronic service, I caused the documents to be sent to the persons at the 17 electronic service addresses listed in the Service List. My email address is 18 [email protected].

19 XX State I declare under penalty of perjury under the laws of the State of California 20 that the foregoing is true and correct. 21 Executed on May 8, 2025, at El Segundo, California. 22

23 /s/ Maria Nixon 24 Maria Nixon 25 26 27 28 SERVICE LIST 1 540-17 2 Terrence Johnson v. County of Riverside, et al USDC Case No.: 5:25-cv-00738-RGK (SHKx) 3

4 Gregory L. Kirakosian, Esq. Attorneys for Plaintiff, 5 KIRAKOSIAN LAW, APC TERRENCE JOHNSON 11684 Ventura Blvd., Suite 975 6 Studio City, California 91604 7 Telephone: (213) 986-5389 Facsimile: (213) 477-2355 8 EM: [email protected] 9 [email protected] [email protected] 10 [email protected] 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28