11 James R. Touchstone, SBN 184584 [email protected] 22 Helen O. Kim, SBN 254560 [email protected] 33 JONES MAYER 3777 North Harbor Boulevard 44 Fullerton, CA 92835 Telephone: (714) 446-1400 55 Facsimile: (714) 446-1448 66 Attorneys for Defendant, CITY OF REDLANDS 77 Peter L. Carr, IV, SBN 256104 88 [email protected] Na’Shaun L. Neal, SBN 284280 99 [email protected] Lauren K. McRae, SBN 331296 1100 [email protected] PLC LAW GROUP, APC 1111 3756 Santa Rosalia Dr., Suite 326 Los Angeles, CA 90008 1122 Telephone: (310) 400-5890 Facsimile: (310)- 400-5895 1133 Attorneys for Plaintiffs, 1144 WINDY TAYLOR, individually, and W.T., by and through his Guardian ad litem, 1155 DEANDRA MOORE, individually, and as successor in interest for WINSTON 1166 TAYLOR 1177 [Additional counsel cont. on next page] 1188 UNITED STATES DISTRICT COURT 1199 CENTRAL DISTRICT OF CALIFORNIA 2200 WINDY TAYLOR, individually, and Case No. 5:25-cv-00299-JGB (DTB) 2211 W.T., by and through his Guardian ad Litem, DEANDREA MOORE, Assigned for All Purposes to: 2222 individually and as successor in interest Judge Jesus G. Bernal for WINSTON TAYLOR, 2233 Plaintiffs, [PROPOSED STIPULATED 2244 PROTECTIVE ORDER] vs. 2255 CITY OF REDLANDS, and DOES 1-10, Complaint filed: February 3, 2025 2266 inclusive, 2277 Defendants. 11 [Additional counsel from previous page] 22 33 Jaaye Person-Lynn, SBN 269614 [email protected] 44 200 Corporate Pointe, Suite 495 Culver City, CA 90230 55 Telephone: (310) 642-0600 Facsimile: (310) 642-4712 66 Attorneys for Plaintiffs, 77 WINDY TAYLOR, individually, and W.T., by and through his Guardian ad litem, 88 DEANDRA MOORE, individually, and as successor in interest for WINSTON 99 TAYLOR 1100 1111 1122 1133 1144 1155 1166 1177 1188 1199 2200 2211 2222 2233 2244 2255 2266 2277 11 STIPULATED PROTECTIVE ORDER 22 Pursuant to Federal Rule of Civil Procedure 26(c), Defendant CITY OF 33 REDLANDS and Plaintiffs WINDY TAYLOR, individually, and W.T., by and 44 through his Guardian ad litem, DEANDRA MOORE, individually and as 55 successor in interest for WINSTON TAYLOR, (collectively "the Parties"), by their 66 undersigned counsel, agree to be bound to the terms of the following Protective 77 Order. The Parties represent that pre-trial discovery in this case is likely to include 88 the production of information and/or documents that are confidential and/or 99 privileged including the production of peace officer personnel file information 1100 and/or documents which the Parties agree includes: (1) Personal data, including 1111 marital status, family members, educational and employment history, home 1122 addresses, or similar information; (2) Medical history; (3) Election of employee 1133 benefits; (4) Employee advancement, appraisal, or discipline; and (5) Complaints, 1144 or investigations of complaints, concerning an event or transaction in which a 1155 peace officer participated, or which a peace officer perceived, and pertaining to the 1166 manner in which the peace officer performed his or her duties including compelled 1177 statements by peace officers. Defendant contends that such information is 1188 privileged as official information. Sanchez v. City of Santa Ana,

, 1199 1033 (9th Cir. Cal. 1990); see also Kerr v. United States Dist. Ct. for N.D. Cal., 2200

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

,

,

725 (1976). Further, discovery may require the production of certain Redlands 2222 Police Department Policies and Procedures not available to the public and the 2233 public disclosure of which could comprise officer safety, raise security issues, 2244 and/or impede investigations. Peace officer personnel file information and/or 2255 documents and security-sensitive policies and procedures are hereinafter referred 2266 to as "Confidential Information". 2277 Defendant contends that that public disclosure of such material poses a substantial risk of embarrassment, oppression and/or physical harm to peace 11 officers whose Confidential Information is disclosed. The Parties further agree that 22 the risk of harm to peace officers is greater than with other government employees 33 due to the nature of their profession. Finally, the Defendant contends that the 44 benefit of public disclosure of Confidential Information is minimal while the 55 potential disadvantages are great. 66 Accordingly, good cause exists for entry of this Protective Order to facilitate 77 pre-trial disclosure while assuring the safety of these sensitive disclosures. See 88 Fed. R. Civ. Proc. 26(c). 99 SO STIPULATED 1100 Dated: May 27, 2025 Respectfully submitted, 1111 JONES MAYER 1122 1133 By: s/ Helen O. Kim 1144 JAMES R. TOUCHSTONE HELEN O. KIM 1155 Attorneys for Defendant City of Redlands 1166 1177 Dated: May 27, 2025 Respectfully submitted, 1188 PLC LAW GROUP, APC 1199 2200 2211 By: s/ Peter L. Carr PETER L. CARR 2222 NA’SHAN L. NEAL 2233 LAUREN K. MCRAE Attorneys for Plaintiffs WINDY 2244 TAYLOR, individually, and W.T., by and through his Guardian ad litem, 2255 DEANDRA MOORE, individually, and as successor in interest for 2266 WINSTON TAYLOR 2277 11 Dated: May 27, 2025 Respectfully submitted, 22 PERSON-LYNN LAW OFFICE 33 44 55 By: s/ Jaaye Person-Lynn JAAYE PERSON-LYNN, 66 Attorneys for Plaintiffs WINDY TAYLOR, individually, and W.T., 77 by and through his Guardian ad litem, DEANDRA MOORE, individually, 88 and as successor in interest for WINSTON TAYLOR 99 1100 1111 1122 1133 1144 1155 1166 1177 1188 1199 2200 2211 2222 2233 2244 2255 2266 2277 11 PROTECTIVE ORDER 22 PER THE STIPULATION OF THE PARTIES AND GOOD CAUSE 33 APPEARING, IT IS HEREBY ORDERED that the terms and conditions of this 44 Protective Order shall govern the handling of Discovery Materials containing 55 Confidential Information in matter of Windy Taylor, et. al. v City of Redlands, et. 66 al. USCD Case No. 5:25-cv-00299-JGB (DTB) ("the Litigation"): 77 1. Applicability of Order: This Order does not and will not govern any 88 trial proceedings in this Litigation, but will otherwise be applicable to and govern 99 the handling of documents, depositions, deposition exhibits, interrogatory 1100 responses, responses to requests for admissions, responses to requests for 1111 production of documents, and all other discovery obtained pursuant to the Federal 1122 Rules of Civil Procedure by Plaintiffs in connection with the Litigation (this 1133 information hereinafter referred to as “Discovery Material”). 1144 2. Designation of Material: Defendant may designate Discovery 1155 Material that is in their possession, custody or control to be produced to Plaintiffs 1166 as “Confidential Information” under the terms of this Order if Defendant in good 1177 faith reasonably believe that such Discovery Material contains non-public, 1188 confidential material as defined in section 4 below. 1199 3. Exercise of Restraint and Care in Designating Material for 2200 Protection: When designating Discovery Material for protection as Confidential 2211 Information under this Order, Defendant must take care to limit any such 2222 designation to specific material that qualifies under the appropriate standards. 2233 Mass, indiscriminate, or routinized designations are prohibited. 2244 4. Confidential Information: For purposes of this Order, Confidential 2255 Information is any information and/or documents that Defendant believes in good 2266 faith to be Peace Officer Personnel File Information and/or Documents including: 2277 (1) Personal data, including marital status, family members, educational and employment history, home addresses, or similar information; (2) Medical history; 11 (3) Election of employee benefits; (4) Employee advancement, appraisal, or 22 discipline; and (5) Complaints, or investigations of complaints, concerning an 33 event or transaction in which a peace officer participated, or which a peace officer 44 perceived, and pertaining to the manner in which the peace officer performed his 55 or her duties including compelled statements. Confidential Information is also any 66 Redlands Police Department Policies and Procedures not available to the public 77 and the public disclosure of which could comprise officer safety, raise security 88 issues, and/or impede investigations. 99 5. Designating Confidential Information: The designation of 1100 Discovery Material as Confidential Information for purposes of this Order shall be 1111 made in the following manner: 1122 a. Documents: In the case of documents or other materials (apart from 1133 depositions or other pre-trial testimony), designation shall be made by 1144 stamping “Confidential” to each page containing any Confidential 1155 Information. Any such stamp shall not overwrite or otherwise 1166 obscure the text or images of any page. 1177 b. Deposition and Other Proceedings: In the case of depositions or other 1188 pre-trial testimony, designation of the portion of the transcript 1199 (including exhibits) which contains Confidential Information shall be 2200 made (i) by a statement to such effect on the record during the 2211 proceeding in which the testimony is received, or (ii) by written notice 2222 served on counsel of record in this Litigation within thirty (30) 2233 business days after the receipt of the draft transcript of such 2244 deposition or other pre-trial proceeding. However, before such thirty 2255 (30) day period expires, all testimony, exhibits and transcripts of 2266 depositions or other testimony shall be treated as Confidential 2277 Information. Thereafter, only those portions properly designated shall be deemed Confidential Information. 11 c. Non-Written Materials: Any non-written Confidential Information 22 (e.g., videotape, audio tape, computer disk, etc.) may be designated 33 as such by labeling the outside of such non-written material 44 designated as “Confidential”. In the event Plaintiffs generate any 55 “hard copy” transcription or printout from any such designated non- 66 written materials, the person who generates such “hard copy” 77 transcription shall take reasonable steps to maintain the 88 confidentiality of such materials. 99 6. Inadvertent Disclosure: The inadvertent failure to designate 1100 Discovery Information as "Confidential" does not constitute a waiver of such claim 1111 and may be remedied by prompt supplemental written notice upon discovery of the 1122 inadvertent disclosure, with the effect that such Discovery Material will be subject 1133 to the protections of this Order. Plaintiffs shall exercise good faith efforts to ensure 1144 that copies they make of Confidential Information produced to him, and copies 1155 made by others who obtained such Confidential Information directly or indirectly 1166 from the Plaintiffs include the appropriate confidentiality legend, to the same 1177 extent that the Confidential Information has been marked with the appropriate 1188 confidentiality legend by the Defendant. 1199 7. No Waiver of Privilege: Inadvertent disclosure of Confidential 2200 Information or otherwise privileged information shall not constitute a waiver of, or 2211 estoppel as to any claim of privilege. This Order is intended to provide the full 2222 protection afforded by Federal Rule of Evidence 502(d). 2233 8. Claw-Back: Pursuant to Federal Rule of Civil Procedure 26(b)(5), 2244 upon learning it may have produced Confidential or otherwise privileged 2255 Information, Defendant shall, within ten (10) days of such discovery, request the 2266 return of such Information in writing by identifying the Confidential or otherwise 2277 privileged Information and stating the basis on which the Information should be withheld from production. After being notified, Plaintiffs must promptly return, 11 sequester, or destroy the Confidential or otherwise privileged Information and any 22 copies, must not use or disclose the Information until the claim is resolved and 33 must take reasonable steps to retrieve the Confidential or otherwise privileged 44 Information if he disclosed the Information before being notified. If Plaintiffs 55 dispute Defendant’s claim of confidentiality or privilege; they shall notify the 66 Defendant claiming confidentiality of the dispute and the basis therefore in writing 77 within thirty (30) days of receipt of the request for the return of the Confidential or 88 otherwise privileged Information. The Plaintiffs and the Defendant claiming 99 confidentiality shall meet and confer in good faith regarding the disputed claim 1100 within thirty (30) days. In the event that the Plaintiffs and the Defendant claiming 1111 confidentiality do not resolve their dispute, either party may bring a motion for a 1122 determination of whether a privilege applies. If such a motion is made, the 1133 Defendant claiming confidentiality shall submit to the Court for in camera review 1144 under seal a copy of the disputed Information in connection with its motion papers. 1155 The submission to the Court shall not constitute a waiver of any privilege or 1166 protection. Defendant must preserve the Information claimed to be privileged or 1177 otherwise protected until the claim is resolved. 1188 9. Notes of Confidential Information: Any notes, lists, memoranda, 1199 indices, compilations prepared or based on an examination of Confidential 2200 Information that quote from or paraphrase, Confidential Information with such 2211 specificity that the Confidential Information can be identified, or by reasonable 2222 logical extension can be identified, shall be accorded the same status of 2233 confidentiality as the underlying Confidential Information from which they are 2244 made and shall be subject to all of the terms of this Order. 2255 // 2266 // 2277 // // 11 10. Persons Authorized To Receive Confidential Information: 22 Discovery Material designated “Confidential” may be disclosed, summarized, 33 described, characterized or otherwise communicated or made available in whole or 44 in part only to the following persons: 55 a. The Court, persons employed by the Court who are necessary for the 66 handling of the Litigation, and court reporters transcribing the 77 testimony or argument at a hearing, trial or deposition in this 88 Litigation or any appeal there from; 99 b. Counsel of record in this Litigation, as well as paralegals, technical, 1100 administrative and clerical employees working under the direct 1111 supervision of such counsel; 1122 c. Experts or consultants assisting any counsel of record in this 1133 Litigation, provided such experts and consultants agree to be bound 1144 by the terms and conditions set forth in the “Agreement Concerning 1155 Information Covered by Protective Order” attached hereto as 1166 Exhibit "A" prior to the time such information is disclosed; and 1177 d. Any other person, only upon order of the Court or upon stipulation 1188 of the Parties, and who agrees to be bound by the terms and conditions 1199 set forth in the “Agreement Concerning Information Covered by 2200 Protective Order” attached hereto as Exhibit "A" prior to the time such 2211 Information is disclosed. However, under no circumstances shall 2222 home addresses or telephone numbers of individual Defendant be 2233 provided to Plaintiffs. 2244 11. Use of Confidential Discovery Material: Discovery Material 2255 containing Confidential Information shall be used solely for purposes of the 2266 Litigation, including any appeal and re-trial. Any person or entity in possession of 2277 Discovery Material designated Confidential shall maintain those materials in accordance with Paragraph (storage) below. 11 12. Storage Of Confidential Information: The recipient of any 22 Confidential Information that is provided under this Protective Order shall 33 maintain such information in a reasonably secure and safe manner that ensures that 44 access is limited to the persons authorized under this Order. 55 13. Filing of Confidential Information: Without written permission 66 from Defendant or a Court order, Plaintiffs may not file in the public record in this 77 action any Confidential Information. Filing this information in the public record 88 must occur under seal in compliance with Local Rule 79-5 when seeking to file 99 Confidential Information under seal. The party desiring to place any Confidential 1100 Information before the Court shall lodge the information in a sealed envelope 1111 along with an application to file the papers or the portion thereof containing 1122 Confidential Information under seal and a copy of a Proposed Order Sealing 1133 Documents. Said envelope shall be endorsed with the title of the Litigation, an 1144 indication of the nature of the contents of such sealed envelope, the identity of the 1155 party filing the materials, the phrase “Confidential Information” and a statement 1166 substantially in the following form: 1177 THIS ENVELOPE CONTAINS MATERIALS SUBJECT TO A 1188 PROTECTIVE ORDER ENTERED IN THIS LITIGATION. IT 1199 IS NOT TO BE OPENED NOR ARE ITS CONTENTS TO BE 2200 DISPLAYED, REVEALED, OR MADE PULBIC, EXCEPT BY 2211 ORDER OF THE COURT. UNLESS THE COURT ORDERS THAT IT 2222 NOT BE FILED, IT SHALL BE FILED UNDER SEAL. 2233 Additionally, within seven (7) days from the date that the papers (or portions 2244 thereof) were filed under seal consistent with the above procedures, the party who 2255 filed the papers under seal also shall file in the public record a version of the 2266 papers that has been redacted to omit the Confidential Information or any 2277 references thereto). 11 As for any other information disclosed during discovery and marked 22 “Confidential” that either party wishes to file in the public record in this action in 33 support of or in opposition to any motion, the Parties shall specifically identify any 44 such documents and seek a stipulation concerning any sealing requirement 55 therefore during the parties Local Rule 7-3 conference of counsel. If no agreement 66 can be reached, the party advancing the “confidential” designation bears the 77 burden of moving to have those documents sealed by the court. 88 14. No Prejudice: Agreeing to be bound by this Protective Order, 99 agreeing to and/or producing or receiving Confidential Information or otherwise 1100 complying with the terms of this Order shall not: 1111 a. Prejudice in any way the rights of Defendant to object to the 1122 production of documents it considers not subject to discovery, or 1133 operate as an admission by Defendant that the restrictions and 1144 procedures set forth herein constitute adequate protection for any 1155 particular information deemed by Defendant to be Confidential 1166 Information; 1177 b. Prejudice in any way the rights of Defendant to object to the 1188 authenticity or admissibility into evidence of any document, 1199 testimony or other evidence subject to this Order; 2200 c. Prejudice in any way the rights of Defendant to seek a determination 2211 by the Court whether any Confidential Information should be subject 2222 to the terms of this Order; 2233 15. Challenging Designation of Information: Plaintiffs may challenge 2244 the propriety of a Confidential Information designation by providing to the 2255 Defendant claiming confidentiality a writing which briefly: (i) identifies with 2266 reasonable particularity the documents and/or information which are the subject of 2277 the challenge; and (ii) describes the basic legal or factual grounds for the challenge. Once a challenge is made, the Defendant claiming confidentiality will 11 bear the burden of initiating and conducting a sufficient meet and confer (per Local 22 Rule 37-1); and, if necessary, Defendant claiming confidentiality will bear the 33 burdens of proof and persuasion in moving for a Protective Order (per Local Rule 44 37-2) to uphold the challenged Confidential Information designation(s). Until the 55 Court rules on the timely filed Motion for Protective Order, all parties shall 66 continue to afford the material in question the level of protection to which it is 77 entitled under the claiming Defendant’s designation. 88 16. Additional Parties or Attorneys: In the event additional parties join 99 or intervene in this action, the newly joined party(ies) shall not have access to 1100 Confidential Information until its counsel has executed an agreement to be fully 1111 bound by this Order. If any additional attorneys make appearances in this 1122 Litigation, those attorneys shall not have access to Confidential Information until 1133 they execute the “Agreement Concerning Information Covered by Protective 1144 Order” attached hereto as Exhibit "A". 1155 17. Protective Order Remains In Force: This Protective Order shall 1166 remain in force and effect until modified, superseded, or terminated by consent of 1177 the Parties or by order of the Court made upon reasonable written notice. Unless 1188 otherwise ordered, or agreed upon by the Parties, this Protective Order shall 1199 survive the termination of this action. The Court retains jurisdiction even after 2200 termination of this action to enforce this Protective Order and to make such 2211 amendments, modifications, deletions and additions to this Protective Order as the 2222 Court may from time to time deem appropriate. 2233 18. Conclusion of Litigation: Within ninety (90) days after receiving 2244 notice of the entry of an order, judgment or decree finally disposing of this 2255 Litigation, all persons having received Confidential Information shall either return 2266 such material and all copies thereof to the counsel of the Defendant who 2277 designated the information as Confidential or destroy all such Confidential Information including the Confidential Information Plaintiffs provided to other 1 | persons. In either case, counsel for Plaintiffs must certify that fact to the counsel of 2 || the Defendant who designated the information as Confidential. 3 19. Redaction Allowed: Defendant may redact Confidential Information 4 || from documents and things produced to the extent that such information consists o 5 || personal identifying information of third parties per Federal Rule of Civil 6 || Procedure 5.2 and Central District Local Rule 5.2-1 and/or personal identifying 7 || information of peace officers or their family members, such as ID numbers, phone 8 || numbers, addresses, or medical history which is unrelated to any claim or defense 9 || raised in the instant action. Defendant shall mark each thing where matter has been 10 | redacted with a legend stating “REDACTED,” as appropriate, or a comparable 11 |] notice. 12 20. Violations of Protective Order: In the event that any person or party 13 || should violate the terms of this Protective Order, the aggrieved party should apply 14 |] to the Court obtain relief against any such person or party violating or threatening 15 |] to violate any of the terms of this Protective Order. 16 In the event that the aggrieved party seeks injunctive relief, it must petition 17 || the District Judge for such relief, which may be granted at the sole discretion of the 18 || District Judge. 19 20 IT ISSO ORDERED. 21 22 || Dated: May 29 , 2025 23 24 i nif) / f 25 : 26 UNITED STATES MAGISTRATE JUDGE 27 28

11 EXHIBIT "A"TO STIPULATED PROTECTIVE ORDER 22 UNITED STATES DISTRICT COURT 33 CENTRAL DISTRICT OF CALIFORNIA 44 55 WINDY TAYLOR, individually, and Case No. 5:25-cv-00299-JGB (DTB) W.T., by and through his Guardian ad 66 Litem, DEANDREA MOORE, AGREEMENT CONCERNING individually and as successor in interest INFORMATION COVERED BY 77 for WINSTON TAYLOR, STIPULATED PROTECTIVE ORDER 88 Plaintiffs, 99 vs. CITY OF REDLANDS, and DOES 1-10, 1100 inclusive, 1111 Defendants. 1122 1133 1144 1. I, __________________________________, hereby acknowledge 1155 that I have received a copy of the Stipulated Protective Order entered in this 1166 Litigation [Case No: 5:25-cv-00299-JGB (DTB)] by the United States District 1177 Court for the Central District of California (hereinafter, “the Protective Order”). 1188 2. I have either read the Protective Order or have had the terms of the 1199 Protective Order explained to me by my attorney. 2200 3. I understand the terms of the Protective Order and agree to comply 2211 with and to be bound by such terms. 2222 4. If I receive documents or information designated as Confidential 2233 Information (as that term is defined in the Protective Order), I understand that such 2244 Information is provided to me pursuant to the terms and restrictions of the 2255 Protective Order. 2266 5. I agree to hold in confidence and not further disclose or use for any 2277 purpose (other than is permitted by the Protective Order) any Confidential Information disclosed to me pursuant to the terms of the Protective Order. 11 6. I hereby submit myself to the jurisdiction of the United States District 22 Court for the Central District of California for resolution of any matters pertaining 33 to the Protective Order. 44 55 My address is:____________________________________ 66 77 My present employer is: ________________________________ 88 99 Dated: ______________ 1100 1111 1122 Signed: _________________________ 1133 1144 1155 1166 1177 1188 1199 2200 2211 2222 2233 2244 2255 2266 2277