1 || Eugene P. Ramirez (State Bar No. 134865) cugeneramir menninglip.com 2 || Eugene P. Hanrahan (State Bar No. 185826) eugene. □□□□□□□□□□□□□□□□□□□□□□□ 3 || Kayleigh A. Andersen (State Bar No. 306442) Rapicigh □□□□□□□□□□□□□□□□□□□□□□□ 4||MANNING & KAS ELLROD, RAMIREZ, TRESTER LLP 5|/801 S. Figueroa St, 15th Floor, Los Angeles, California 90017-3012 6 || Telephone: GB) 624-6900 Facsimile: (213) 624-6999 7 Attorneys for Defendants SHERIFF 8 || CHAD BIANCO; Sergeant TODD JOHNSON; Correctional Deputy ABDUL 9 || FAR; MORGAN MCCANDLESS; Correctional Corporal BENJAMIN 10 || SEAGRAVES-GLADNEY; Deputy KEVIN JONES; Correctional Deputy 2 11 || PHILLIP DIEFENDERFER; Correctional Deputy THOMAS KOLB; Correctional — 412 Deputy MIGUE TRIANA; and Corporal KAT GALLARDO z 13 > UNITED STATES DISTRICT COURT 14 = CENTRAL DISTRICT OF CALIFORNIA = 15 16 oe DEZARAE MUNOZ, individually and | Case No. 5:23-cv-02063-JGB-DTB 17 || as successor-in-interest to Estate of ULYSSES MUNOZ AYALA, 18 STIPULATED PROTECTIVE Plaintiffs, ORDER RE CONFIDENTIAL 19 DOCUMENTS V. 20 SHERIFF CHAD BIANCO, an Action Filed: October 10, 2023 21 || Individual; Sergeant TODD FAC Filed: November 8, 2024 JOHNSON, an individual, Correctional 22 peput ABDUL FAR, an individual, M IRGAN MCCANDLESS, an 23 || Individual, Correctional Corporal BENJAMIN SEAGRAVES- 24 || GLADNEY, an Individual, Correctional Deputy KEVIN JONES, an Individual; 25 || Correctional Deputy PHILLIP DIEFENDERFER, an Individual, 26 || Correctional Deputy THOMAS KOLB, an Individual, Correctional Deputy 27 || MIGUE TRIANA, an Individual, Corporal KAI GALLARDO, an 28 || individual: RIVERSIDE COUNTY

| BOERS RERARE MENT: Defendants. 3 4 5|}1. A.PURPOSES AND LIMITATIONS 6 Discovery in this action is likely to involve production of confidential, 7 || proprietary, or private information for which special protection from public disclosure 8 || and from use for any purpose other than prosecuting this litigation may be warranted. 9 || Accordingly, the parties hereby stipulate to and petition the Court to enter the 10 || following Stipulated Protective Order. The parties acknowledge that this Order does 2 11 ||not confer blanket protections on all disclosures or responses to discovery and that x 12 ||the protection it affords from public disclosure and use extends only to the limited 13 information or items that are entitled to confidential treatment under the applicable 14 || legal principles. The parties further acknowledge, as set forth in Section 12.3, below, 15 ||that this Stipulated Protective Order does not entitle them to file confidential 16 || information under seal; Civil Local Rule 79-5 sets forth the procedures that must be 17 || followed and the standards that will be applied when a party seeks permission from 18 || the court to file material under seal. 19 B. GOOD CAUSE STATEMENT 20 This action is likely to involve medical records, documents containing private 21 ||information from third parties, police investigation procedures and tactics, and other 22 ||confidential and private information for which special protection from public 23 disclosure and from use for any purpose other than prosecution of this action is 24 || warranted. Such confidential and proprietary materials and information consist of, 25 || among other things, confidential personal information of non-parties, private medical 26 ||and mental health records, including Plaintiff's and plaintiffs’ decedent’s HIPAA 27 || protected medical and mental health care records, internal police reviews and 28 || procedures, and other confidential and sensitive information otherwise generally

1 || unavailable to the public, or which may be privileged or otherwise protected from 2 || disclosure under state or federal statutes, court rules, case decisions, or common law. 3 || Defendants contend that there is good cause for a protective order to maintain the 4 confidentiality of peace officer personnel records. They emphasize that releasing 5 ||these records, which include internal analyses and legal communications, could 6 || hinder law enforcement investigations. 7 Accordingly, to expedite the flow of information, to facilitate the prompt 8 ||resolution of disputes over confidentiality of discovery materials, to adequately 9 || protect information the parties are entitled to keep confidential, to ensure that the 10 || parties are permitted reasonable necessary uses of such material in preparation for and 2 11 in the conduct of trial, to address their handling at the end of the litigation, and serve x 12 || the ends of justice, a protective order for such information is justified in this matter. 13 || It is the intent of the parties that information will not be designated as confidential for S$ 14 || tactical reasons and that nothing be so designated without a good faith belief that it 15 been maintained in a confidential, non-public manner, and there is good cause 16 || why it should not be part of the public record of this case. 17||2.. DEFINITIONS 18 2.1 Action: this pending federal lawsuit in Munoz v. County of Riverside, et al. 19 || (Case No: 5:23-cv-02063-JGB-DTB). 20 2.2 Challenging Party: a Party or Non-Party that challenges the designation of 21 || information or items under this Order. 22 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how 23 ||it is generated, stored or maintained) or tangible things that qualify for protection 24 ||}under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 25 || Cause Statement. 26 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 27 || support staff). 28 2.5 Designating Party: a Party or Non-Party that designates information or

1 |j/items that it produces in disclosures or in responses to discovery as 2 || “CONFIDENTIAL.” 3 2.6 Disclosure or Discovery Material: all items or information, regardless of 4||the medium or manner in which it is generated, stored, or maintained (including, 5 ||among other things, testimony, transcripts, and tangible things), that are produced or 6 || generated in disclosures or responses to discovery in this matter. 7 2.7 Expert: a person with specialized knowledge or experience in a matter 8 || pertinent to the litigation who has been retained by a Party or its counsel to serve as 9 || an expert witness or as a consultant in this Action. 10 2.8 House Counsel: attorneys who are employees of a party to this Action. 2 11 || House Counsel does not include Outside Counsel of Record or any other outside 12|Ilcounsel. 13 2.9 Non-Party: any natural person, partnership, corporation, association, or S$ 14 || other legal entity not named as a Party to this action. 15 2.10 Outside Counsel of Record: attorneys who are not employees of a party to 16||this Action but are retained to represent or advise a party to this Action and have 17 || appeared in this Action on behalf of that party or are affiliated with a law firm which 18 || has appeared on behalf of that party, and includes support staff. 19 2.11 Party: any party to this Action, including all of its officers, directors, 20 ||employees, consultants, retained experts, and Outside Counsel of Record (and their 21 || support staffs). 22 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 23 || Discovery Material in this Action. 24 2.13 Professional Vendors: persons or entities that provide litigation support 25 ||services (e.g., photocopying, videotaping, translating, preparing exhibits or 26 || demonstrations, and organizing, storing, or retrieving data in any form or medium) 27 ||and their employees and subcontractors. 28 2.14 Protected Material: any Disclosure or Discovery Material that 1s

1 || designated as “CONFIDENTIAL.” 2 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 3 || from a Producing Party. 4|/3. SCOPE 5 The protections conferred by this Stipulation and its associated Order cover not 6 || only Protected Material/Confidential Documents (as defined above), but also (1) any 7 ||information copied or extracted from Protected Material; (2) all copies, excerpts, 8 ||summaries, or compilations of Protected Material; and (3) any testimony, 9 || conversations, or presentations by Parties or their Counsel that might reveal Protected 10 || Material. However, the protections conferred by this Stipulation and its associated 2 11 || Order do not cover the following information: (a) any information that is in the public x 12 || domain at the time of disclosure to a Receiving Party or becomes part of the public 13 || domain after its disclosure to a Receiving Party as a result of publication not involving 14 || a violation of this Order, including becoming part of the public record through trial or 15 || otherwise; and (b) any information known to the Receiving Party prior to the 16 || disclosure or obtained by the Receiving Party after the disclosure from a source who 17 || obtained the information lawfully and under no obligation of confidentiality to the 18 || Designating Party. 19 Any use of Protected Material at trial shall be governed by the orders of the 20 || trial judge. This Order does not govern the use of Protected Material at trial. 21|}4. DURATION 22 “Once a case proceeds to trial, all information designated as confidential and 23 || introduced at trial shall be presumptively public, subject only to sealing by order of 24 || the trial judge upon a showing of compelling reasons supported by specific factual 25 || findings (Kamakana v. City & County of Honolulu,

). This Order shall 26 || not be construed to create any preemptive right to seal trial exhibits.” Accordingly, 27 || the terms of this protective order do not extend beyond the commencement of the trial 28 || except as designated above.

1/5. DESIGNATION OF PROTECTED MATERIAL 2 5.1. Exercise of Restraint and Care in Designating Material for Protection. 3 Each Party or non-party that designates information or items for protection 4|/under this Stipulation and its associated Order must take care to limit any such 5 || designation to specific material that qualifies under the appropriate standards. A 6 || Designating Party must take care to designate for protection only those parts of 7 || material, documents, items, or oral or written communications that qualify — so that 8 ||other portions of the material, documents, items or communications for which 9 || protection is not warranted are not swept unjustifiably within the ambit of this Order. 10 “Mass, indiscriminate, or routine designations are prohibited, and designations 2 11 ||shall be made only where good cause exists under FRCP 26(c) or applicable x 12 || California law, with a specific factual basis supporting confidentiality. Information 13 || may not be designated confidential for tactical reasons or to impede case preparation.” 14 || Designations that are shown to be clearly unjustified, or that have been made for an 15 ||improper purpose (e.g., to unnecessarily encumber or retard the case development 16 || process, or to impose unnecessary expenses and burdens on other parties), expose the 17 || Designating Party to sanctions. 18 If it comes to a Designating Party’s attention that information or items that it 19 || designated for protection do not qualify for protection, that Designating Party must 20 || promptly notify all other Parties that it is withdrawing the inapplicable designation. 21 5.2. Manner and Timing of Designations. Except as otherwise provided in 22 || this Order, or as otherwise stipulated or ordered, material that qualifies for protection 23 ||}under this Order must be clearly so designated before the material is disclosed or 24 || produced. 25 Designation in conformity with this Order requires: 26 (a) for information in documentary form (apart from transcripts of 27 || depositions or other pretrial or trial proceedings, and regardless of whether produced 28||in hardcopy or electronic form), that the Producing Party affix the legend

1 || “CONFIDENTIAL: THESE DOCUMENTS ARE SUBJECT TO THE TERMS AND 2 || CONDITIONS OF A PROTECTIVE ORDER, Case No. 5:24-cv-02405-SVW-DTB” 3 || to each page that contains Protected Material. If only a portion or portions of the 4 material on a page qualifies for protection, the Producing Party also must clearly 5 || identify the protected portion(s) (e.g., by making appropriate markings in the margins) 6 ||and must specify, for each portion that it is “CONFIDENTIAL.” The placement of 7 ||such “CONFIDENTIAL” stamp on such page(s) shall not obstruct the substance of 8 || the page’s (or pages’) text or content and shall be in the margin of the document 9 || whenever possible. 10 A Party or Non-Party that makes original documents or materials available for 2 11 || inspection need not designate them for protection until after the inspecting Party has x 12 || indicated which material it would like copied and produced. During the inspection 13 || and before the designation, all of the material made available for inspection shall be 14 || deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents 15 || it wants copied and produced, the Producing Party must determine which documents, or portions thereof, qualify for protection under this Order. Then, before producing 17||the specified documents, the Producing Party must affix the “CONFIDENTIAL” 18 || legend to each page that contains Protected Material. If only a portion or portions of 19 || the material on a page qualifies for protection, the Producing Party also must clearly 20 |lidentify the protected portion(s) (e.g., by making appropriate markings in the 21 || margins). 22 (b) fortestimony given in depositions that the Designating Party identify the 23 || Disclosure or Discovery Material on the record, before the close of the deposition all 24 || protected testimony. 25 (c) for information produced in some form other than documentary, and for 26 || any other tangible items (including but not limited to information produced on disc or 27 || electronic data storage device), that the Producing Party affix in a prominent place on 28 || the exterior of the container or containers in which the information or item is stored

1 || the legend “CONFIDENTIAL.” If only portions of the information or item warrant 2 || protection, the Producing Party, to the extent practicable, shall identify the protected 3 || portions, specifying the material as “CONFIDENTIAL.” 4 5.3. Inadvertent Failures to Designate. If timely corrected (preferably, 5 || though not necessarily, within 30 days of production or disclosure of such material), 6|[an inadvertent failure to designate qualified information or items as 7||“CONFIDENTIAL” does not, standing alone, waive the Designating Party’s right to 8 ||secure protection under this Stipulation and its associated Order for such material. 9 If material is appropriately designated as “CONFIDENTIAL” after the material 10 || was initially produced, the Receiving Party, on timely notification of the designation, 2 11 || must make reasonable efforts to assure that the material is treated in accordance with 2 this Stipulation and its associated Order. 13 || 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS. 14 6.1. Timing of Challenges. Any Party or Non-Party may challenge a 15 designation of confidentiality at any time that is consistent with the Court's 16 || Scheduling Order. 17 6.2. Meet_and Confer. The Challenging Party shall initiate the dispute 18 || resolution process under Local Rule 37.1 et seq. 19 6.3. The burden of persuasion in any such challenge proceeding shall be on 20 || the Designating Party. Frivolous challenges, and those made for an improper purpose 21 ||(e.g., to harass or impose unnecessary expenses and burdens on other parties) may 22 || expose the Challenging Party to sanctions. Unless the Designating Party has waived 23 □□ □□ withdrawn the confidentiality designation, all parties shall continue to afford the 24 || material in question the level of protection to which it is entitled under the Producing 25 || Party’s designation until the Court rules on the challenge. 26 6.4. Withdrawal of “CONFIDENTIAL” Designation. At its discretion, a 27 || Designating Party may remove Protected Material/Confidential Documents from 28 ||some or all of the protections and provisions of this Stipulation and its associated

1 || Order at any time by any of the following methods: 2 (a) Express Written Withdrawal. A Designating Party may withdraw a 3 ||“CONFIDENTIAL” designation made to any specified Protected Material 4 ||/Confidential Documents from some or all of the protections of this Stipulation and 5 ||its associated Order by an express withdrawal in a writing signed by such Party (or 6||such Party’s Counsel, but not including staff of such Counsel) that specifies and 7 ||itemizes the Disclosure or Discovery Material previously designated as Protected 8 || Material/Confidential Documents that shall no longer be subject to all or some of the 9 || provisions of this Stipulation and Order. Such express withdrawal shall be effective || when transmitted or served upon the Receiving Party. If a Designating Party is 2 11 || withdrawing Protected Material from only some of the provisions/ protections of this x 12 || Stipulation and Order, such Party must state which specific provisions are no longer 13 ||to be enforced as to the specified material for which confidentiality protection S$ 14||hereunder is withdrawn: otherwise, such withdrawal shall be construed as a 15 || withdrawal of such material from all of the protections/provisions of this Stipulation 16 || and Order; 17 (b) Express Withdrawal on the Record. A Designating Party may withdraw 18]}a “CONFIDENTIAL” designation made to any _ specified Protected 19 || Material/Confidential Documents from all of the provisions/protections of this 20 || Stipulation and its associated Order by verbally consenting in court proceedings on 21||the record to such withdrawal — provided that such withdrawal specifies the 22 ||Disclosure or Discovery Material previously designated as Protected Material/ 23 || Confidential Documents that shall no longer be subject to any of the provisions of this 24 || Stipulation and Order. A Designating Party 1s not permitted to withdraw Protected 25 || Material from only some of the protections/provisions of this Stipulation and Order 26 || by this method; 27 (c) Implicit Withdrawal by Publication or Failure to Oppose Challenge. A 28 || Designating Party shall be construed to have withdrawn a “CONFIDENTIAL”

1 || designation made to any specified Protected Material/Confidential Documents from 2 || all of the provisions/protections of this Stipulation and Order by either (1) making 3 ||such Protected Material/Confidential Records part of the public record — including 4||but not limited to attaching such as exhibits to any filing with the court without 5 || moving, prior to such filing, for the court to seal such records; or (2) failing to timely 6 || oppose a Challenging Party’s motion to remove a “CONFIDENTIAL” designation to 7 || specified Protected Material/Confidential Documents. Nothing in this Stipulation and 8||Order shall be construed so as to require any Party to file Protected 9 || Material/Confidential Documents under seal, unless expressly specified herein. 10||7. ACCESS TO AND USE OF PROTECTED MATERIAL. 2 11 7.1. Basic Principles. A Receiving Party may use Protected Material that is 12|/disclosed or produced by another Party or by a non-party in connection with this case 13 || only for preparing, prosecuting, defending, or attempting to settle this litigation — up to and including final disposition of the above-entitled action — and not for any other 15 || purpose, including any other litigation or dispute outside the scope of this action. 16 || Such Protected Material may be disclosed only to the categories of persons and under 17 || the conditions described in this Stipulation and its associated Order. When the above 18 || entitled litigation has been terminated, a Receiving Party must comply with the 19 || provisions of section 13, below (FINAL DISPOSITION). 20 Protected Material must be stored and maintained by a Receiving Party at a 21 ||location and in a secure manner that ensures that access is limited to the persons 22 || authorized under this Stipulation and its Order. 23 7.2. Disclosure of “CONFIDENTIAL” Information or Items. Unless 24 || otherwise ordered by the Court or permitted in writing by the Designating Party, a 25 || Receiving Party may disclose any information or item designated CONFIDENTIAL 26 || only to: 27 (a) the Receiving Party’s Outside Counsel of record in this action, as well 28 ||as employees of such Counsel to whom it is reasonably necessary to disclose the

1 || information for this litigation; 2 (b) the Receiving Party and the officers, directors, and employees (including 3 || House Counsel) of the Receiving Party to whom disclosure is reasonably necessary 4 || for this litigation — each of whom, by accepting receipt of such Protected Material, 5 || thereby agree to be bound by this Stipulation and Order; 6 (c) Experts (as defined in this Stipulation and Order) of the Receiving Party 7 ||to whom disclosure is reasonably necessary for this litigation — each of whom, by 8 ||accepting receipt of such Protected Material, thereby agree to be bound by this 9 || Stipulation and Order; 10 (d) court reporters, their staffs, and Professional Vendors to whom 2 11 || disclosure is reasonably necessary for this litigation — each of whom, by accepting x 12 || receipt of such Protected Material, thereby agree to be bound by this Stipulation and 13 || Order; S$ 14 (e) during their depositions, witnesses in the action to whom disclosure is 15||reasonably necessary — each of whom, by accepting receipt of such Protected Material, thereby agree to be bound by this Stipulation and Order. Pages of 17||transcribed deposition testimony or exhibits to depositions that reveal Protected 18 || Material must have a confidential designation affixed by the court reporter to such 19 || pages containing Protected Material and such may not be disclosed to anyone except 20 || as permitted under this Stipulation and its Protective Order. 21 (f) the author or custodian of a document containing the information that 22 || constitutes Protected Material, or other person who otherwise possessed or knew the 23 || information. 24 (g) any mediator or settlement officer, and their supporting personnel, 25 || mutually agreed upon by any of the parties engaged in settlement discussions. 26 7.3. Notice of Confidentiality. Prior to producing or disclosing Protected 27 || Material/Confidential Documents to persons to whom this Stipulation and its Order 28 permits disclosure or production (see section 8.2, supra), a Receiving Party shall

1 || provide a copy of this Stipulation and Order to such persons so as to put such persons 2 ||on notice as to the restrictions imposed upon them herein: except that, for court 3 ||reporters, Professional Vendors, and for witnesses being provided with Protected 4 || Material during a deposition, it shall be sufficient notice for Counsel for the Receiving 5 || Party to give the witness a verbal admonition (on the record, for witnesses) regarding 6 || the provisions of this Stipulation and its Order and such provisions’ applicability to 7 || specified Protected Material at issue. 8 7.4. Reservation of Rights. Nothing in this Stipulation and Order shall be 9 || construed so as to require any Producing Party to designate any records or materials 10 ||}as “CONFIDENTIAL.” Nothing in this Stipulation and Order shall be construed so 2 to prevent the admission of Protected Material into evidence at the trial of this x 12 || action, or in any appellate proceedings for this action, solely on the basis that such 13||Disclosure or Discovery Material has been designated as _ Protected 14 || Material/Confidential Documents. Notwithstanding the foregoing, nothing in this 15 || Stipulation and Order shall be construed as a waiver of any privileges or of any rights ||to object to the use or admission into evidence of any Protected Material in any 17 || proceeding; nor shall anything herein be construed as a concession that any privileges 18 || asserted or objections made are valid or applicable. Nothing in this Stipulation and || Order shall be construed so as to prevent the Designating Party (or its Counsel or 20 || custodian of records) from having access to and using Protected Material designated 21 || by that Party in the manner in which such persons or entities would typically use such 22 || materials in the normal course of their duties or profession — except that the waiver of 23 || confidentiality provisions shall apply (see section 6.4(c), supra). 24 7.5. Requirement to File Confidential Documents Under Seal. “Any party 25 ||seeking to file materials designated ‘CONFIDENTIAL’ must comply with Civil 26 || Local Rule 79-5. No document shall be filed under seal absent a court order granting 27 ||such relief upon a showing of compelling reasons (for merits-related filings) or good 28 || cause (for discovery materials). Designation alone does not justify sealing.” If any

1 || Receiving Party attaches any Confidential Documents to any pleading, motion, or 2 || other paper to be filed, lodged, or otherwise submitted to the Court, such Confidential 3 || Document(s) shall be filed/lodged under seal pursuant to Federal Rules of Civil 4|| Procedure 5.2 and 26 and/or United States District Court, Central District of 5 || California Local Rules 79-5.1 and 79-5.2 to the extent applicable. 6 7||8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER LITIGATION.

9 If a Party is served with a subpoena or a court order issued in other litigation 10||that compels disclosure of any information or items designated in this action as 11]/“CONFIDENTIAL,” that Party must: x 12 (a) promptly notify in writing the Designating Party, preferably (though not 13 || necessarily) by facsimile or electronic mail. Such notification shall include a copy of 14 || the subpoena or court order at issue; 15 (b) promptly notify in writing the party who caused the subpoena or order to 16 || issue in the other litigation that some or all of the material covered by the subpoena 17 || or order is subject to this Stipulation and its Protective Order. Such notification shall 18 || include a copy of this Stipulation and its Protective Order; and 19 (c) cooperate with respect to all reasonable procedures sought to be pursued 20 || by all sides in any such situation, while adhering to the terms of this Stipulation and 21 |}its Order. 22 If the Designating Party timely seeks a protective order, the Party served with 23 || the subpoena or court order shall not produce any information designated in this action 24 || as “CONFIDENTIAL” before a determination by the court from which the subpoena 25 || or order issued, unless the Party has obtained the Designating Party’s permission. The 26 || Designating Party shall bear the burden and expense of seeking protection in that court 27 || of its confidential material — and nothing in these provisions should be construed as 28 || authorizing or encouraging a Receiving Party in this action to disobey a lawful

1 || directive from another court. 2 The purpose of this section 1s to ensure that the affected Party has a meaningful 3 opportunity to preserve its confidentiality interests in the court from which the 4 || subpoena or court order issued. “Nothing in this section authorizes or requires a party 5 ||to disobey a lawful order of another court. The Receiving Party may comply with 6 ||such orders after providing notice and an opportunity to seek protection, as required 7 || by Rule 45.” 8/19. A NON-PARTY’S PROTECTED MATERIAL SOUGHT □□ □□ 9 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 © 3 remedies and relief provided by this Order. Nothing in these provisions should be 14 construed as prohibiting a Non-Party from seeking additional protections. < 15 (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 shall: (1) promptly notify in writing the Requesting Party and the Non-Party that some or all of the information requested is subject to a confidentiality agreement with a Non-Party; (2) promptly provide the Non-Party with a copy of the Stipulated Protective Order in this Action, the relevant discovery request(s), and a reasonably specific description of the information requested; and 25 (3) make the information requested available for inspection by the Non-Party, if requested. 38 (c) “Ifthe Non-Party fails to seek protection within 7 days of notice, the Receiving

1 || Party may produce the information. This timeframe is shortened to avoid undue delay 2 ||in discovery.” If the Non-Party timely seeks a protective order, the Receiving Party 3 || shall not produce any information in its possession or control that is subject to the 4 || confidentiality agreement with the Non-Party before a determination by the court. 5 || Absent a court order to the contrary, the Non-Party shall bear the burden and expense 6 || of seeking protection in this court of its Protected Material. 710. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL. 8 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 9 || Protected Material to any person or in any circumstance not authorized under this 10 || Stipulation and Order, the Receiving Party must immediately: 2 11 (a) notify in writing the Designating Party of the unauthorized disclosures; 2 (b) use its best efforts to retrieve all copies of the Protected Material; 13 (c) inform the person or persons to whom unauthorized disclosures were made Ss 14 || of all the terms of this Order; and 15 (d) request such person or persons consent to be bound by the Stipulation and 16 || Order. 17||11. Inadvertent Production of Privileged or Otherwise Protected Material. 18 When a Producing Party gives notice to Receiving Parties that certain 19 || inadvertently produced material is subject to a claim of privilege or other protection, 20 || the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 21 || Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 22 || may be established in an e-discovery order that provides for production without prior 23 || privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 24 || parties reach an agreement on the effect of disclosure of a communication or 25 || information covered by the attorney-client privilege or work product protection, the 26 || parties may incorporate their agreement in the stipulated protective order submitted 27 || to the court. 28

1|}12. MISCELLANEOUS 2 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 3 || person to seek its modification by the Court in the future. 4 12.2 Right to Assert Other Objections. By stipulating to the entry of this 5 || Protective Order no Party waives any right it otherwise would have to object to 6 || disclosing or producing any information or item on any ground not addressed in this 7 || Stipulated Protective Order. Similarly, no Party waives any right to object on any 8 || ground to use in evidence of any of the material covered by this Protective Order. 9 12.3 Filing Protected Material. A Party that seeks to file under seal any 10 || Protected Material must comply with Civil Local Rule 79-5. Protected Material may 2 11 || only be filed under seal pursuant to a court order authorizing the sealing of the specific x 12 || Protected Material at issue. If a Party's request to file Protected Material under seal is 13 || denied by the court, then the Receiving Party may file the information in the public S$ 14 || record unless otherwise instructed by the court. 15|}13. FINAL DISPOSITION. 16 “Unless otherwise ordered, within 60 days after termination of this action each 17 || Receiving Party must return or destroy Protected Material, except that counsel may 18 || retain archival copies of pleadings, exhibits, deposition transcripts, correspondence, 19||and attorney work product as required by the California Rules of Professional 20 || Conduct and federal law. Such archival materials remain subject to this Order.” 21 As used in this subdivision, “all Protected Material” includes all copies, 22 || abstracts, compilations, summaries or any other form of reproducing or capturing any 23 ||of the Protected Material, regardless of the medium (hardcopy, electronic, or 24 || otherwise) in which such Protected Material is stored or retained. 25 In the alternative, at the discretion of the Receiving Party, the Receiving Party 26 || may destroy some or all of the Protected Material instead of returning it — unless such 27 || Protected Material is an original, in which case, the Receiving Party must obtain the 28 || Producing Party’s written consent before destroying such original Protected Material.

1 Whether the Protected Material is returned or destroyed, the Receiving Party 2 || must submit a written certification to the Producing Party (and, if not the same person 3 |/or entity, to the Designating Party) within sixty (60) days of the aforementioned || written request by the Designating Party that specifically identifies (by category, 5 || where appropriate) all the Protected Material that was returned or destroyed and that 6 || affirms that the Receiving Party has not retained any copies, abstracts, compilations, 7 ||summaries or other forms of reproducing or capturing any of the Protected material 8 || (Gn any medium, including but not limited to any hardcopy, electronic or digital copy, 9 || or otherwise). 10 Notwithstanding this provision, Counsel are entitled to retain an archival copy 2 11 || of all pleadings, motion papers, transcripts, legal memoranda filed with the court in x 12 ||this action, as well as any correspondence or attorney work product prepared by 13 || Counsel for the Receiving Party, even if such materials contain Protected Material; S$ 14 || however, any such archival copies that contain or constitute Protected Material remain 15 || subject to this Protective Order as set forth in Section 4 (DURATION), above. 16 “Any violation of this Order may be addressed by the Court in accordance with 17 || the Federal Rules of Civil Procedure, the Court’s inherent authority, and applicable 18 || law. Sanctions, if any, shall be limited to those authorized under FRCP 37 and related 19 || authority.” 20 21 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. || DATED: August 13, 2025 MANNING & KASS 73 ELLROD, RAMIREZ, TRESTER LLP By: /s/ Kayleigh A. Andersen 5 Eugene P. Ramirez Eugene P. Hanrahan 26 Kayleigh A. Andersen 07 Attorneys for Defendants SHERIFF CHAD BIANCO, et al. 28

1 |}; DATED: August 13, 2025 KHASHAN LAW FIRM, APC 2 By: /s/ Lewis G. Khashan 3 Lewis G. Khashan 4 Attorneys for Plaintiffs 5 6 7 9 10 < 11 — 12 2 13 S 14 Ss 16

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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] inthe caseof Dezarae Munoz, et al. v. 8 || County of Riverside, et al., Case No. 5:23-cv-02063-JGB-DTB. I agree to comply 9 || with and to be bound by all the terms of this Stipulated Protective Order and I 10 || understand and acknowledge that failure to so comply could expose me to sanctions 2 11 || and punishment in the nature of contempt. I solemnly promise that I will not disclose x 12 ||in any manner any information or item that is subject to this Stipulated Protective 13 || Order to any person or entity except in strict compliance with the provisions of this S$ 14 || 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

2 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 3 4 DATED: August 27, 2025 5

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8||HON.DAVIDT.BRISTOW ————CS 9 United States Magistrate Judge 10 11

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