1 2 Nathan A. Oyster (SBN 225307) E-mail: [email protected] 3 Caylin W. Jones (SBN 327829) E-mail: [email protected] 4 BURKE, WILLIAMS & SORENSEN, LLP 444 South Flower Street, 40th Floor 5 Los Angeles, California 90071-2942 Tel: 213.236.0600 Fax: 213.236.2700 6 Attorneys for Defendants, 7 COUNTY OF RIVERSIDE and JULIO OLGUIN 8 9 UNITED STATES DISTRICT COURT 10 CENTRAL DISTRICT OF CALIFORNIA 11 12 KENNETH SOTO, individually and as Case No. 5:25-cv-00182-CAS-DTBx successor in interest to Decedent [5:25-cv-00874-CAS-SHKx] 13 Kenneth Soto, 14 Plaintiff, STIPULATED PROTECTIVE 15 v. ORDER 16 COUNTY OF RIVERSIDE; and DOES 1 through 100, inclusive, Judge: Christina A. Snyder 17 Defendant. 18 19 ANDREA SOTO, individually and as successor in interest to Decedent 20 Kenneth Andrew Soto, 21 Plaintiff, 22 v. 23 COUNTY OF RIVERSIDE, JULIO OLGUIN and DOES 1 through 10, 24 inclusive, 25 Defendants. 26 27 1 TO THE HONORABLE COURT: 2 Plaintiffs KENNETH SOTO and ANDREA SOTO, (hereinafter referred to as 3 “Plaintiffs”) and Defendants COUNTY OF RIVERSIDE and JULIO OLGUIN 4 (hereinafter referred to collectively as “Defendants”) hereby stipulate for the purpose 5 of jointly requesting that the honorable Court enter a protective order as follows: 6 1. A. PURPOSES AND LIMITATIONS 7 Discovery in this action is likely to involve production of confidential, 8 proprietary, or private information for which special protection from public disclosure 9 and from use for any purpose other than prosecuting this litigation may be warranted. 10 Accordingly, the parties hereby stipulate to and petition the Court to enter the 11 following Stipulated Protective Order. The parties acknowledge that this Order does 12 not confer blanket protections on all disclosures or responses to discovery and that 13 the protection it affords from public disclosure and use extends only to the limited 14 information or items that are entitled to confidential treatment under the applicable 15 legal principles. The parties further acknowledge, as set forth in Section 12.3, below, 16 that this Stipulated Protective Order does not entitle them to file confidential 17 information under seal; Civil Local Rule 79-5 sets forth the procedures that must be 18 followed and the standards that will be applied when a party seeks permission from 19 the court to file material under seal. 20 B. GOOD CAUSE STATEMENT 21 This action relates to the officer involved shooting of Kenneth Soto. The parties 22 submit that good cause exists to enter the proposed protective order to balance 23 Defendant’s concern regarding the investigation into the shooting, autopsy 24 photographs, and concerns regarding witnesses’ identities. Further, confidential 25 medical records regarding the decedent are likely to be subpoenaed and/or produced 26 during the course of litigation. 27 2. DEFINITIONS 2.1. Action: this pending federal law suit Kenneth Soto v. County of Riverside, 1 case number 5:25-cv-00182-CAS-SHK, consolidated with Andrea Soto v. County of 2 Riverside 5:25-cv-00874-CAS-SHK. 3 2.2. Challenging Party: a Party or Non-Party that challenges the designation 4 of information or items under this Order. 5 2.3. “CONFIDENTIAL” Information or Items: information (regardless of 6 how it is generated, stored or maintained) or tangible things that qualify for protection 7 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 8 Cause Statement. 9 2.4. Counsel: Outside Counsel of Record and House Counsel (as well as their 10 support staff). 11 2.5. Designating Party: a Party or Non-Party that designates information or 12 items that it produces in disclosures or in responses to discovery as 13 “CONFIDENTIAL.” 14 2.6. Disclosure or Discovery Material: all items or information, regardless 15 of the medium or manner in which it is generated, stored, or maintained (including, 16 among other things, testimony, transcripts, and tangible things), that are produced or 17 generated in disclosures or responses to discovery in this matter. 18 2.7. Expert: a person with specialized knowledge or experience in a matter 19 pertinent to the litigation who has been retained by a Party or its counsel to serve as 20 an expert witness or as a consultant in this Action. 21 2.8. House Counsel: attorneys who are employees of a party to this Action. 22 House Counsel does not include Outside Counsel of Record or any other outside 23 counsel. 24 2.9. Non-Party: any natural person, partnership, corporation, association, or 25 other legal entity not named as a Party to this action. 26 2.10. Outside Counsel of Record: attorneys who are not employees of a party 27 to this Action but are retained to represent or advise a party to this Action and have appeared in this Action on behalf of that party or are affiliated with a law firm which 1 has appeared on behalf of that party, and includes support staff. 2 2.11. Party: any party to this Action, including all of its officers, directors, 3 employees, consultants, retained experts, and Outside Counsel of Record (and their 4 support staffs). 5 2.12. Producing Party: a Party or Non-Party that produces Disclosure or 6 Discovery Material in this Action. 7 2.13. Professional Vendors: persons or entities that provide litigation support 8 services (e.g., photocopying, videotaping, translating, preparing exhibits or 9 demonstrations, and organizing, storing, or retrieving data in any form or medium) 10 and their employees and subcontractors. 11 2.14. Protected Material: any Disclosure or Discovery Material that is 12 designated as “CONFIDENTIAL.” 13 2.15. Receiving Party: a Party that receives Disclosure or Discovery Material 14 from a Producing Party. 15 3. SCOPE 16 The protections conferred by this Stipulation and Order cover not only 17 Protected Material (as defined above), but also (1) any information copied or extracted 18 from Protected Material; (2) all copies, excerpts, summaries, or compilations of 19 Protected Material; and (3) any testimony, conversations, or presentations by Parties 20 or their Counsel that might reveal Protected Material. 21 Any use of Protected Material at trial shall be governed by the orders of the 22 trial judge. This Order does not govern the use of Protected Material at trial. 23 4. DURATION 24 Once a case proceeds to trial, all of the information that was designated as 25 confidential or maintained pursuant to this protective order becomes public and 26 will be presumptively available to all members of the public, including the press, 27 unless compelling reasons supported by specific factual findings to proceed otherwise are made to the trial judge in advance of the trial. See Kamakana v. City 1 and County of Honolulu,

, 1180-81 (9th Cir. 2006) (distinguishing 2 “good cause” showing for sealing documents produced in discovery from “compelling 3 reasons” standard when merits-related documents are part of court record). 4 Accordingly, the terms of this protective order do not extend beyond the 5 commencement of the trial. 6 5. DESIGNATING PROTECTED MATERIAL 7 5.1. Exercise of Restraint and Care in Designating Material for Protection. 8 Each Party or Non-Party that designates information or items for protection 9 under this Order must take care to limit any such designation to specific material that 10 qualifies under the appropriate standards. The Designating Party must designate for 11 protection only those parts of material, documents, items, or oral or written 12 communications that qualify so that other portions of the material, documents, items, 13 or communications for which protection is not warranted are not swept unjustifiably 14 within the ambit of this Order. 15 Mass, indiscriminate, or routinized designations are prohibited. Designations 16 that are shown to be clearly unjustified or that have been made for an improper 17 purpose (e.g., to unnecessarily encumber the case development process or to impose 18 unnecessary expenses and burdens on other parties) may expose the Designating Party 19 to sanctions. 20 If it comes to a Designating Party’s attention that information or items that it 21 designated for protection do not qualify for protection, that Designating Party must 22 promptly notify all other Parties that it is withdrawing the inapplicable designation. 23 5.2. Manner and Timing of Designations. Except as otherwise provided in 24 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 25 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 26 under this Order must be clearly so designated before the material is disclosed or 27 produced. Designation in conformity with this Order requires: 1 (a) for information in documentary form (e.g., paper or electronic 2 documents, but excluding transcripts of depositions or other pretrial or trial 3 proceedings), that the Producing Party affix at a minimum, the legend 4 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 5 contains protected material. If only a portion or portions of the material on a page 6 qualifies for protection, the Producing Party also must clearly identify the protected 7 portion(s) (e.g., by making appropriate markings in the margins). 8 A Party or Non-Party that makes original documents available for inspection 9 need not designate them for protection until after the inspecting Party has indicated 10 which documents it would like copied and produced. During the inspection and before 11 the designation, all of the material made available for inspection shall be deemed 12 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 13 copied and produced, the Producing Party must determine which documents, or 14 portions thereof, qualify for protection under this Order. Then, before producing the 15 specified documents, the Producing Party must affix the “CONFIDENTIAL legend” 16 to each page that contains Protected Material. If only a portion or portions of the 17 material on a page qualifies for protection, the Producing Party also must clearly 18 identify the protected portion(s) (e.g., by making appropriate markings in the 19 margins). 20 (b) for testimony given in depositions that the Designating Party identify the 21 Disclosure or Discovery Material on the record, before the close of the deposition all 22 protected testimony. 23 (c) for information produced in some form other than documentary and for 24 any other tangible items, that the Producing Party affix in a prominent place on the 25 exterior of the container or containers in which the information is stored the legend 26 “CONFIDENTIAL.” If only a portion or portions of the information warrants 27 protection, the Producing Party, to the extent practicable, shall identify the protected portion(s). 1 5.3 Inadvertent Failure to Designate. If timely corrected, an inadvertent 2 failure to designate qualified information or items does not, standing alone, waive the 3 Designating Party’s right to secure protection under this Order for such material. 4 Upon timely correction of a designation, the Receiving Party must make reasonable 5 efforts to assure that the material is treated in accordance with the provisions of this 6 Order. 7 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 8 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 9 designation of confidentiality at any time that is consistent with the Court’s 10 Scheduling Order. 11 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 12 resolution process under Local Rule 37.1 et seq. 13 6.3 The burden of persuasion in any such challenge proceeding shall be on 14 the Designating Party. Frivolous challenges, and those made for an improper purpose 15 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 16 expose the Challenging Party to sanctions. Unless the Designating Party has waived 17 or withdrawn the confidentiality designation, all parties shall continue to afford the 18 material in question the level of protection to which it is entitled under the Producing 19 Party’s designation until the Court rules on the challenge. 20 7. ACCESS TO AND USE OF PROTECTED MATERIAL 21 7.1 Basic Principles. A Receiving Party may use Protected Material that is 22 disclosed or produced by another Party or by a Non-Party in connection with this 23 Action only for prosecuting, defending, or attempting to settle this Action. Such 24 Protected Material may be disclosed only to the categories of persons and under the 25 conditions described in this Order. When the Action has been terminated, a Receiving 26 Party must comply with the provisions of section 13 below (FINAL DISPOSITION). 27 Protected Material must be stored and maintained by a Receiving Party at a location and in a secure manner that ensures that access is limited to the persons 1 authorized under this Order. 2 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 3 otherwise ordered by the court or permitted in writing by the Designating Party, a 4 Receiving Party may disclose any information or item designated 5 “CONFIDENTIAL” only to: 6 (a) the Receiving Party’s Outside Counsel of Record in this Action, 7 as well as employees of said Outside Counsel of Record to whom it is reasonably 8 necessary to disclose the information for this Action; 9 (b) the officers, directors, and employees (including House Counsel) 10 of the Receiving Party to whom disclosure is reasonably necessary for this Action; 11 (c) Experts (as defined in this Order) of the Receiving Party to whom 12 disclosure is reasonably necessary for this Action and who have signed the 13 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 14 (d) the court and its personnel; 15 (e) court reporters and their staff; 16 (f) professional jury or trial consultants, mock jurors, and 17 Professional Vendors to whom disclosure is reasonably necessary for this Action and 18 who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 19 (g) the author or recipient of a document containing the information 20 or a custodian or other person who otherwise possessed or knew the information; 21 (h) During their depositions, witnesses ,and attorneys for witnesses, 22 in the Action to whom disclosure is reasonably necessary provided: (1) the deposing 23 party requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they 24 will not be permitted to keep any confidential information unless they sign the 25 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 26 agreed by the Designating Party or ordered by the court. Pages of transcribed 27 deposition testimony or exhibits to depositions that reveal Protected Material may be separately bound by the court reporter and may not be disclosed to anyone except as 1 permitted under this Stipulated Protective Order; and 2 (i) any mediator or settlement officer, and their supporting personnel, 3 mutually agreed upon by any of the parties engaged in settlement discussions. 4 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 5 OTHER LITIGATION 6 If a Party is served with a subpoena or a court order issued in other litigation 7 that compels disclosure of any information or items designated in this Action as 8 “CONFIDENTIAL,” that Party must: 9 (a) promptly notify in writing the Designating Party. Such notification shall 10 include a copy of the subpoena or court order; 11 (b) promptly notify in writing the party who caused the subpoena or order to 12 issue in the other litigation that some or all of the material covered by the subpoena 13 or order is subject to this Protective Order. Such notification shall include a copy of 14 this Stipulated Protective Order; and 15 (c) cooperate with respect to all reasonable procedures sought to be pursued 16 by the Designating Party whose Protected Material may be affected. 17 If the Designating Party timely seeks a protective order, the Party served with 18 the subpoena or court order shall not produce any information designated in this action 19 as “CONFIDENTIAL” before a determination by the court from which the subpoena 20 or order issued, unless the Party has obtained the Designating Party’s permission. The 21 Designating Party shall bear the burden and expense of seeking protection in that court 22 of its confidential material and nothing in these provisions should be construed as 23 authorizing or encouraging a Receiving Party in this Action to disobey a lawful 24 directive from another court. 25 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 26 PRODUCED IN THIS LITIGATION 27 (a) The terms of this Order are applicable to information produced by a Non- Party in this Action and designated as “CONFIDENTIAL.” Such information 1 produced by Non-Parties in connection with this litigation is protected by the 2 remedies and relief provided by this Order. Nothing in these provisions should be 3 construed as prohibiting a Non-Party from seeking additional protections. 4 (b) In the event that a Party is required, by a valid discovery request, to 5 produce a Non-Party’s confidential information in its possession, and the Party is 6 subject to an agreement with the Non-Party not to produce the Non-Party’s 7 confidential information, then the Party shall: 8 (1) promptly notify in writing the Requesting Party and the Non-Party 9 that some or all of the information requested is subject to a confidentiality agreement 10 with a Non-Party; 11 (2) promptly provide the Non-Party with a copy of the Stipulated 12 Protective Order in this Action, the relevant discovery request(s), and a reasonably 13 specific description of the information requested; and 14 (3) make the information requested available for inspection by the 15 Non-Party, if requested. 16 (c) If the Non-Party fails to seek a protective order from this court within 14 17 days of receiving the notice and accompanying information, the Receiving Party may 18 produce the Non-Party’s confidential information responsive to the discovery request. 19 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce 20 any information in its possession or control that is subject to the confidentiality 21 agreement with the Non-Party before a determination by the court. Absent a court 22 order to the contrary, the Non-Party shall bear the burden and expense of seeking 23 protection in this court of its Protected Material. 24 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 25 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 26 Protected Material to any person or in any circumstance not authorized under this 27 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 1 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 2 persons to whom unauthorized disclosures were made of all the terms of this Order, 3 and (d) request such person or persons to execute the “Acknowledgment and 4 Agreement to Be Bound” that is attached hereto as Exhibit A. 5 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 6 PROTECTED MATERIAL 7 When a Producing Party gives notice to Receiving Parties that certain 8 inadvertently produced material is subject to a claim of privilege or other protection, 9 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 10 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 11 may be established in an e-discovery order that provides for production without prior 12 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 13 parties reach an agreement on the effect of disclosure of a communication or 14 information covered by the attorney-client privilege or work product protection, the 15 parties may incorporate their agreement in the stipulated protective order submitted 16 to the court. 17 12. MISCELLANEOUS 18 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 19 person to seek its modification by the Court in the future. 20 12.2 Right to Assert Other Objections. By stipulating to the entry of this 21 Protective Order no Party waives any right it otherwise would have to object to 22 disclosing or producing any information or item on any ground not addressed in this 23 Stipulated Protective Order. Similarly, no Party waives any right to object on any 24 ground to use in evidence of any of the material covered by this Protective Order. 25 12.3 Filing Protected Material. A Party that seeks to file under seal any 26 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 27 only be filed under seal pursuant to a court order authorizing the sealing of the specific Protected Material at issue. If a Party's request to file Protected Material under seal is 1 denied by the court, then the Receiving Party may file the information in the public 2 record unless otherwise instructed by the court. 3 13. FINAL DISPOSITION 4 After the final disposition of this Action, as defined in paragraph 4, within 60 5 days of a written request by the Designating Party, each Receiving Party must return 6 all Protected Material to the Producing Party or destroy such material. As used in this 7 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 8 summaries, and any other format reproducing or capturing any of the Protected 9 Material. Whether the Protected Material is returned or destroyed, the Receiving Party 10 must submit a written certification to the Producing Party (and, if not the same person 11 or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by 12 category, where appropriate) all the Protected Material that was returned or destroyed 13 and (2)affirms that the Receiving Party has not retained any copies, abstracts, 14 compilations, summaries or any other format reproducing or capturing any of the 15 Protected Material. Notwithstanding this provision, Counsel are entitled to retain an 16 archival copy of all pleadings, motion papers, trial, deposition, and hearing 17 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 18 reports, attorney work product, and consultant and expert work product, even if such 19 materials contain Protected Material. Any such archival copies that contain or 20 constitute Protected Material remain subject to this Protective Order as set forth in 21 Section 4 (DURATION). 22 14. Any violation of this Order may be punished by any and all appropriate 23 measures including, without limitation, contempt proceedings and/or monetary 24 sanctions. 25 26 27 1 IT IS SO STIPULATED 2 || Dated: September 3, 2025 BURKE, WILLIAMS & SORENSEN, LLP 3 4 5 By: /s/ Caylin W. Jones Nathan A. Oyster 6 Caylin W. Jones 7 Attorneys for Defendants COUNTY OF RIVERSIDE and JULIO OLGUIN 9 19|| Dated: September 3, 2025 LAW OFFICE OF GREGORY PEACOCK

11 12 By: /s/ Gregory Peacock 13 Gregory Peacock 14 Attorney for Plaintiff KENNETH SOTO 15 16 Dated: September 3, 2025 LAW OFFICES OF JERRY L. STEERING

18 19 By: /s/ Jerry Steering 20 Jerry Steering 21 Attorney for Plaintiff ANDREA SOTO 22 23 94 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 25 Dated: September 9, 2025 / fe 26 HONORABL¥ DAVID T. BRISTOW United States Magistrate Judge 28 E, WILLIAMS &

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 6 of perjury that I have read in its entirety and understand the Stipulated Protective 7 Order that was issued by the United States District Court for the Central District of 8 California on ____________ in the case of Kenneth Soto v. County of Riverside, et 9 al. Case No. 5:25-cv-00182-CAS-SHK, consolidated with Andrea Soto v. County of 10 Riverside, et al. 5:25-cv-00874-CAS-SHK. I agree to comply with and to be bound 11 by all the terms of this Stipulated Protective Order and I understand and 12 acknowledge that failure to so comply could expose me to sanctions and punishment 13 in the nature of contempt. I solemnly promise that I will not disclose in any manner 14 any information or item that is subject to this Stipulated Protective Order to any 15 person or entity except in strict compliance with the provisions of this Order. 16 I further agree to submit to the jurisdiction of the United States District Court 17 for the Central District of California for the purpose of enforcing the terms of this 18 Stipulated Protective Order, even if such enforcement proceedings occur after 19 termination of this action. I hereby appoint __________________________ [print or 20 type full name] of _______________________________________ [print or type 21 full address and telephone number] as my California agent for service of process in 22 connection with this action or any proceedings related to enforcement of this 23 Stipulated Protective Order. 24 Date: 25 City and State where sworn and signed: 26 Printed Name: 27 Signature: