1 JILL WILLIAMS - State Bar No. 221793 KIMBERLY SARMIENTO – State Bar No. 345641 2 CARPENTER, ROTHANS & DUMONT LLP 500 South Grand Avenue, 19th Floor 3 Los Angeles, California 90071 (213) 228-0400 / (213) 228-0401 (Fax) 4 [email protected] / [email protected]

5 Attorneys for Defendants, County of Los Angeles and 6 Deputy Aram Derderian 7 8 UNITED STATES DISTRICT COURT

9 CENTRAL DISTRICT OF CALIFORNIA 10

11 WESTLEY HENSON, individually ) Case No. 2:24-CV-08883 JLS (AJRx) and as successor-in-interest to ) 12 Joseph Henson; RHONDA ANN ) SMITH, individually and as ) STIPULATED PROTECTIVE ORDER 13 successor-in-interest to Joseph ) Henson, ) 14 ) Plaintiff, ) 15 ) v. ) 16 ) COUNTY OF LOS ANGELES, a ) 17 public entity; ARAM ) DERDERIAN, an individual; and ) 18 Does 1-20 inclusive, ) ) 19 ) Defendants. ) 20 ) 21 1. GENERAL 22 1.1 Purposes and Limitations. Discovery in this action is likely to involve 23 production of confidential, proprietary, or private information for which special 24 protection from public disclosure and from use for any purpose other than 25 prosecuting this litigation may be warranted. Accordingly, the parties hereby 26 stipulate to and petition the Court to enter the following Stipulated Protective Order. 27 The parties acknowledge that this Order does not confer blanket protections on all 28 1 disclosures or responses to discovery and that the protection it affords from public 2 disclosure and use extends only to the limited information or items that are entitled 3 to confidential treatment under the applicable legal principles. The parties further 4 acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective 5 Order does not entitle them to file confidential information under seal; Civil Local 6 Rule 79-5 sets forth the procedures that must be followed and the standards that will 7 be applied when a party seeks permission from the court to file material under seal. 8 1.2 Good Cause Statement. 9 This action is likely to involve law enforcement investigatory materials, 10 including information derived from the confidential personnel files of sworn peace 11 officers, for which special protection from public disclosure and from use for any 12 purpose other than prosecution of this action is warranted. Such confidential and 13 proprietary materials and information consist of, among other things, law 14 enforcement records and other information otherwise generally unavailable to the 15 public, or which may be privileged or otherwise protected from disclosure under 16 state or federal statutes, court rules, case decisions, or common law. Accordingly, 17 to expedite the flow of information, to facilitate the prompt resolution of disputes 18 over confidentiality of discovery materials, to adequately protect information the 19 parties are entitled to keep confidential, to ensure that the parties are permitted 20 reasonable necessary uses of such material in preparation for and in the conduct of 21 trial, to address their handling at the end of the litigation, and serve the ends of 22 justice, a protective order for such information is justified in this matter. It is the 23 intent of the parties that information will not be designated as confidential for tactical 24 reasons and that nothing be so designated without a good faith belief that it has been 25 maintained in a confidential, non-public manner, and there is good cause why it 26 should not be part of the public record of this case. 27 2. DEFINITIONS 28 1 2.1 Action: Westley Henson v. County of Los Angeles, et al., Case No. 2 2:24-CV-08883 JLS (AJRx) 3 2.2 Challenging Party: a Party or Non-Party that challenges the 4 designation 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 7 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 8 the Good Cause Statement. 9 2.4 Counsel: Outside Counsel of Record and County Counsel (as well as 10 their 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 17 or 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 County Counsel: attorneys who are employees of a party to this Action. 22 County 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, 25 or 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 28 1 appeared in this Action on behalf of that party or are affiliated with a law firm that 2 has appeared on behalf of that party, including support staff. 3 2.11 Party: any party to this Action, including all of its officers, directors, 4 employees, consultants, retained experts, and Outside Counsel of Record (and their 5 support staffs). 6 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 7 Discovery Material in this Action. 8 2.13 Professional Vendors: persons or entities that provide litigation 9 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 10 demonstrations, and organizing, storing, or retrieving data in any form or medium) 11 and their employees and subcontractors. 12 2.14 Protected Material: any Disclosure or Discovery Material that is 13 designated as “CONFIDENTIAL.” 14 2.15 Receiving Party: a Party that receives Disclosure or Discovery 15 Material from a Producing Party. 16 17 3. SCOPE 18 The protections conferred by this Stipulation and Order cover not only 19 Protected Material (as defined above), but also (1) any information copied or 20 extracted from Protected Material; (2) all copies, excerpts, summaries, or 21 compilations of Protected Material; and (3) any testimony, conversations, or 22 presentations by Parties or their Counsel that might reveal Protected Material. 23 Any use of Protected Material at trial shall be governed by the orders of the 24 trial judge. This Order does not govern the use of Protected Material at trial. 25 26 4. DURATION 27 Once a case proceeds to trial, all of the court-filed information to be 28 1 introduced that was previously designated as confidential or maintained pursuant to 2 this protective order becomes public and will be presumptively available to all 3 members of the public, including the press, unless compelling reasons supported by 4 specific factual findings to proceed otherwise are made to the trial judge in advance 5 of the trial. See Kamakana v. City and Cty. of Honolulu,

, 1180-81 6 (9th Cir. 2006) (distinguishing “good cause” showing for sealing documents 7 produced in discovery from “compelling reasons” standard when merits-related 8 documents are part of court record). Accordingly, the terms of this protective order 9 do not extend beyond the commencement of the trial. 10 11 5. DESIGNATING PROTECTED MATERIAL 12 5.1 Exercise of Restraint and Care in Designating Material for Protection. 13 Each Party or Non-Party that designates information or items for protection under 14 this Order must take care to limit any such designation to specific material that 15 qualifies under the appropriate standards. The Designating Party must designate for 16 protection only those parts of material, documents, items, or oral or written 17 communications that qualify so that other portions of the material, documents, items, 18 or communications for which protection is not warranted are not swept unjustifiably 19 within the ambit of this Order. 20 Mass, indiscriminate, or routinized designations are prohibited. Designations 21 that are shown to be clearly unjustified or that have been made for an improper 22 purpose (e.g., to unnecessarily encumber the case development process or to impose 23 unnecessary expenses and burdens on other parties) may expose the Designating 24 Party to sanctions. 25 If it comes to a Designating Party’s attention that information or items that it 26 designated for protection do not qualify for protection, that Designating Party must 27 promptly notify all other Parties that it is withdrawing the inapplicable designation. 28 1 5.2 Manner and Timing of Designations. Except as otherwise provided in 2 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 3 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 4 under this Order must be clearly so designated before the material is disclosed or 5 produced. 6 Designation in conformity with this Order requires: 7 (a) for information in documentary form (e.g., paper or electronic 8 documents, but excluding transcripts of depositions or other pretrial or trial 9 proceedings), that the Producing Party affix, at a minimum, the legend 10 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 11 contains protected material. If only a portion or portions of the material on a page 12 qualifies for protection, the Producing Party also must clearly identify the protected 13 portion(s) (e.g., by making appropriate markings in the margins). 14 A Party or Non-Party that makes original documents available for inspection 15 need not designate them for protection until after the inspecting Party has indicated 16 which documents it would like copied and produced. During the inspection and 17 before the designation, all of the material made available for inspection shall be 18 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 19 documents it wants copied and produced, the Producing Party must determine which 20 documents, or portions thereof, qualify for protection under this Order. Then, before 21 producing the specified documents, the Producing Party must affix the 22 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 23 portion or portions of the material on a page qualifies for protection, the Producing 24 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 25 markings in the margins). 26 27 28 1 (b) for testimony given in depositions that the Designating Party 2 identify the Disclosure or Discovery Material on the record, before the close of the 3 deposition. 4 (c) for information produced in some form other than documentary and 5 for any other tangible items, that the Producing Party affix in a prominent place on 6 the exterior of the container or containers in which the information is stored the 7 legend “CONFIDENTIAL.” If only a portion or portions of the information 8 warrants protection, the Producing Party, to the extent practicable, shall identify the 9 protected portion(s). 10 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 11 failure to designate qualified information or items does not, standing alone, waive 12 the Designating Party’s right to secure protection under this Order for such material. 13 Upon timely correction of a designation, the Receiving Party must make reasonable 14 efforts to assure that the material is treated in accordance with the provisions of this 15 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. Any discovery motion must 23 strictly comply with the procedures set forth in Local Rules 37-1, 37-2, and 37-3. 24 6.3 Burden. The burden of persuasion in any such challenge proceeding 25 shall be on the Designating Party. Frivolous challenges, and those made for an 26 improper purpose (e.g., to harass or impose unnecessary expenses and burdens on 27 other parties) may expose the Challenging Party to sanctions. Unless the 28 1 Designating Party has waived or withdrawn the confidentiality designation, all 2 parties shall continue to afford the material in question the level of protection to 3 which it is entitled under the Producing Party’s designation until the Court rules on 4 the challenge. 5 7. ACCESS TO AND USE OF PROTECTED MATERIAL 6 7.1 Basic Principles. A Receiving Party may use Protected Material that is 7 disclosed or produced by another Party or by a Non-Party in connection with this 8 Action only for prosecuting, defending, or attempting to settle this Action. Such 9 Protected Material may be disclosed only to the categories of persons and under the 10 conditions described in this Order. When the Action has been terminated, a 11 Receiving Party must comply with the provisions of section 13 below (FINAL 12 DISPOSITION). 13 Protected Material must be stored and maintained by a Receiving Party at a 14 location and in a secure manner that ensures that access is limited to the persons 15 authorized under this Order. 16 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 17 otherwise ordered by the Court or permitted in writing by the Designating Party, a 18 Receiving Party may disclose any information or item designated 19 “CONFIDENTIAL” only to: 20 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 21 well as employees of said Outside Counsel of Record to whom it is reasonably 22 necessary to disclose the information for this Action; 23 (b) the officers, directors, and employees (including House Counsel) 24 of the Receiving Party to whom disclosure is reasonably necessary for this Action; 25 (c) Experts (as defined in this Order) of the Receiving Party to whom 26 disclosure is reasonably necessary for this Action and who have signed the 27 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 28 1 (d) the Court and its personnel; 2 (e) court reporters and their staff; 3 (f) professional jury or trial consultants, mock jurors, and Professional 4 Vendors to whom disclosure is reasonably necessary for this Action and who have 5 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 6 (g) the author or recipient of a document containing the information or 7 a custodian or other person who otherwise possessed or knew the information; 8 (h) during their depositions, witnesses, and attorneys for witnesses, in 9 the Action to whom disclosure is reasonably necessary provided: (1) the deposing 10 party requests that the witness sign the form attached as Exhibit A hereto; and (2) 11 they will not be permitted to keep any confidential information unless they sign the 12 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 13 agreed by the Designating Party or ordered by the Court. Pages of transcribed 14 deposition testimony or exhibits to depositions that reveal Protected Material may 15 be separately bound by the court reporter and may not be disclosed to anyone except 16 as permitted under this Stipulated Protective Order; and 17 (i) any mediator or settlement officer, and their supporting personnel, 18 mutually agreed upon by any of the parties engaged in settlement discussions. 19 20 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 21 PRODUCED IN OTHER LITIGATION 22 If a Party is served with a subpoena or a court order issued in other litigation 23 that compels disclosure of any information or items designated in this Action as 24 “CONFIDENTIAL,” that Party must: 25 (a) promptly notify in writing the Designating Party. Such notification shall 26 include a copy of the subpoena or court order; 27 28 1 (b) promptly notify in writing the party who caused the subpoena or order to 2 issue in the other litigation that some or all of the material covered by the subpoena 3 or order is subject to this Protective Order. Such notification shall include a copy of 4 this Stipulated Protective Order; and 5 (c) cooperate with respect to all reasonable procedures sought to be pursued 6 by the Designating Party whose Protected Material may be affected. 7 If the Designating Party timely seeks a protective order, the Party served with 8 the subpoena or court order shall not produce any information designated in this 9 action as “CONFIDENTIAL” before a determination by the court from which the 10 subpoena or order issued, unless the Party has obtained the Designating Party’s 11 permission. The Designating Party shall bear the burden and expense of seeking 12 protection in that court of its confidential material and nothing in these provisions 13 should be construed as authorizing or encouraging a Receiving Party in this Action 14 to disobey a lawful directive from another court. 15 16 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 17 PRODUCED IN THIS LITIGATION 18 (a) The terms of this Order are applicable to information produced by a Non- 19 Party in this Action and designated as “CONFIDENTIAL.” Such information 20 produced by Non-Parties in connection with this litigation is protected by the 21 remedies and relief provided by this Order. Nothing in these provisions should be 22 construed as prohibiting a Non-Party from seeking additional protections. 23 (b) In the event that a Party is required, by a valid discovery request, to 24 produce a Non-Party’s confidential information in its possession, and the Party is 25 subject to an agreement with the Non-Party not to produce the Non-Party’s 26 confidential information, then the Party shall: 27 28 1 (1) promptly notify in writing the Requesting Party and the Non-Party 2 that some or all of the information requested is subject to a confidentiality agreement 3 with a Non-Party; 4 (2) promptly provide the Non-Party with a copy of the Stipulated 5 Protective Order in this Action, the relevant discovery request(s), and a reasonably 6 specific description of the information requested; and 7 (3) make the information requested available for inspection by the 8 Non-Party, if requested. 9 (c) If the Non-Party fails to seek a protective order from this Court within 14 10 days of receiving the notice and accompanying information, the Receiving Party 11 may produce the Non-Party’s confidential information responsive to the discovery 12 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 13 not produce any information in its possession or control that is subject to the 14 confidentiality agreement with the Non-Party before a determination by the Court. 15 Absent a court order to the contrary, the Non-Party shall bear the burden and expense 16 of seeking protection in this Court of its Protected Material. 17 18 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 19 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 20 Protected Material to any person or in any circumstance not authorized under this 21 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 22 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 23 to retrieve all unauthorized copies of the Protected Material, (c) inform the person 24 or persons to whom unauthorized disclosures were made of all the terms of this 25 Order, and (d) request such person or persons to execute the “Acknowledgment and 26 Agreement to Be Bound” that is attached hereto as Exhibit A. 27 28 1 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 2 PROTECTED MATERIAL 3 When a Producing Party gives notice to Receiving Parties that certain 4 inadvertently produced material is subject to a claim of privilege or other protection, 5 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 6 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 7 may be established in an e-discovery order that provides for production without prior 8 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as 9 the parties reach an agreement on the effect of disclosure of a communication or 10 information covered by the attorney-client privilege or work product protection, the 11 parties may incorporate their agreement in the stipulated protective order submitted 12 to the Court. 13 14 12. MISCELLANEOUS 15 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 16 person to seek its modification by the Court in the future. 17 12.2 Right to Assert Other Objections. By stipulating to the entry of this 18 Protective Order, no Party waives any right it otherwise would have to object to 19 disclosing or producing any information or item on any ground not addressed in this 20 Stipulated Protective Order. Similarly, no Party waives any right to object on any 21 ground to use in evidence of any of the material covered by this Protective Order. 22 12.3 Filing Protected Material. A Party that seeks to file under seal any 23 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 24 only be filed under seal pursuant to a court order authorizing the sealing of the 25 specific Protected Material at issue; good cause must be shown in the request to file 26 under seal. If a Party’s request to file Protected Material under seal is denied by the 27 28 1 Court, then the Receiving Party may file the information in the public record unless 2 otherwise instructed by the Court. 3 4 13. FINAL DISPOSITION 5 After the final disposition of this Action, within 60 days of a written request 6 by the Designating Party, each Receiving Party must return all Protected Material to 7 the Producing Party or destroy such material. As used in this subdivision, “all 8 Protected Material” includes all copies, abstracts, compilations, summaries, and any 9 other format reproducing or capturing any of the Protected Material. Whether the 10 Protected Material is returned or destroyed, the Receiving Party must submit a 11 written certification to the Producing Party (and, if not the same person or entity, to 12 the Designating Party) by the 60 day deadline that (1) identifies (by category, where 13 appropriate) all the Protected Material that was returned or destroyed, and (2) affirms 14 that the Receiving Party has not retained any copies, abstracts, compilations, 15 summaries or any other format reproducing or capturing any of the Protected 16 Material. Notwithstanding this provision, counsel are entitled to retain an archival 17 copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal 18 memoranda, correspondence, deposition and trial exhibits, expert reports, attorney 19 work product, and consultant and expert work product, even if such materials 20 contain Protected Material. Any such archival copies that contain or constitute 21 Protected Material remain subject to this Protective Order as set forth in Section 4 22 (DURATION). 23 24 14. VIOLATION OF ORDER 25 Any violation of this Order may be punished by any and all appropriate 26 measures including, without limitation, contempt proceedings and/or monetary 27 sanctions. 28 1 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 2 3 DATED: October 10, 2025 CARPENTER, ROTHANS & DUMONT 4 5 6 By: /s/ Jill Williams 7 JILL WILLIAMS KIMBERLY SARMIENTO 8 Attorneys for Defendants, County of Los Angeles and 9 Deputy Aram Derderian 10 11 DATED: October 10, 2025 TAYLOR & RING LLP 12 13 14 By: /s/ Peter Reagan 15 JOHN C. TAYLOR NEIL GEHLAWAT 16 PETER REAGAN Attorneys for Plaintiff 17 WESTLEY HENSON 18 19 20 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 21 22 DATED:_1_0_/1_4_/_2_02_5_______ 23 _________________________________ 24 HON. A. JOEL RICHLIN _ United States Magistrate Judge 25 26 27 28 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 I, _____________________________ [full name], of _________________ 5 [full address], declare under penalty of perjury that I have read in its entirety and 6 understand the Stipulated Protective Order that was issued by the United States 7 District Court for the Central District of California on ____________ [date] in the 8 case of ___________ [insert case name and number]. I agree to comply with 9 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 11 sanctions and punishment in the nature of contempt. I solemnly promise that I will 12 not disclose in any manner any information or item that is subject to this Stipulated 13 Protective Order to any person or entity except in strict compliance with the 14 provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District 16 Court for the Central District of California for the purpose of enforcing the terms 17 of this Stipulated Protective Order, even if such enforcement proceedings occur 18 after termination of this action. I hereby appoint __________________________ 19 [full name] of _______________________________________ [full address and 20 telephone number] as my California agent for service of process in connection 21 with this action or any proceedings related to enforcement of this Stipulated 22 Protective Order. 23 Date: ______________________________________ 24 City and State where signed: _________________________________ 25 26 Printed name: _______________________________ 27 Signature: __________________________________ 28