1 || Eugene P. Ramirez (State Bar No. 134865) eugene, [email protected] 2 || Kayleigh A. Andersen (State Bar No. 306442) Rapicigh andersen(manningkass.com 3 || MANNING & KAS ELLROD, RAMIREZ, TRESTER LLP 4}/801 S. Figueroa St, 15th Floor, Los Angeles, California 90017-3012 5 || Telephone: GB) 624-6900 Facsimile: (213) 624-6999 6 Attorneys for Defendants, 7 RIVERSIDE COUNTY SHERIFF’S DEPARTMENT, SHERIFF CHAD BIANCO, DEPUTY DENNIS VROOM and RIVERSIDE UNIVERSITY HEALTH SYSTEM 9 UNITED STATES DISTRICT COURT 10 CENTRAL DISTRICT OF CALIFORNIA, EASTERN DIVISION Il

CHRISTOPHER D. SAWYER, an Case No. 5:24-cv-01683-SSS-DTB individual, District Judge: Sunshine S. Sykes Magistrate Judge: David T. Bristow Plaintiff, 15 V. STIPULATED PROTECTIVE ORDER RE CONFIDENTIAL 2! 16|| RIVERSIDE COUNTY SHERIFF’S DOCUMENTS DEPARTMENT; CHAD BIANCO; DENNIS VROOM; FLAKES; RIVERSIDE UNIVERSITY HEALTH | Filed Date: 08/08/24 18 || SYSTEM; and DOES 1 thru 10, inclusive, 19 Defendants. 20 21 22|}1. A.PURPOSES AND LIMITATIONS 23 Discovery in this action is likely to involve production of confidential, 24 || proprietary, or private information for which special protection from public disclosure 25 || and from use for any purpose other than prosecuting this litigation may be warranted. || Accordingly, the parties hereby stipulate to and petition the Court to enter the 27 || following Stipulated Protective Order. The parties acknowledge that this Order does 28 □□ □□□ confer blanket protections on all disclosures or responses to discovery and that

1 || the protection it affords from public disclosure and use extends only to the limited 2 ||information or items that are entitled to confidential treatment under the applicable 3 || legal principles. The parties further acknowledge, as set forth in Section 12.3, below, 4|/that this Stipulated Protective Order does not entitle them to file confidential 5 || information under seal; Civil Local Rule 79-5 sets forth the procedures that must be 6 || followed and the standards that will be applied when a party seeks permission from 7 || the court to file material under seal. 8 B. GOOD CAUSE STATEMENT 9 This action is likely to involve medical records, sensitive and confidential 10 || documents related to a death, documents containing private information from third 11 || parties, police investigation procedures and tactics, and other confidential and private 12 || information for which special protection from public disclosure and from use for any 13 || purpose other than prosecution of this action is warranted. Such confidential and 2 proprietary materials and information consist of, among other things, confidential 15 || personal information of non-parties, private medical and autopsy records, internal | 16|| police reviews and procedures, and other confidential and sensitive information 17 || otherwise generally unavailable to the public, or which may be privileged or otherwise 18 || protected from disclosure under state or federal statutes, court rules, case decisions, 19 || or common law. Defendants contend that there is good cause for a protective order to 20 || maintain the confidentiality of peace officer personnel records. They emphasize that 21 ||releasing these records, which include internal analyses and legal communications, 22 || could hinder law enforcement investigations. 23 Accordingly, to expedite the flow of information, to facilitate the prompt 24 ||resolution of disputes over confidentiality of discovery materials, to adequately 25 || protect information the parties are entitled to keep confidential, to ensure that the 26 || parties are permitted reasonable necessary uses of such material in preparation for and 27 ||in the conduct of trial, to address their handling at the end of the litigation, and serve 28 || the ends of justice, a protective order for such information is justified in this matter.

1 || It is the intent of the parties that information will not be designated as confidential for 2 || tactical reasons and that nothing be so designated without a good faith belief that it 3 || has been maintained in a confidential, non-public manner, and there is good cause 4 || why it should not be part of the public record of this case. 5||2.. DEFINITIONS 6 2.1 Action: this pending federal law suit. 7 2.2 Challenging Party: a Party or Non-Party that challenges the designation of 8 || information or items under this Order. 9 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how 10 |/it is generated, stored or maintained) or tangible things that qualify for protection 11 |}under Federal Rule of Civil Procedure 26(c), and as specified above in the Good

12 || Cause Statement. | 13 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 2 14 || support staff). 15 2.5 Designating Party: a Party or Non-Party that designates information or 16||items that it produces in disclosures or in responses to discovery as 3 “CONFIDENTIAL.” 18 2.6 Disclosure or Discovery Material: all items or information, regardless of 19 ||the medium or manner in which it is generated, stored, or maintained (including, 20 || among other things, testimony, transcripts, and tangible things), that are produced or 21 || generated in disclosures or responses to discovery in this matter. 22 2.7 Expert: a person with specialized knowledge or experience in a matter 23 || pertinent to the litigation who has been retained by a Party or its counsel to serve as 24 || an expert witness or as a consultant in this Action. 25 2.8 House Counsel: attorneys who are employees of a party to this Action. 26 || House Counsel does not include Outside Counsel of Record or any other outside 27 || counsel. 28 2.9 Non-Party: any natural person, partnership, corporation, association, or

1 || other legal entity not named as a Party to this action. 2 2.10 Outside Counsel of Record: attorneys who are not employees of a party to 3 || this Action but are retained to represent or advise a party to this Action and have 4 || appeared in this Action on behalf of that party or are affiliated with a law firm which 5 || has appeared on behalf of that party, and includes support staff. 6 2.11 Party: any party to this Action, including all of its officers, directors, 7 ||employees, consultants, retained experts, and Outside Counsel of Record (and their 8 || support staffs). 9 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 10 || Discovery Material in this Action. 11 2.13 Professional Vendors: persons or entities that provide litigation support 12||services (e.g., photocopying, videotaping, translating, preparing exhibits or | 13 || demonstrations, and organizing, storing, or retrieving data in any form or medium) 2 14 || and their employees and subcontractors. 15 2.14 Protected Material: any Disclosure or Discovery Material that is 16 || designated as “CONFIDENTIAL.” 3 Al 17 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 18 || from a Producing Party. 19 |/3. SCOPE 20 The protections conferred by this Stipulation and its associated Order cover not 21 || only Protected Material/Confidential Documents (as defined above), but also (1) any 22 ||information copied or extracted from Protected Material; (2) all copies, excerpts, 23 ||summaries, or compilations of Protected Material; and (3) any testimony, 24 || conversations, or presentations by Parties or their Counsel that might reveal Protected 25 || Material. However, the protections conferred by this Stipulation and its associated 26 || Order do not cover the following information: (a) any information that is in the public 27 ||domain at the time of disclosure to a Receiving Party or becomes part of the public 28 || domain after its disclosure to a Receiving Party as a result of publication not involving

1 |) a violation of this Order, including becoming part of the public record through trial or 2 ||otherwise; and (b) any information known to the Receiving Party prior to the 3 || disclosure or obtained by the Receiving Party after the disclosure from a source who 4 || obtained the information lawfully and under no obligation of confidentiality to the 5 || Designating Party. 6 Any use of Protected Material at trial shall be governed by the orders of the 7 || trial judge. This Order does not govern the use of Protected Material at trial. 8||4. DURATION 9 Once a case proceeds to trial, all of the information that was designated as □□ confidential or maintained pursuant to this protective order used or introduced 11 |}as an exhibit at trial becomes public and will be presumptively available to all

12 || member of the public, including the press, unless compelling reasons supported by | 13 || specific factual findings to proceed otherwise are made to the trial judge in advance 2 14 || of the trial. See Kamakana v. City and County of Honolulu,

, 1180-81 15 || (9" Cir. 2006) (distinguishing “good cause” showing for sealing documents produced 16||in discovery from “compelling reasons” standard when merits-related documents 3 17|\are part of court record). Accordingly, the terms of this protective order do not 18 || extend beyond the commencement of the trial. 19||5. DESIGNATION OF PROTECTED MATERIAL 20 5.1. Exercise of Restraint and Care in Designating Material for Protection. 21 Each Party or non-party that designates information or items for protection ||under this Stipulation and its associated Order must take care to limit any such 23 || designation to specific material that qualifies under the appropriate standards. A 24 || Designating Party must take care to designate for protection only those parts of 25 || material, documents, items, or oral or written communications that qualify — so that 26 ||other portions of the material, documents, items or communications for which 27 || protection is not warranted are not swept unjustifiably within the ambit of this Order. 28 Mass, indiscriminate, or routine designations are prohibited. Designations that

1 || are shown to be clearly unjustified, or that have been made for an improper purpose 2 || (e.g., to unnecessarily encumber or retard the case development process, or to impose 3 || unnecessary expenses and burdens on other parties), expose the Designating Party to 4 || sanctions. 5 If it comes to a Designating Party’s attention that information or items that it 6 || designated for protection do not qualify for protection, that Designating Party must 7 || promptly notify all other Parties that it is withdrawing the inapplicable designation. 8 5.2. Manner and Timing of Designations. Except as otherwise provided in 9 || this Order, or as otherwise stipulated or ordered, material that qualifies for protection 10 || under this Order must be clearly so designated before the material is disclosed or 11 || produced. 12 Designation in conformity with this Order requires: | 13 (a) for information in documentary form (apart from transcripts of 2 14 || depositions or other pretrial or trial proceedings, and regardless of whether produced 15|}in hardcopy or electronic form), that the Producing Party affix the legend 16 || “CONFIDENTIAL: THESE DOCUMENTS ARE SUBJECT TO THE TERMS AND 3 CONDITIONS OF A PROTECTIVE ORDER, Case No. 5:23-cv-01825-WLH-SHK” 18 || to each page that contains Protected Material. If only a portion or portions of the || material on a page qualifies for protection, the Producing Party also must clearly 20 || identify the protected portion(s) (e.g., by making appropriate markings in the margins) must specify, for each portion that it is “CONFIDENTIAL.” The placement of 22 ||such “CONFIDENTIAL” stamp on such page(s) shall not obstruct the substance of 23 || the page’s (or pages’) text or content and shall be in the margin of the document 24 || whenever possible. 25 A Party or Non-Party that makes original documents or materials available for 26 || inspection need not designate them for protection until after the inspecting Party has 27 ||indicated which material it would like copied and produced. During the inspection 28 || and before the designation, all of the material made available for inspection shall be

1 || deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents 2 || it wants copied and produced, the Producing Party must determine which documents, 3 || or portions thereof, qualify for protection under this Order. Then, before producing 4||/the specified documents, the Producing Party must affix the “CONFIDENTIAL” 5 || legend to each page that contains Protected Material. If only a portion or portions of 6 || the material on a page qualifies for protection, the Producing Party also must clearly 7 \|identify the protected portion(s) (e.g., by making appropriate markings in the 8 || margins). 9 (b) testimony given in depositions that the Designating Party identify the 10 || Disclosure or Discovery Material on the record, before the close of the deposition all «| 11 || protected testimony. 12 (c) for information produced in some form other than documentary, and for | 13 || any other tangible items (including but not limited to information produced on disc or 2 14 || electronic data storage device), that the Producing Party affix in a prominent place on 15 || the exterior of the container or containers in which the information or item is stored 16 || the legend “CONFIDENTIAL.” If only portions of the information or item warrant 3 protection, the Producing Party, to the extent practicable, shall identify the protected 18 || portions, specifying the material as “CONFIDENTIAL.” 19 5.3. Inadvertent Failures to Designate. If timely corrected (preferably, 20 || though not necessarily, within 30 days of production or disclosure of such material), 21|)an inadvertent failure to designate qualified information or items as 22 ||““CONFIDENTIAL” does not, standing alone, waive the Designating Party’s right to 23 ||secure protection under this Stipulation and its associated Order for such material. 24 If material is appropriately designated as “CONFIDENTIAL” after the material 25 || was initially produced, the Receiving Party, on timely notification of the designation, 26 || must make reasonable efforts to assure that the material is treated in accordance with 27 || this Stipulation and its associated Order. 28 || ///

1 || 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS. 2 6.1. Timing of Challenges. Any Party or Non-Party may challenge a 3 ||designation of confidentiality at any time that is consistent with the Court's 4 || Scheduling Order. 5 6.2. Meet _and Confer. The Challenging Party shall initiate the dispute 6 || resolution process under Local Rule 37.1 ef seq. 7 6.3. The burden of persuasion in any such challenge proceeding shall be on 8 || the Designating Party. Frivolous challenges, and those made for an improper purpose 9 ||(e.g., to harass or impose unnecessary expenses and burdens on other parties) may 10 || expose the Challenging Party to sanctions. Unless the Designating Party has waived 11 || or withdrawn the confidentiality designation, all parties shall continue to afford the

12 || material in question the level of protection to which it is entitled under the Producing | 13 || Party’s designation until the Court rules on the challenge. 14 6.4. Withdrawal of “CONFIDENTIAL” Designation. At its discretion, a 15 || Designating Party may remove Protected Material/Confidential Documents from | 16 ||some or all of the protections and provisions of this Stipulation and its associated 3 Order at any time by any of the following methods: 18 (a) Express Written Withdrawal. A Designating Party may withdraw a 19||“CONFIDENTIAL” designation made to any specified Protected Material 20 ||/Confidential Documents from some or all of the protections of this Stipulation and 21 ||its associated Order by an express withdrawal in a writing signed by such Party (or 22 ||such Party’s Counsel, but not including staff of such Counsel) that specifies and 23 ||itemizes the Disclosure or Discovery Material previously designated as Protected 24 || Material/Confidential Documents that shall no longer be subject to all or some of the 25 || provisions of this Stipulation and Order. Such express withdrawal shall be effective 26 || when transmitted or served upon the Receiving Party. If a Designating Party is 27 || withdrawing Protected Material from only some of the provisions/ protections of this 28 || Stipulation and Order, such Party must state which specific provisions are no longer

1 ||/to be enforced as to the specified material for which confidentiality protection 2||hereunder is withdrawn: otherwise, such withdrawal shall be construed as a 3 || withdrawal of such material from all of the protections/provisions of this Stipulation 4 || and Order; 5 (b) Express Withdrawal on the Record. A Designating Party may withdraw 6]|1a “CONFIDENTIAL” designation made to any _ specified Protected 7 || Material/Confidential Documents from all of the provisions/protections of this 8 || Stipulation and its associated Order by verbally consenting in court proceedings on 9||the record to such withdrawal — provided that such withdrawal specifies the 10|| Disclosure or Discovery Material previously designated as Protected Material/ 11 || Confidential Documents that shall no longer be subject to any of the provisions of this

12 || Stipulation and Order. A Designating Party is not permitted to withdraw Protected | 13 || Material from only some of the protections/provisions of this Stipulation and Order 2 14 || by this method; 15 (c) Implicit Withdrawal by Publication or Failure to Oppose Challenge. A 16 || Designating Party shall be construed to have withdrawn a “CONFIDENTIAL” 3 designation made to any specified Protected Material/Confidential Documents from 18 || all of the provisions/protections of this Stipulation and Order by either (1) making 19 || such Protected Material/Confidential Records part of the public record — including 20 || but not limited to attaching such as exhibits to any filing with the court without 21 || moving, prior to such filing, for the court to seal such records; or (2) failing to timely 22 || oppose a Challenging Party’s motion to remove a “CONFIDENTIAL” designation to 23 || specified Protected Material/Confidential Documents. Nothing in this Stipulation and 24||Order shall be construed so as to require any Party to file Protected 25 || Material/Confidential Documents under seal, unless expressly specified herein. 26||7. ACCESS TO AND USE OF PROTECTED MATERIAL. 27 7.1. Basic Principles. A Receiving Party may use Protected Material that is 28 || disclosed or produced by another Party or by a non-party in connection with this case

1 || only for preparing, prosecuting, defending, or attempting to settle this litigation — up 2 ||to and including final disposition of the above-entitled action — and not for any other 3 || purpose, including any other litigation or dispute outside the scope of this action. 4 || Such Protected Material may be disclosed only to the categories of persons and under 5 || the conditions described in this Stipulation and its associated Order. When the above 6 ||entitled litigation has been terminated, a Receiving Party must comply with the 7 || provisions of section 13, below (FINAL DISPOSITION). 8 Protected Material must be stored and maintained by a Receiving Party at a 9 ||location and in a secure manner that ensures that access is limited to the persons 10 || authorized under this Stipulation and its Order. 11 7.2. Disclosure of “CONFIDENTIAL” Information or Items. Unless

12 || otherwise ordered by the Court or permitted in writing by the Designating Party, a | 13 || Receiving Party may disclose any information or item designated CONFIDENTIAL 2 14 || only to: 15 (a) the Receiving Party’s Outside Counsel of record in this action, as well | 16||as employees of such Counsel to whom it is reasonably necessary to disclose the 3 17 |linformation for this litigation; 18 (b) the officers, directors, and employees (including House Counsel) of the 19 || Receiving Party to whom disclosure is reasonably necessary for this litigation — each 20 || of whom, by accepting receipt of such Protected Material, thereby agree to be bound 21 || by this Stipulation and Order; 22 (c) Experts (as defined in this Stipulation and Order) of the Receiving Party 23 ||to whom disclosure is reasonably necessary for this litigation — each of whom, by 24 || accepting receipt of such Protected Material, thereby agree to be bound by this 25 || Stipulation and Order; 26 (d) court reporters, their staff, and Professional Vendors to whom disclosure 27 ||is reasonably necessary for this litigation — each of whom, by accepting receipt of 28 || such Protected Material, thereby agree to be bound by this Stipulation and Order;

1 (e) during their depositions, witnesses in the action to whom disclosure is 2 ||reasonably necessary — each of whom, by accepting receipt of such Protected 3 ||Material, thereby agree to be bound by this Stipulation and Order. Pages of 4||transcribed deposition testimony or exhibits to depositions that reveal Protected 5 || Material must have a confidential designation affixed by the court reporter to such 6 || pages containing Protected Material and such may not be disclosed to anyone except 7 ||as permitted under this Stipulation and its Protective Order. 8 (f) the author or custodian of a document containing the information that 9 || constitutes Protected Material, or other person who otherwise possessed or knew the 10 || information. 11 (g) any mediator or settlement officer, and their supporting personnel, 12 || mutually agreed upon by any of the parties engaged in settlement discussions. 13 7.3. Notice of Confidentiality. Prior to producing or disclosing Protected 2 14 || Material/Confidential Documents to persons to whom this Stipulation and its Order || permits disclosure or production (see section 8.2, supra), a Receiving Party shall & 16 || provide a copy of this Stipulation and Order to such persons so as to put such persons 17||on notice as to the restrictions imposed upon them herein: except that, for court 18 || reporters, Professional Vendors, and for witnesses being provided with Protected 19 || Material during a deposition, it shall be sufficient notice for Counsel for the Receiving 20 || Party to give the witness a verbal admonition (on the record, for witnesses) regarding 21 provisions of this Stipulation and its Order and such provisions’ applicability to 22 || specified Protected Material at issue. 23 7.4. Reservation of Rights. Nothing in this Stipulation and Order shall be 24 || construed so as to require any Producing Party to designate any records or materials 25 |}as “CONFIDENTIAL.” Nothing in this Stipulation and Order shall be construed so 26 ||as to prevent the admission of Protected Material into evidence at the trial of this 27 || action, or in any appellate proceedings for this action, solely on the basis that such 28 ||Disclosure or Discovery Material has been designated as _ Protected

1 || Material/Confidential Documents. Notwithstanding the foregoing, nothing in this 2 || Stipulation and Order shall be construed as a waiver of any privileges or of any rights 3 || to object to the use or admission into evidence of any Protected Material in any 4 || proceeding; nor shall anything herein be construed as a concession that any privileges 5 ||asserted or objections made are valid or applicable. Nothing in this Stipulation and 6 || Order shall be construed so as to prevent the Designating Party (or its Counsel or 7 || custodian of records) from having access to and using Protected Material designated 8 || by that Party in the manner in which such persons or entities would typically use such 9 || materials in the normal course of their duties or profession — except that the waiver of 10 || confidentiality provisions shall apply (see section 6.4(c), supra). 11 7.5. Requirement to File Confidential Documents Under Seal. Confidential

12 || Documents may be submitted in all law and motion proceedings before the Court if | 13 ||done so under seal pursuant to Federal Rules of Civil Procedure 5.2 and 26 and/or 2 14 || United States District Court, Central District of California Local Rules 79-5.1 and 79- 15||5.2 (as applicable) and pursuant to the provisions of this Stipulation and any 16 || associated Order. If any Receiving Party attaches any Confidential Documents to any 3 FI —17]||pleading, motion, or other paper to be filed, lodged, or otherwise submitted to the 18 || Court, such Confidential Document(s) shall be filed/lodged under seal pursuant to 19 || Federal Rules of Civil Procedure 5.2 and 26 and/or United States District Court, 20 || Central District of California Local Rules 79-5.1 and 79-5.2 to the extent applicable. 21 However, this paragraph (§ 7.5) shall not be construed so as to prevent a 22 || Designating Party or counsel from submitting, filing, lodging, or publishing any 23 ||document it has previously designated as a Confidential Document without 24 || compliance with this paragraph’s requirement to do so under seal (1.e., a producing- 25 || disclosing party or counsel may submit or publish its own Confidential Documents 26 || without being in violation of the terms of this Stipulation and its Protective Order). 27 Furthermore, a Receiving Party shall be exempted from the requirements of 28 || this paragraph as to any specifically identified Confidential Document(s) where —

1 || prior to the submission or publication of the Confidential Document(s) at issue — the 2 || Designating Party of such specifically identified Confidential Document(s) has 3 || waived/withdrawn the protections of this Stipulation and its Order (pursuant to 4 || paragraph 6.4, supra). 5 A Receiving Party shall also be exempt from the sealing requirements of this 6 || paragraph (§] 7.5) where the Confidential Documents/Protected Material at issue is/are 7 ||not documents, records, or information regarding or incorporating: 8 (1) _ private, personal information contained in peace officer personnel files 9 ||(such as social security numbers, driver’s license numbers or comparable personal 10 || government identification numbers, residential addresses, compensation or pension 11 || or personal property information, credit card numbers or credit information, dates of

12 || birth, tax records and information, information related to the identity of an officer’s | 13 || family members or co-residents, and comparable personal information about the 2 14 || officer or his family); 15 (2) any internal affairs or comparable investigation by any law enforcement 16 || agency into alleged officer misconduct; and/or 3 17 (3) the medical records or records of psychiatric or psychological treatment 18 || of any peace officer or party to this action. 19 |/8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 50 PRODUCED IN OTHER LITIGATION.

21 If a Party is served with a subpoena or a court order issued in other litigation 22 ||that compels disclosure of any information or items designated in this action as 23 || “CONFIDENTIAL,” that Party must: 24 (a) promptly notify in writing the Designating Party, preferably (though not 25 necessarily) by facsimile or electronic mail. Such notification shall include a copy of 26 || the subpoena or court order at issue; 27 (b) promptly notify in writing the party who caused the subpoena or order to 28 || issue in the other litigation that some or all of the material covered by the subpoena

1 || or order is subject to this Stipulation and its Protective Order. Such notification shall 2 □□ include a copy of this Stipulation and its Protective Order; and 3 (c) cooperate with respect to all reasonable procedures sought to be pursued 4 || by all sides in any such situation, while adhering to the terms of this Stipulation and 5 || its Order. 6 If the Designating Party timely seeks a protective order, the Party served with 7 || the subpoena or court order shall not produce any information designated in this action 8 || as “CONFIDENTIAL” before a determination by the court from which the subpoena 9 || or order issued, unless the Party has obtained the Designating Party’s permission. The 10 || Designating Party shall bear the burden and expense of seeking protection in that court 11 || of its confidential material — and nothing in these provisions should be construed as

12 ||authorizing or encouraging a Receiving Party in this action to disobey a lawful | 13 || directive from another court. 2 14 The purpose of this section is to ensure that the affected Party has a meaningful 15 || opportunity to preserve its confidentiality interests in the court from which the 16 || subpoena or court order issued. 3 17\|9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE ig PRODUCED IN THIS LITIGATION

19 (a) The terms of this Order are applicable to information produced by a Non- 20||Party in this Action and designated as “CONFIDENTIAL.” Such information produced by Non-Parties in connection with this litigation is protected by the 22 ||remedies and relief provided by this Order. Nothing in these provisions should be 23 || construed as prohibiting a Non-Party from seeking additional protections. 24 (b) In the event that a Party is required, by a valid discovery request, to 25 || produce a Non-Party’s confidential information in its possession, and the Party is 26||subject to an agreement with the Non-Party not to produce the Non-Party’s 27 || confidential information, then the Party shall: 28 (1) promptly notify in writing the Requesting Party and the Non-Party

1 that some or all of the information requested is subject to a 2 confidentiality agreement with a Non-Party; 3 (2) promptly provide the Non-Party with a copy of the Stipulated 4 Protective Order in this Action, the relevant discovery request(s), 5 and a reasonably specific description of the information requested; 6 and 7 (3) make the information requested available for inspection by the 8 Non-Party, if requested. 9\\(c) Ifthe Non-Party fails to seek a protective order from this court within 14 days || of receiving the notice and accompanying information, the Receiving Party may 11 || produce the Non-Party’s confidential information responsive to the discovery request. 12 || If the Non-Party timely seeks a protective order, the Receiving Party shall not produce | 13 |}any information in its possession or control that is subject to the confidentiality 2 14 ||agreement with the Non-Party before a determination by the court. Absent a court 15 || order to the contrary, the Non-Party shall bear the burden and expense of seeking 16 || protection in this court of its Protected Material. 3 17||10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL. 18 10.1. 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 || Stipulation and Order, the Receiving Party must immediately: 22 (a) notify in writing the Designating Party of the unauthorized disclosures; 23 (b) use its best efforts to retrieve all copies of the Protected Material; 24 (c) inform the person or persons to whom unauthorized disclosures were made 25 || of all the terms of this Order; and 26 (d) request such person or persons consent to be bound by the Stipulation and 27 || Order. 28

1||/11. Inadvertent Production of Privileged or Otherwise Protected Material. 2 When a Producing Party gives notice to Receiving Parties that certain 3 || inadvertently produced material is subject to a claim of privilege or other protection, 4 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 5 || Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 6 || may be established in an e-discovery order that provides for production without prior 7 || privilege review. Pursuant to Federal Rule of Evidence 502(d) and (ce), insofar as the 8 || parties reach an agreement on the effect of disclosure of a communication or 9 || information covered by the attorney-client privilege or work product protection, the 10 || parties may incorporate their agreement in the stipulated protective order submitted 11 || to the court. 12|]12. MISCELLANEOUS | 13 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 2 14 || person to seek its modification by the Court in the future. 15 12.2 Right to Assert Other Objections. By stipulating to the entry of this | Protective Order no Party waives any right it otherwise would have to object to 3 17 || disclosing or producing any information or item on any ground not addressed in this 18 || Stipulated Protective Order. Similarly, no Party waives any right to object on any 19 || ground to use in evidence of any of the material covered by this Protective Order. 20 12.3 Filing Protected Material. A Party that seeks to file under seal any 21 || Protected Material must comply with Civil Local Rule 79-5. Protected Material may 22 || only be filed under seal pursuant to a court order authorizing the sealing of the specific 23 || Protected Material at issue. If a Party's request to file Protected Material under seal is 24 || denied by the court, then the Receiving Party may file the information in the public 25 ||record unless otherwise instructed by the court. 26||13. FINAL DISPOSITION. 27 Unless otherwise ordered or agreed in writing by the Producing Party, within 28 || sixty (60) days after the final termination of this action (defined as the dismissal or

1 || entry of judgment by the above named court, or if an appeal is filed, the disposition 2 ||of the appeal), upon written request by the Producing Party, each Receiving Party 3 || must return all Protected Material to the Producing Party — whether retained by the 4 || Receiving Party or its Counsel, Experts, Professional Vendors, agents, or any non- 5 || party to whom the Receiving Party produced or shared such records or information. 6 As used in this subdivision, “all Protected Material” includes all copies, 7 || abstracts, compilations, summaries or any other form of reproducing or capturing any 8 ||of the Protected Material, regardless of the medium (hardcopy, electronic, or 9 || otherwise) in which such Protected Material is stored or retained. 10 In the alternative, at the discretion of the Receiving Party, the Receiving Party 11 || may destroy some or all of the Protected Material instead of returning it — unless such

12 || Protected Material is an original, in which case, the Receiving Party must obtain the | 13 || Producing Party’s written consent before destroying such original Protected Material. 2 14 Whether the Protected Material is returned or destroyed, the Receiving Party 15 || must submit a written certification to the Producing Party (and, if not the same person | 16]||or entity, to the Designating Party) within sixty (60) days of the aforementioned || written request by the Designating Party that specifically identifies (by category, 18 || where appropriate) all the Protected Material that was returned or destroyed and that 19 || affirms that the Receiving Party has not retained any copies, abstracts, compilations, 20 ||}summaries or other forms of reproducing or capturing any of the Protected material 21 || (in any medium, including but not limited to any hardcopy, electronic or digital copy, 22 || or otherwise). 23 Notwithstanding this provision, Counsel are entitled to retain an archival copy 24 || of all pleadings, motion papers, transcripts, legal memoranda filed with the court in 25 ||this action, as well as any correspondence or attorney work product prepared by 26 || Counsel for the Receiving Party, even if such materials contain Protected Material; 27 || however, any such archival copies that contain or constitute Protected Material remain 28 || subject to this Protective Order as set forth in Section 4 (DURATION), above.

1 Any violation of this Order may be punished by any and all appropriate 2 ||including, without limitation, contempt proceedings and/or monetary sanctions. 3 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 4|| DATED: November 3, 2025 MANNING & KASS 5 ELLROD, RAMIREZ, TRESTER LLP 6 By: /s/ Kayleigh A. Andersen 8 Kayleigh Andersen 9 Attorneys for Defendants DATED: November 3, 2025 BOND LAW LEGAL GROUP 11 12 By: /s/ Royal DL Bond 43 Royal DL Bond, Esq. Attorneys for Plaintiffs

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1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, [print or type full name], 4 || of [print or type full address], 5 ||declare under penalty of perjury that I have read in its entirety and understand the 6 || Stipulated Protective Order that was issued by the United States District Court for the 7 || Central District of California on [date] in the case of CHRISTOPHER 8 || SAWYER v. RIVERSIDE COUNTY SHERIFF’S DEPARTMENT, et al., Case 9 || No. 5:24-cv-01683-SSS-DTB. I agree to comply with and to be bound by all the terms 10 || of this Stipulated Protective Order and I understand and acknowledge that failure to so 11 ||comply could expose me to sanctions and punishment in the nature of contempt. I

12 ||solemnly promise that I will not disclose in any manner any information or item that | 13 ||is subject to this Stipulated Protective Order to any person or entity except in strict 2 14 || compliance with the provisions of this 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 3 —17||Stipulated Protective Order, even if such enforcement proceedings occur after 18 || termination of this action. I hereby appoint [print or type full name] 20 || of 21 || [print or type full address and telephone number] as my California agent for service 22 || of process in connection with this action or any proceedings related to enforcement 23 || of this Stipulated Protective Order. 24 || Date: 25 || City and State where sworn and signed: 26 || Printed name: 27 || Signature: 28

1 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 2 3 || DATED: November 5, 2025 4 | de 7

7|| HON. DAVID T. BRISTOW United States Magistrate Judge 10 11

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