1 | Angela M. Powell, SBN 191876 eee SS 2 | Helen O. Kim, Esq., SBN 254560 [email protected] 3 | JON ES MAYER 3777 North Harbor Boulevard 4 | Fullerton, CA 92835 Telephone: (714) 446-1400 5 | Facsimile: (714) 446-1448 6 Attorneys for Defendants, CITY OF FONTANA, FONTANA POLICE 7 | DEPARTMENT, OFFICER CHAD EBLI, and OFFICER NICHOLAS STRAKA 8 Eduardo M. Madrid, SBN 82395 9 | [email protected] Erica L. Madrid, SBN 229327 10 | [email protected] MADRID LAW FIRM 11 | A Professional Law Corporation 12612 Central Avenue 12 | Chino, CA 91710 Telephone: (909) 628-0068 13 | Facsimile: (909) 628-0067 14 | Attorneys for Plaintiff, LORETTA GURROLA 15 16 UNITED STATES DISTRICT COURT 7 CENTRAL DISTRICT OF CALIFORNIA 18 | LORETTA GURROLA Case No. 5:25-cv-02221 SSS (Ex) 19 Plaintiff, Honorable Sunshine Suzanne Sykes 0 Courtroom

Magistrate Judge Charles F. Eick CITY OF FONTANA, FONTANA POLICE DEPARTMENT, POLICE STIPULATED PROTECTIVE OFFICER CHAD EBLI, POLICE ORDER 3 OFFICER NICHOLAS STRAKA, individually and in their official Complaint Filed: August 25, 2025 04 capacity as police officers with the City | First Amended Complaint Filed: of Fontana/Fontana Police October 20, 2025 95 Department, DOES 8 to 10, individually and in their official %6 capacity as police officers and/or employees of the City of 7 Fontana/Fontana Police Department, Inclusive, 28 Defendants. STIPULATED PROTECTIVE ORDER

1] 1. GENERAL 2 1.1 Purposes and Limitations. Discovery in this action is likely to involve 3 | production of confidential, proprietary, or private information for which special 4 | protection from public disclosure and from use for any purpose other than 5 | prosecuting this litigation may be warranted. Accordingly, the parties hereby 6 | stipulate to and petition the Court to enter the following Stipulated Protective 7 | Order. The parties acknowledge that this Order does not confer blanket 8 | protections on all disclosures or responses to discovery and that the protection it 9 | affords from public disclosure and use extends only to the limited information or 10 | items that are entitled to confidential treatment under the applicable legal 11 | principles. The parties further acknowledge, as set forth in Section 12.3, below, 12 | that this Stipulated Protective Order does not entitle them to file confidential 13 | information under seal; Civil Local Rule 79-5 sets forth the procedures that must 14 | be followed and the standards that will be applied when a party seeks permission 15 | from the court to file material under seal. 16 1.2. Good Cause Statement. This action is likely to involve discovery that 17 | is confidential and privileged for which special protection from public disclosure 18 | and from use for any purpose other than prosecution of this action may be 19 | warranted. Such confidential and proprietary materials and information consist 29 | of, among other things, information pertaining to the investigation from Fontana 91 | Police Department and San Bernardino County Sherrifs Department of the 99 | underlying criminal activities, as well as peace officer personnel file information 93 | and/or documents which the parties agree include (1) Personal data, including 94 | marital status, family members, educational and employment history, home 25 addresses, or similar information; (2) Medical history; (8) Election of employee %6 benefits; (4) Employee advancement, appraisal or discipline; and (5) Complaints, 97 | investigations of complaints, if any, concerning an event or transaction in which | 2 peace officer participated, or which a peace officer perceived, and pertaining to the manner in which the peace officer performed his or her duties. STIPULATED PROTECTIVE ORDER

1 Such confidential materials and information consist of, among other things, 2 | materials which may be entitled to privileges and/or protections under the 3 | following: United States Constitution, First Amendment; the California 4 | Constitution, Article I, Section 1; California Penal Code §§ 832.5, 832.7 and 832.8; 5 | California Evidence Code §§ 1040 and 1048 et. seq; the Privacy Act of 1974, 5 6 | U.S.C. § 552; Health Insurance Portability and Accountability Act of 1996 7 | CHIPPA); the right to privacy; decisional law relating to such provisions; and 8 | information otherwise generally unavailable to the public, or which may be 9 | privileged or otherwise protected from disclosure under state or federal statutes, 10 | court rules, case decisions, or common law. 11 Defendants also contend that such confidential materials and information 12 | are entitled to the Official Information Privilege. Sanchez v. City of Santa Ana, 13 |

, 1033 (9th Cir. Cal. 1990); see also Kerr v. United States Dist. Ct. 14 | for.N.D. Cal.,

(9th Cir. Cal. 1975). Affd,

, 96S. Ct. 15 | 3229,

(1976). The information otherwise may be generally 16 unavailable to the public, or may be privileged or otherwise protected from 17 disclosure under state or federal statutes, court rules, case decisions, or common 18 law. 19 Further, discovery may require depositions, written discovery and/or the 0 production of certain information the public disclosure of which could comprise >] officer safety, and/or raise security issues. Additionally, public disclosure of such 9 information poses a substantial risk of embarrassment, oppression, and/or 74 physical harm to peace officers whose confidential information is disclosed. The risk of harm to peace officers is greater than with other government employees 35 due to the nature of their profession. The benefit of public disclosure of confidential information 1s minimal while the potential disadvantages are great. *6 Accordingly, to expedite the flow of information, to facilitate the prompt a resolution of disputes over confidentiality of discovery materials, to adequately 28 protect information the parties are entitled to keep confidential, to ensure that STIPULATED PROTECTIVE ORDER

| | the parties are permitted reasonable necessary uses of such material in 2 | preparation for and in the conduct of trial, to address their handling at the end of 3 | the litigation, and serve the ends of justice, a protective order for such information 4 | is justified in this matter. It is the intent of the parties that information will not 5 | be designated as confidential for tactical reasons and that nothing be so 6 | designated without a good faith belief that it has been maintained in a 7 | confidential, non-public manner, and there is good cause why it should not be part 8 | of the public record of this case. 2. DEFINITIONS 10 2.1 Action: Loretta Gurrola v, City of Fontana, Fontana Police I Department, Police Officer Chad Ebli, Police Officer Nicholas Straka, individually 12 | and in their official capacity as police officers with the City of Fontana/Fontana 13 | Police Department, DOES 8 to 10, individually and in their official capacity as 14 police officers and/or employees of the City of Fontana/Fontana Police 15 Department, Inclusive. 16 2.2 Challenging Party: a Party or Non-Party that challenges the 17 designation of information or items under this Order. 18 2.8 “CONFIDENTIAL” Information or Items: information (regardless of 19 | how it is generated, stored or maintained) or tangible things that qualify for 20 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 21 | the Good Cause Statement. 22 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 23 | their support staff). 24 2.5 Designating Party: a Party or Non-Party that designates information 25 | or items that it produces in disclosures or in responses to discovery as 26 | “CONFIDENTIAL.” 27 2.6 Disclosure or Discovery Material: all items or information, regardless 28 | of the medium or manner in which it is generated, stored, or maintained □□ STIPULATED PROTECTIVE ORDER

1 | Gncluding, among other things, testimony, transcripts, and tangible things), that 2 | are produced or generated in disclosures or responses to discovery in this matter. 3 2.7 Expert: a person with specialized knowledge or experience in a 4 | matter pertinent to the litigation who has been retained by a Party or its counsel 5 | to serve as an expert witness or as a consultant in this Action. 6 2.8 House Counsel: attorneys who are employees of a party to this Action. 7 | House Counsel does not include Outside Counsel of Record or any other outside 8 | counsel. 9 2.9 Non-Party: any natural person, partnership, corporation, 10 | association, or other legal entity not named as a Party to this action. 11 2.10 Outside Counsel of Record: attorneys who are not employees of a 12 | party to this Action but are retained to represent or advise a party to this Action 13 | and have appeared in this Action on behalf of that party or are affiliated with a 14 | law firm that has appeared on behalf of that party, including support staff. 15 2.11 Party: any party to this Action, including all of its officers, directors, 16 | employees, consultants, retained experts, and Outside Counsel of Record (and 17 | their support staffs). 18 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 19 | Discovery Material in this Action. 20 2.13 Professional Vendors: persons or entities that provide litigation 21 | support services (e.g., photocopying, videotaping, translating, preparing exhibits 22 | or demonstrations, and organizing, storing, or retrieving data in any form or 23 | medium) and their employees and subcontractors. 24 2.14 Protected Material: any Disclosure or Discovery Material that is 25 | designated as “CONFIDENTIAL.” 26 2.15 Receiving Party: a Party that receives Disclosure or Discovery 27 | Material from a Producing Party. 28 | 3. SCOPE 5. STIPULATED PROTECTIVE ORDER

1 The protections conferred by this Stipulation and Order cover not only 2 | Protected Material (as defined above), but also (1) any information copied or 3 | extracted from Protected Material; (2) all copies, excerpts, summaries, or 4 | compilations of Protected Material; and (3) any testimony, conversations, or 5 | presentations by Parties or their Counsel that might reveal Protected Material. 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 court-filed information to be 10 | introduced that was previously designated as confidential or maintained 11 | pursuant to this protective order becomes public and will be presumptively 12 | available to all members of the public, including the press, unless compelling 13 | reasons supported by specific factual findings to proceed otherwise are made to 14 | the trial judge in advance of the trial. See Kamakana v. City and Cty. of Honolulu, 15 |

, 1180-81 (9th Cir. 2006) (distinguishing “good cause” showing for 16 | sealing documents produced in discovery from “compelling reasons” standard 17 | when merits-related documents are part of court record). Accordingly, the terms 18 | of this protective order do not extend beyond the commencement of the trial. 19 | 5. DESIGNATING PROTECTED MATERIAL 20 5.1 Exercise of Restraint and Care in Designating Material for 21 | Protection. Each Party or Non-Party that designates information or items for 22 | protection under this Order must take care to limit any such designation to 23 | specific material that qualifies under the appropriate standards. The Designating 24 | Party must designate for protection only those parts of material, documents, 25 | items, or oral or written communications that qualify so that other portions of the 26 | material, documents, items, or communications for which protection 1s not 27 | warranted are not swept unjustifiably within the ambit of this Order. 28 -6- STIPULATED PROTECTIVE ORDER

1 Mass, indiscriminate, or routinized designations are prohibited. 2 | Designations that are shown to be clearly unjustified or that have been made for 3 | an improper purpose (e.g., to unnecessarily encumber the case development 4 | process or to impose unnecessary expenses and burdens on other parties) may 5 | expose the Designating Party to sanctions. 6 If it comes to a Designating Party’s attention that information or items that 7 | it designated for protection do not qualify for protection, that Designating Party 8 | must promptly notify all other Parties that it is withdrawing the inapplicable 9 | designation. 10 5.2. Manner and Timing of Designations. Except as otherwise provided 11 | in this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 12 | stipulated or ordered, Disclosure or Discovery Material that qualifies for 13 | protection under this Order must be clearly so designated before the material is 14 | disclosed or produced. 15 Designation in conformity with this Order requires: 16 (a) for information in documentary form (e.g., paper or electronic 17 | documents, but excluding transcripts of depositions or other pretrial or trial 18 | proceedings), that the Producing Party affix, at a minimum, the legend 19 | “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 20 | contains protected material. If only a portion or portions of the material on a page 21 | qualifies for protection, the Producing Party also must clearly identify the 22 | protected portion(s) (e.g., by making appropriate markings in the margins). 23 A Party or Non-Party that makes original documents available for 24 | inspection need not designate them for protection until after the inspecting Party 25 | has indicated which documents it would like copied and produced. During the 26 | inspection and before the designation, all of the material made available for 27 | inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has 28 | identified the documents it wants copied and produced, the Producing Party must 1: STIPULATED PROTECTIVE ORDER

1 | determine which documents, or portions thereof, qualify for protection under this 2 | Order. Then, before producing the specified documents, the Producing Party must 3 | affix the “CONFIDENTIAL legend” to each page that contains Protected Material. 4 | If only a portion or portions of the material on a page qualifies for protection, the 5 | Producing Party also must clearly identify the protected portion(s) (e.g., by 6 | making appropriate markings in the margins). 7 (b) for testimony given in depositions that the Designating Party 8 | identify the Disclosure or Discovery Material on the record, before the close of the 9 | deposition. 10 (c) for information produced in some form other than documentary 11 | and for any other tangible items, that the Producing Party affix in a prominent 12 | place on the exterior of the container or containers in which the information is 13 | stored the legend “CONFIDENTIAL.” If only a portion or portions of the 14 | information warrants protection, the Producing Party, to the extent practicable, 15 | shall identify the protected portion(s). 16 5.3 Inadvertent Failures to Designate. If timely corrected, an 17 | inadvertent failure to designate qualified information or items does not, standing 18 | alone, waive the Designating Party’s right to secure protection under this Order 19 | for such material. Upon timely correction of a designation, the Receiving Party 20 | must make reasonable efforts to assure that the material is treated in accordance 21 | with the provisions of this Order. 22 | 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 23 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 24 | designation of confidentiality at any time that is consistent with the Court’s 25 | Scheduling Order. 26 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 27 | resolution process under Local Rule 37-1, et seq. Any discovery motion must 28 | strictly comply with the procedures set forth in Local Rules 37-1, 37-2, and 37-3. 8. STIPULATED PROTECTIVE ORDER

1 6.3. Burden. The burden of persuasion in any such challenge proceeding 2 | shall be on the Designating Party. Frivolous challenges, and those made for an 3 | improper purpose (e.g., to harass or impose unnecessary expenses and burdens on 4 | other parties) may expose the Challenging Party to sanctions. Unless the 5 | Designating Party has waived or withdrawn the confidentiality designation, all 6 | parties shall continue to afford the material in question the level of protection to 7 | which it is entitled under the Producing Party’s designation until the Court rules 8 | on the challenge. 9} 7. ACCESS TO AND USE OF PROTECTED MATERIAL 10 7.1 Basic Principles. A Receiving Party may use Protected Material that 11 | is disclosed or produced by another Party or by a Non-Party in connection with 12 | this Action only for prosecuting, defending, or attempting to settle this Action. 13 | Such Protected Material may be disclosed only to the categories of persons and 14 | under the conditions described in this Order. When the Action has been 15 | terminated, a Receiving Party must comply with the provisions of section 13 below 16 | (FINAL DISPOSITION). 17 Protected Material must be stored and maintained by a Receiving Party at 18 | a location and in a secure manner that ensures that access is limited to the 19 | persons authorized under this Order. 20 7.2. Disclosure _of “CONFIDENTIAL” Information or Items. Unless 21 | otherwise ordered by the Court or permitted in writing by the Designating Party, 22 | a Receiving Party may disclose any information or item designated 23 | “CONFIDENTIAL?” only to: 24 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 25 | well as employees of said Outside Counsel of Record to whom it is reasonably 26 | necessary to disclose the information for this Action; 27 (b) the officers, directors, and employees (including House Counsel) 28 | of the Receiving Party to whom disclosure is reasonably necessary for this Action; 9. STIPULATED PROTECTIVE ORDER

1 (c) Experts (as defined in this Order) of the Receiving Party to whom 2 | disclosure is reasonably necessary for this Action and who have signed the 3 | “Acknowledgment and Agreement to Be Bound” (Exhibit A); 4 (d) the Court and its personnel; 5 (e) court reporters and their staff; 6 (f) professional jury or trial consultants, mock jurors, and 7 | Professional Vendors to whom disclosure is reasonably necessary for this Action 8 | and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit 9 | A); 10 (g) the author or recipient of a document containing the information 11 | or a custodian or other person who otherwise possessed or knew the information; 12 (h) during their depositions, witnesses, and attorneys for witnesses, 13 | in the Action to whom disclosure is reasonably necessary provided: (1) the 14 | deposing party requests that the witness sign the form attached as Exhibit A 15 | hereto; and (2) they will not be permitted to keep any confidential information 16 | unless they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A), 17 | unless otherwise agreed by the Designating Party or ordered by the Court. Pages 18 | of transcribed deposition testimony or exhibits to depositions that reveal 19 | Protected Material may be separately bound by the court reporter and may not be 20 | disclosed to anyone except as permitted under this Stipulated Protective Order; 21 | and 22 (i) any mediator or settlement officer, and their supporting personnel, 23 | mutually agreed upon by any of the parties engaged in settlement discussions. 24 | 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 25 | PRODUCED IN OTHER LITIGATION 26 If a Party is served with a subpoena or a court order issued in other 27 | litigation that compels disclosure of any information or items designated in this 28 | Action as “CONFIDENTIAL,” that Party must: -10- STIPULATED PROTECTIVE ORDER

1 (a) promptly notify in writing the Designating Party. Such notification 2 | shall include a copy of the subpoena or court order; 3 (b) promptly notify in writing the party who caused the subpoena or order 4 | to issue in the other litigation that some or all of the material covered by the 5 | subpoena or order is subject to this Protective Order. Such notification shall 6 | include a copy of this Stipulated Protective Order; and 7 (c) cooperate with respect to all reasonable procedures sought to be pursued 8 | by the Designating Party whose Protected Material may be affected. 9 If the Designating Party timely seeks a protective order, the Party served 10 | with the subpoena or court order shall not produce any information designated in 11 | this action as “CONFIDENTIAL” before a determination by the court from which 12 | the subpoena or order issued, unless the Party has obtained the Designating 13 | Party’s permission. The Designating Party shall bear the burden and expense of 14 | seeking protection in that court of its confidential material and nothing in these 15 | provisions should be construed as authorizing or encouraging a Receiving Party 16 | in this Action to disobey a lawful directive from another court. 17 | 9. A _NON-PARTYS PROTECTED MATERIAL SOUGHT TO BE 18 PRODUCED IN THIS LITIGATION 19 (a) The terms of this Order are applicable to information produced by a 20 | Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 21 | 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 23 | be 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 -ll- STIPULATED PROTECTIVE ORDER

1 (1) promptly notify in writing the Requesting Party and the Non- 2 | Party that some or all of the information requested is subject to a confidentiality 3 | agreement 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 6 | reasonably 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 10 | 14 days of receiving the notice and accompanying information, the Receiving 11 | Party may produce the Non-Party’s confidential information responsive to the 12 | discovery request. If the Non-Party timely seeks a protective order, the Receiving 13 | Party shall not produce any information in its possession or control that is subject 14 | to the confidentiality agreement with the Non-Party before a determination by 15 | the Court. Absent a court order to the contrary, the Non-Party shall bear the 16 | burden and expense of seeking protection in this Court of its Protected Material. 17 | 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 18 If a Receiving Party learns that, by inadvertence or otherwise, it has 19 | disclosed Protected Material to any person or in any circumstance not authorized 20 | under this Stipulated Protective Order, the Receiving Party must immediately (a) 21 | notify in writing the Designating Party of the unauthorized disclosures, (b) use 22 | its best efforts to retrieve all unauthorized copies of the Protected Material, (c) 23 | inform the person or persons to whom unauthorized disclosures were made of all 24 | the terms of this Order, and (d) request such person or persons to execute the 25 | “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit 26 | A. 27 | 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 28 PROTECTED MATERIAL -12- STIPULATED PROTECTIVE ORDER

1 When a Producing Party gives notice to Receiving Parties that certain 2 | inadvertently produced material is subject to a claim of privilege or other 3 | protection, the obligations of the Receiving Parties are those set forth in Federal 4 | Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 5 | whatever procedure may be established in an e-discovery order that provides for 6 | production without prior privilege review. Pursuant to Federal Rule of Evidence 7 | 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure 8 | of acommunication or information covered by the attorney-client privilege or work 9 | product protection, the parties may incorporate their agreement in the stipulated 10 | protective order submitted to the Court. 11 | 12. MISCELLANEOUS 12 12.1 Right to Further Relief. Nothing in this Order abridges the right of 13 | any person to seek its modification by the Court in the future. 14 12.2 Right to Assert Other Objections. By stipulating to the entry of this 15 | Protective Order, no Party waives any right it otherwise would have to object to 16 | disclosing or producing any information or item on any ground not addressed in 17 | this Stipulated Protective Order. Similarly, no Party waives any right to object 18 | on any ground to use in evidence of any of the material covered by this Protective 19 | 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 22 | may only be filed under seal pursuant to a court order authorizing the sealing of 23 | the specific Protected Material at issue; good cause must be shown in the request 24 | to file under seal. If a Party’s request to file Protected Material under seal is 25 | denied by the Court, then the Receiving Party may file the information in the 26 | public record unless otherwise instructed by the Court. 27 | 18. FINAL DISPOSITION 28 -13- STIPULATED PROTECTIVE ORDER

1 After the final disposition of this Action, within 60 days of a written request 2 | by the Designating Party, each Receiving Party must return all Protected 3 | Material to the Producing Party or destroy such material. As used in this 4 | subdivision, “all Protected Material” includes all copies, abstracts, compilations, 5 | summaries, and any other format reproducing or capturing any of the Protected 6 | Material. Whether the Protected Material is returned or destroyed, the Receiving 7 | Party must submit a written certification to the Producing Party (and, if not the 8 || same person or entity, to the Designating Party) by the 60 day deadline that (1) 9 | identifies (by category, where appropriate) all the Protected Material that was 10 | returned or destroyed, and (2) affirms that the Receiving Party has not retained 11 | any copies, abstracts, compilations, summaries or any other format reproducing 12 | or capturing any of the Protected Material. Notwithstanding this provision, 13 | counsel are entitled to retain an archival copy of all pleadings, motion papers, 14 | trial, deposition, and hearing transcripts, legal memoranda, correspondence, 15 | deposition and trial exhibits, expert reports, attorney work product, and 16 | consultant and expert work product, even if such materials contain Protected 17 | Material. Any such archival copies that contain or constitute Protected Material 18 | remain subject to this Protective Order as set forth in Section 4 (DURATION). 19 | 14. VIOLATION OF ORDER 20 Any violation of this Order may be punished by any and all appropriate 21 | measures including, without limitation, contempt proceedings and/or monetary 22 | sanctions. 23 | ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD. 24 MADRID LAW FIRM 25 DATED: November 11, 2025 /s/ Eduardo M. Madrid 26 Eduardo M. Madrid, Esq. Erica L. Madrid, Esq. 27 Attorneys for Plaintiff Loretta Gurrola 28 - 14- STIPULATED PROTECTIVE ORDER

1 JONES MAYER 2 DATED: November 11, 2025 /s/ Helen O. Kim 3 Angela M. Powell, Esq. Helen O. Kim, Esq. 4 Attorneys for Defendants City of Fontana, Fontana Police Department, 5 Police Officer Chad Ebli and Police Officer Nicholas Straka

7 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

DATED: November 12, 2025 9 HON. CHARLES F. EICK 10 United States Magistrate Judge 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -15- STIPULATED PROTECTIVE ORDER

l EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, [full name], of (full 4 | address], declare under penalty of perjury that I have read in its entirety and 5 | understand the Stipulated Protective Order that was issued by the United 6 | States District Court for the Central District of California on 7 | [date] in the case of [insert case name and number]. I agree to 8 | comply with and to be bound by all the terms of this Stipulated Protective Order 9 | I understand and acknowledge that failure to so comply could expose me to 10 | sanctions and punishment in the nature of contempt. I solemnly promise that I 11 | will not disclose in any manner any information or item that is subject to this 12 | Stipulated Protective Order to any person or entity except in strict compliance 13 | with the provisions of this Order. 14 I further agree to submit to the jurisdiction of the United States District 15 | Court for the Central District of California for the purpose of enforcing the terms 16 | of this Stipulated Protective Order, even if such enforcement proceedings occur 17 | after termination of this action. I hereby appoint 18 | [full name] of [full address and 19 | telephone number] as my California agent for service of process in connection 20 | with this action or any proceedings related to enforcement of this Stipulated 21 | Protective Order. 22 23 | Date: 24 | City and State where signed: 25 26 | Printed name: 27 28 | Signature: - 16 - STIPULATED PROTECTIVE ORDER