Lillie Palush, Erick Gloria, Monique Gloria individually and as Successor in...

| | James R. Touchstone, Esq., SBN 184584 ic ones mayet.com 2 elissa M. Ballard, Esq., SBN 185739 [email protected] | Thurgood M. Wynn, Esq., SBN 345199 umuicjones-mayer dom | JONES MAYE 3777 North Harbor Boulevard | Fullerton, CA 92835 Telephone: 14) 446-1400 | Facsimile: (714) 446-1448 | Attorneys for Defendants, COUNTY OF RIVERSIDE; RIVERSIDE | COUNTY’S SHERIFF’S DEPARTMENT; FIDEL REYES; SEBASTIAN MUNOZ; ANDRE | PALACIOS | Peter John Johnson, Esq. peicria jilaw<.com 1] W OFFICE OF JOHNSON AND JOHNSON 2125 Oak Grove Road, Suite 316 | Walnut Creek, CA 94598 Telephone: Oe) 952-8900 | Facsimile: (925) 952-8902 | [CAPTION CONTINUED ON NEXT PAGE] 15 UNITED STATES DISTRICT COURT 16 CENTRAL DISTRICT OF CALIFORNIA | LILLIE PALUSH, ERICK GLORIA, Case No. 5:25-cv-01410-DTB MONE GLORIA individually and as | SUCESSOR IN INTEREST FOR THE Honorable David T. Bristow ESTATE OF JOSEPH GLORIA, RICHARD | Courtroom: 4 | GLORIA, □ [PROPOSED] STIPULATED 21 Plaintiffs, ROTECTI ORDER 22 V. 23 | COUNTY OF RIVERSIDE, RIVERSIDE COUNTY SHERIFF’S DEPARTMENT, | FIDEL REYES, SEBASTIAN MUNOZ, ANDRE PALACIOS, and DOES 1-50, Action Filed: June 02, 2025 | inclusive; 26 Defendants. -l- | Michael W. Donaldson, Esq. tas tnt onal een fay conn | GRESSLEY AND DONALDSON, LLP 24630 Washington Avenue, Suite 202 | Murrieta, CA 92562 Telephone: (951) 319-3199 A Attorneys for Plaintiffs, | LILLIE PALUSH, ERICK GLORIA, MONIQUE GLORIA INDIVIDUALLY | and as Successor in Interest for the ESTATE OF JOSEPH GLORIA, |RICHARD GLORIA -2- I 1. A. PURPOSES AND LIMITATIONS 2 Discovery in this action is likely to involve production of confidential, | proprietary, or private information for which special protection from public disclosure | and from use for any purpose other than prosecuting this litigation may be warranted.

5 | Accordingly, the parties hereby stipulate to and petition the Court to enter the following | Stipulated Protective Order. The parties acknowledge that this Order does not confer | blanket protections on all disclosures or responses to discovery and that the protection 8 affords from public disclosure and use extends only to the limited information or items |that are entitled to confidential treatment under the applicable legal principles. The || parties further acknowledge, as set forth in Section 12.3, below, that this Stipulated | Protective Order does not entitle them to file confidential information under seal; Civil | Local Rule 79-5 sets forth the procedures that must be followed and the standards that | will be applied when a party seeks permission from the court to file material under seal.

14 B. GOOD CAUSE STATEMENT 15 One or more of the Parties represent that pre-trial discovery in this case may |/include matters that are confidential and privileged and may require the discovery of | and/or production of documents pertaining to the Riverside County Sheriff | Department’s investigation of the underlying criminal activities, as well as peace | officer personnel file information and/or documents which the Parties agree which may | include: (1) Personal data; (2) Medical history; (3) Election of employee benefits; (4) | Employee advancement, appraisal, or discipline; and (5) Complaints, or investigations | of complaints, if any, concerning an event or transaction in which a peace officer may | have participated, or which a peace officer may have perceived, and may pertaining to | the manner in which the peace officer performed his or her duties. Without waiving | objections to the production of such documentation and information, such confidential | materials and information consist of, among other things, materials entitled to privileges and/or protections under the following: United States Constitution, First Amendment; | the California Constitution, Article Il, Section 1; California Penal Code §§ 832.5, 832.7 | and 832.8; California Evidence Code §§ 1040 and 1043 et. seq; the Privacy Act of 1974, |SUS.C. § 552; Health Insurance Portability and Accountability Act of 1996 (HIPPA); |the right to privacy; decisional law relating to such provisions; and information | otherwise generally unavailable to the public, or which may be privileged or otherwise | protected from disclosure under state or federal statutes, court rules, case decisions, or common law. Defendants also contend that such confidential materials and information |1s entitled to the Official Information Privilege. Sanchez v. City of Santa Ana, 936 F.2d 8 | 1027, 1033 (9th Cir. Cal. 1990); see also Kerr v. United States Dist. Ct. for N.D. Cal. | SLI F.2d 192, 198 (9th Cir. Cal. 1975). Aff'd, 426 U.S. 394, 96S. Ct. 3229, 48 L.Ed.2d 10 | 725 (1976). Further, discovery may require depositions, written discovery and/or the | production of certain Riverside County Sheriff Department policies and procedures 12 peace officer training information the public disclosure of which may could 13 comprise officer safety, and/or raise security issues. Defendants contend that public | disclosure of such material and information poses a substantial risk of embarrassment, | oppression and/or physical harm to peace officers whose confidential information is || disclosed. Defendants further contend that this potential risk of harm to peace officers 17 greater than with other government employees due to the nature of their profession.

18 | Finally, Defendants contend that the benefit of public disclosure of confidential | information is minimal while the potential disadvantages may be are great.

20 Accordingly, to expedite the flow of information, to facilitate the prompt 21 resolution of disputes over confidentiality of discovery materials, to adequately protect | information the parties are entitled to keep confidential, to ensure that the parties are 23 permitted reasonable necessary uses of such material in preparation for and in the | conduct of trial, to address their handling at the end of the litigation, and serve the ends |of justice, a protective order for such information is justified in this matter. It 1s the intent of the parties that information will not be designated as confidential for tactical reasons and that nothing be so without a good faith belief that it has been maintained in 28 confidential, non-public manner, and there is good cause why it should not be part of STIPULATED PROTECTIVE ORDER | | the public record of this case 2 2. DEFINITIONS 3 2.1 Action: Lillie Palush, Erick Gloria, Monique Gloria individually and as | Successor in Interest for the Estate of Joseph Gloria, and Richard Gloria v. County of | Riverside, Riverside County Sheriff's Department, Riverside County Sheriff-Coroner | Chad Bianco, and DOES 1-50, United District Court, Central District, Case No. 5:25- ||cv-01410 8 2.2 Challenging Party: A Party or Non-Party that challenges the designation | of information or items under this Order.

10 2.3 “CONFIDENTIAL” Information or Items: Information (regardless of how 11 is generated, stored or maintained) or tangible things that qualify for protection under || Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause | Statement.

14 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their | support staff).

16 2.5 Designating Party: A Party or Non-Party that designates information or |items that it produces in disclosures or in responses to discovery as | “CONFIDENTIAL.”

19 2.6 Disclosure or Discovery Material: All items or information, regardless of | the medium or manner in which it is generated, stored, or maintained (including, among | other things, testimony, transcripts, and tangible things), that are produced or generated 22 disclosures or responses to discovery in this matter.

23 2.7 Expert: A person with specialized knowledge or experience in a matter | pertinent to the litigation who has been retained by a Party or its counsel to serve as an | expert witness or as a consultant in this Action.

26 2.8 House Counsel: Attorneys who are employees of a party to this Action.

27 | House Counsel does not include Outside Counsel of Record or any other outside | counsel.

STIPULATED PROTECTIVE ORDER 1 2.9 Non-Party: Any natural person, partnership, corporation, association, or | other legal entity not named as a Party to this action.

3 2.10 Qutside Counsel of Record: Attorneys who are not employees of a party 4 this Action but are retained to represent or advise a party to this Action and have appeared in this Action on behalf of that party or are affiliated with a law firm which | has appeared on behalf of that party, and includes support staff.

7 2.11 Party: Any party to this Action, including all of its officers, directors, | employees, consultants, retained experts, and Outside Counsel of Record (and their | support staffs).

10 2.12 Producing Party: A Party or Non-Party that produces Disclosure or | Discovery Material in this Action.

12 2.13 Professional Vendors: Persons or entities that provide litigation support |/services (e.g., photocopying, videotaping, translating, preparing exhibits or | demonstrations, and organizing, storing, or retrieving data in any form or medium) and | their employees and subcontractors.

16 2.14 Protected Material: Any Disclosure or Discovery Material that is | designated as “CONFIDENTIAL.”

18 2.15 Receiving Party: A Party that receives Disclosure or Discovery Material || from a Producing Party.

20 3. SCOPE 21 The protections conferred by this Stipulation and Order cover not only Protected | Material (as defined above), but also (1) any information copied or extracted from || Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected | Material; and (3) any testimony, conversations, or presentations by Parties or their | Counsel that might reveal Protected Material.

26 Any use of Protected Material at trial shall be governed by the orders of the trial judge. This Order does not govern the use of Protected Material at trial.

STIPULATED PROTECTIVE ORDER I 4. DURATION 2 Should any Protected Material become part of the public record at trial or | otherwise (such as where the Court denies the request to file under seal), this | Protective Order shall no longer apply to such portions at Trial which became part of | the public record, with the exception that all such material/documents, whether part | of the public record or not, must still be returned in compliance with Section 13: Final | Disposition. Should any portion of the Protected Material remain confidential until | trial, during any portion of the trial of this action which could entail the discussion or | disclosure of Confidential Information, each Party may request the opportunity to || show good cause to the Court as to why access to the courtroom should be limited to | parties, their counsel and other designated representative, experts or consultants who || agreed to be bound by this stipulation/protective order, and court personnel.

13 For all portions of the Protected Material after final disposition of the Trial, | whether they became part of the public record or not, the confidentiality obligations | by this Order shall remain in full effect. Final disposition shall be deemed to be the | later of (1) dismissal of all claims and defenses in this Action, with or without | prejudice; (2) In any event wherein all remaining claims in this matter are remanded | to State Court or severed from the Federal matter and returned to State Court; and/or ||(3) final judgment herein after the completion and exhaustion of all appeals, re- | hearings, remands, trials, or reviews of this Action, including the time limits for filing 21 motions or applications for extension of time pursuant to applicable law.

22 5. DESIGNATING PROTECTED MATERIAL 23 5.1 Exercise of Restraint and Care in Designating Material for Protection.

24 | Each Party or Non-Party that designates information or items for protection under this Order must take care to limit any such designation to specific material that qualifies under the appropriate standards. The Designating Party must designate for protection | only those parts of material, documents, items, or oral or written communications that | qualify so that other portions of the material, documents, items, or communications for STIPULATED PROTECTIVE ORDER | which protection is not warranted are not swept unjustifiably within the ambit of this | Order.

3 Mass, indiscriminate, or routinized designations are prohibited. Designations that | are shown to be clearly unjustified or that have been made for an improper purpose |(e.g., to unnecessarily encumber the case development process or to impose | unnecessary expenses and burdens on other parties) may expose the Designating Party | to sanctions.

8 If it comes to a Designating Party’s attention that information or items that it | designated for protection do not qualify for protection, that Designating Party must | promptly notify all other Parties that it is withdrawing the inapplicable designation.

11 5.2 Manner and Timing of Designations. Except as otherwise provided in this || Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated 13 ordered, Disclosure or Discovery Material that qualifies for protection under this | Order must be clearly so designated before the material is 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 STIPULATED PROTECTIVE ORDER l determine which documents, or portions thereof, qualify for protection under this 2 Order. Then, before producing the specified documents, the Producing Party 3 must affix the “CONFIDENTIAL legend” to each page that contains Protected 4 Material. If only a portion or portions of the material on a page qualifies for 5 protection, the Producing Party also must clearly identify the protected portion(s) 6 (e.g., by 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 9 the deposition all protected testimony.

10 (c) for information produced in some form other than documentary and 11 for any other tangible items, that the Producing Party affix in a prominent place 12 on the exterior of the container or containers in which the information is stored 13 the legend “CONFIDENTIAL.” If only a portion or portions of the information 14 warrants protection, the Producing Party, to the extent practicable, shall identify 15 the protected portion(s).

16 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent | failure to designate qualified information or items does not, standing alone, waive the | Designating Party’s right to secure protection under this Order for such material. Upon | timely correction of a designation, the Receiving Party must make reasonable efforts to | assure that the material is treated in accordance with the provisions of this Order.

21 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 22 6.1 Timing of Challenges. Any Party or Non-Party may challenge a | designation of confidentiality at any time that is consistent with the Court’s Scheduling | Order.

25 6.2 Meet_and Confer. The Challenging Party shall initiate the dispute | resolution process under Local Rule 37.1 et seq.

27 6.3. The burden of persuasion in any such challenge proceeding shall be on the | Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., STIPULATED PROTECTIVE ORDER | | to harass or impose unnecessary expenses and burdens on other parties) may expose the | Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn 3 confidentiality designation, all parties shall continue to afford the material in | question the level of protection to which it is entitled under the Producing Party’s | designation until the Court rules on the challenge.

6 7. ACCESS TO AND USE OF PROTECTED MATERIAL 7 7.1. Basic Principles. A Receiving Party may use Protected Material that is | disclosed or produced by another Party or by a Non-Party in connection with this Action |only for prosecuting, defending, or attempting to settle this Action. Such Protected | Material may be disclosed only to the categories of persons and under the conditions | described in this Order. When the Action has been terminated, a Receiving Party must | comply with the provisions of section 13 below (FINAL DISPOSITION).

13 Protected Material must be stored and maintained by a Receiving Party at a | location and in a secure manner that ensures that access is limited to the persons | authorized under this Order.

16 72 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise | ordered by the court or permitted in writing by the Designating Party, a Receiving Party | may disclose any information or item designated “CONFIDENTIAL” only to: 19 (a) The Receiving Party’s Outside Counsel of Record in this Action, as 20 well as employees of said Outside Counsel of Record to whom it is reasonably 21 necessary to disclose the information for this Action; 22 (b) the officers, directors, and employees (including House Counsel) of 23 the Receiving Party to whom disclosure is reasonably necessary for this Action; 24 (c) Experts (as defined in this Order) of the Receiving Party to whom 25 disclosure is reasonably necessary for this Action and who have signed the 26 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 27 (d) the court and its personnel; 28 (e) court reporters and their staff; STIPULATED PROTECTIVE ORDER 1 (f) professional jury or trial consultants, mock jurors, and Professional 2 Vendors to whom disclosure is reasonably necessary for this Action and who 3 have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 4 (g) the author or recipient of a document containing the information or 5 a custodian or other person who otherwise possessed or knew the information; 6 (h) during their depositions, witnesses ,and attorneys for witnesses, in 7 the Action to whom disclosure is reasonably necessary provided: (1) The 8 deposing party requests that the witness sign the form attached as Exhibit 1 9 hereto; and (2) they will not be permitted to keep any confidential information 10 unless they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit 11 A), unless otherwise agreed by the Designating Party or ordered by the court.

12 Pages of transcribed deposition testimony or exhibits to depositions that reveal 13 Protected Material may be separately bound by the court reporter and may not be 14 disclosed to anyone except as permitted under this Stipulated Protective Order; 15 and 16 (i) any mediator or settlement officer, and their supporting personnel, 17 mutually agreed upon by any of the parties engaged in settlement discussions.

18 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED | PRODUCED IN OTHER LITIGATION 20 If a Party is served with a subpoena or a court order issued in other litigation that |compels disclosure of any information or items designated in this Action as | “CONFIDENTIAL,” that Party must: 23 (a) Promptly notify in writing the Designating Party. Such notification 24 shall include a copy of the subpoena or court order; 25 (b) promptly notify in writing the party who caused the subpoena or 26 order to issue in the other litigation that some or all of the material covered by 27 the subpoena or order is subject to this Protective Order. Such notification shall 28 include a copy of this Stipulated Protective Order; and STIPULATED PROTECTIVE ORDER 1 (c) cooperate with respect to all reasonable procedures sought to be 2 pursued by the Designating Party whose Protected Material may be affected.

3 If the Designating Party timely seeks a protective order, the Party served with the | subpoena or court order shall not produce any information designated in this action as “CONFIDENTIAL” before a determination by the court from which the subpoena or | order issued, unless the Party has obtained the Designating Party’s permission. The | Designating Party shall bear the burden and expense of seeking protection in that court | of its confidential material and nothing in these provisions should be construed as | authorizing or encouraging a Receiving Party in this Action to disobey a lawful directive | from another court.

11 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE | PRODUCED IN THIS LITIGATION 13 (a) The terms of this Order are applicable to information produced by a 14 Non-Party in this Action and designated as “CONFIDENTIAL.” Such 15 information produced by Non-Parties in connection with this litigation is 16 protected by the remedies and relief provided by this Order. Nothing in these 17 provisions should be construed as prohibiting a Non-Party from seeking 18 additional protections.

19 (b) In the event that a Party is required, by a valid discovery request, to 20 produce a Non-Party’s confidential information in its possession, and the Party 21 is subject to an agreement with the Non-Party not to produce the Non-Party’s 22 confidential information, then the Party shall: 23 (1) Promptly notify in writing the Requesting Party and the Non- 24 Party that some or all of the information requested is subject to a 25 confidentiality agreement with a Non-Party; 26 (2) promptly provide the Non-Party with a copy of the Stipulated 27 Protective Order in this Action, the relevant discovery request(s), and a 28 reasonably specific description of the information requested; and STIPULATED PROTECTIVE ORDER I (3) make the information requested available for inspection by 2 the Non-Party, if requested.

3 (c) If the Non-Party fails to seek a protective order from this court 4 within 14 days of receiving the notice and accompanying information, the 5 Receiving Party may produce the Non-Party’s confidential information 6 responsive to the discovery request. If the Non-Party timely seeks a protective 7 order, the Receiving Party shall not produce any information in its possession or 8 control that is subject to the confidentiality agreement with the Non-Party before 9 a determination by the court. Absent a court order to the contrary, the Non-Party 10 shall bear the burden and expense of seeking protection in this court of its 11 Protected Material.

12 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 13 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed | Protected Material to any person or in any circumstance not authorized under this || Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing || the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve | all unauthorized copies of the Protected Material, (c) inform the person or persons to | whom unauthorized disclosures were made of all the terms of this Order, and (d) request ||such person or persons to execute the “Acknowledgment and Agreement to Be Bound” | that is attached hereto as Exhibit A.

21 11. INADVERTENT PRODUCTION OF _ PRIVILEGED _OR | OTHERWISE PROTECTED MATERIAL 23 When a Producing Party gives notice to Receiving Parties that certain 24 inadvertently produced material is subject to a claim of privilege or other protection, 25 obligations of the Receiving Parties are those set forth in Federal Rule of Civil | Procedure 26(b)\(5)(B). This provision is not intended to modify whatever procedure may be established in an e-discovery order that provides for production without prior | privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the STIPULATED PROTECTIVE ORDER | parties reach an agreement on the effect of disclosure of a communication or | information covered by the attorney-client privilege or work product protection, the | parties may incorporate their agreement in the stipulated protective order submitted to | the court.

5 12. MISCELLANEOUS 6 12.1 Right to Further Relief. Nothing in this Order abridges the right of any | person to seek its modification by the Court in the future.

8 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 | disclosing or producing any information or item on any ground not addressed in this | Stipulated Protective Order. Similarly, no Party waives any right to object on any | ground to use in evidence of any of the material covered by this Protective Order.

13 12.3 Filing Protected Material. A Party that seeks to file under seal any | Protected Material must comply with Civil Local Rule 79-5. Protected Material may | only be filed under seal pursuant to a court order authorizing the sealing of the specific | Protected Material at issue. If a Party's request to file Protected Material under seal is ||denied by the court, then the Receiving Party may file the information in the public ||record unless otherwise instructed by the court.

19 13. FINAL DISPOSITION 20 After the final disposition of this Action, as defined in paragraph 4, within 60 | days of a written request by the Designating Party, each Receiving Party must return all | Protected Material to the Producing Party or destroy such material. As used in this subdivision, “all Protected Material” includes all copies, abstracts, compilations, |summaries, and any other format reproducing or capturing any of the Protected | Material. Whether the Protected Material is returned or destroyed, the Receiving Party || must submit a written certification to the Producing Party (and, if not the same person 27 entity, to the Designating Party) by the 60 day deadline that (1) identifies (by || category, where appropriate) all the Protected Material that was returned or destroyed STIPULATED PROTECTIVE ORDER |and (2)affirms that the Receiving Party has not retained any copies, abstracts, | compilations, summaries or any other format reproducing or capturing any of the | Protected Material. Notwithstanding this provision, Counsel are entitled to retain an | archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, | legal memoranda, correspondence, deposition and trial exhibits, expert reports, attorney | work product, and consultant and expert work product, even if such materials contain | Protected Material. Any such archival copies that contain or constitute Protected | Material remain subject to this Protective Order as set forth in Section (DURATION).

9 14. Any violation of this Order may be punished by any and all appropriate 10 measures including, without limitation, contempt proceedings and/or monetary | sanctions.

12 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

13 | Dated: January 27, 2026 Respectfully submitted, 14 JONES MAYER 16 By: /s/ Melissa M. Ballard James R. Touchstone 17 Melissa M. Ballard Thurgood M. Wynn 18 Attomeys for Defendants, COUNTY OF RIVERSIDE; RIVERSIDE 19 COUNTY’S SHERIFF’S DEPARTMENT; FIDEL REYES; 20 SEBASTIAN MUNOZ; ANDRE PALACIOS | Dated: January 27, 2026 LAW OFFICE OF JOHNSON AND JOHNSON 24 By: /s/ Peter John Johnson Peter John Johnson, Esq.

25 Attorneys for Plaintiffs, LILLIE PALUSH, ERICK GLORIA, 26 MONTouE GLORIA INDIVIDUALLY and as Successor in 27 Interest for the ESTATE OF JOSEPH GLORIA, RICHARD GLORIA 28 [SIGNATURES CONTINUE ON NEXT PAGE] -15- STIPULATED PROTECTIVE ORDER l | Dated: January 27, 2026 GRESSLEY AND DONALDSON, LLP By: /s/ Michael W. Donaldson 4 Michael W. Donaldson, Esq.

5 Attorneys for Plaintiffs, LILLIE PALUSH, ERICK GLORIA, 6 Momlote GLORIA INDIVIDUALLY and as Successor in 7 Interest for the ESTATE OF JOSEPH GLORIA, RICHARD GLORIA 10 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

DATED: January 28, 2026 12 DAVID T. BRISTOW 13 UNITED STATES MAGISTRATE JUDGE - 16- STIPULATED PROTECTIVE ORDER I EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 [print or type full name], of 4 [print or type full address], declare under penalty of perjury that | [have read in its entirety and understand the Stipulated Protective Order that was issued | by the United States District Court for the Central District of California on [ |in the case of Lillie Palush, Erick Gloria, Monique Gloria individually and as | Successor in Interest for the Estate of Joseph Gloria, and Richard Gloria v. County of | Riverside, Riverside County Sheriff's Department, Riverside County Sheriff-Coroner | Chad Bianco, and DOES 1-50, United District Court, Central District, Case No. 5:25- | cv-0/4/0 [insert formal name of the case and the number and initials assigned to 12 by the court]. I agree to comply with and to be bound by all the terms of this | Stipulated Protective Order and I understand and acknowledge that failure to so comply 14 could expose me to sanctions and punishment in the nature of contempt. I solemnly | promise that I will not disclose in any manner any information or item that is subject 16 this Stipulated Protective Order to any person or entity except in strict compliance | with the provisions of this Order.

18 | I further agree to submit to the jurisdiction of the United States District Court for the | Central District of California for the purpose of enforcing the terms of this Stipulated | Protective Order, even if such enforcement proceedings occur after termination of this action. I hereby appoint [print or type full name] of 22 [print or type full address and telephone 23 number] as my California agent for service of process in connection with this action or 24 proceedings related to enforcement of this Stipulated Protective Order.

25 | Date: | City and State where sworn and signed: | Printed name: | Signature: STIPULATED PROTECTIVE ORDER