Nieto

Leonard C. Herr, #081896 Caren L. Curtiss, #311218 HERR PEDERSEN & BERGLUND LLP Attorneys at Law 100 Willow Plaza, Suite 300 Visalia, California 93291 Telephone: (559) 636-0200

Attorneys for Defendants, CITY OF VISALIA, CHIEF JASON

SALAZAR, OFFICER ANTONIO MATTOS, OFFICER ALEXANDER

CRUZ and SERGEANT RYAN PARK

7 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA, FRESNO DIVISION

URIEL NIETO, Case No. 1:24-cv-00741-JLT-

BAM

Plaintiff, [PROPOSED] STIPULATED v. PROTECTIVE ORDER

14 CITY OF VISALIA, a municipal entity; CHIEF JASON SALAZAR, in his individual and official capacity; OFFICER ANTONIO MATOS; OFFICER ALEXANDER CRUZ and SERGEANT RYAN PARK and DOES 1-5, inclusive, 18 Defendants.

20 IT IS HEREBY STIPULATED by and among the Parties hereto, through their respective counsel of record, that the Court grant a protective order, as follows: 1. PURPOSES AND LIMITATIONS Disclosure and discovery activity in this action are likely to involve production of confidential, …