! | JUSTIN W. CLARK, State Bar No. 235477 iglark(@ilbaclaw.com 2 | SHAWYANE EMADL, State Bar No. 352292 semadi @ibaclaw.com 3 || LAWRENCE BEACH ALLEN & CHOI, PC 150 South Los Robles Avenue, Suite 660 4 || Pasadena, California 91101 5 Telephone No. (818) 545-1925 Attorneys for Defendants 6 || County of Los Angeles and 4 Deputy Larry Parks 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 | JEFFREY PAUL, Case No. 2:25-cv-00008-WLH-E 12 Plaintiff, Honorable Wesley L. Hsu 13 Vs.

STIPULATED PROTECTIVE

14 || LOS ANGELES COUNTY, ORDER

DEPUTY LARRY PARKS, AND

15 | DOE DEPUTIES 1-10, 16 Defendants. 7 Complaint Filed: January 2, 2025 18 19 | 1, A. PURPOSES AND LIMITATIONS. 20 Discovery in this action is likely to involve production of confidential, 21 || proprietary, or private information for which special protection from public 22 | disclosure and from use for any purpose other than prosecuting this litigation may 23 || be warranted. Accordingly, the parties hereby stipulate to and petition the Court 24 || to enter the following Stipulated Protective Order. The parties acknowledge that 25 || this Order does not confer blanket protections on all disclosures or responses to 26 || discovery and that the protection it affords from public disclosure and use extends 27 || only to the limited information or items that are entitled to confidential treatment 28 || under the applicable legal principles.

1 B. GOOD CAUSE STATEMENT. 2 This lawsuit arises from an alleged unlawful seizure and use of force 3 || incident which occurred in a City of Duarte Public Safety Office (the, “Office’’) 4 || on June 28, 2024. Plaintiff Jeffrey Paul (“Plaintiff”) alleges that Los Angeles 5 || County Sheriff's Department (““LASD”) Deputy Larry Parks illegally seized the 6 || Plaintiff and used excessive force in his efforts to detain him (hereinafter, “the 7 || Incident”). Discovery in this case will likely involve the production of 8 || information and documents related to the justification for any alleged seizure of 9 || Plaintiff, the use of force (if any), the manner in which it was conducted, as well 10 || as any other documents which may be subject to various privileges that would bar 11 || them from public disclosure or filing. 12 This action is likely to involve production of information for which special 13 || protection from public disclosure and from use for any purpose other than 14 || prosecution of this action is warranted and appropriate. Such confidential and 15 || proprietary materials and information may consist of, among other things, CCTV 16 || footage from the location where the Incident took place depicting Plaintiff, 17 || reports and documents related to the Incident, and other information implicating 18 || privacy rights of the parties and/or third parties (such as, without limitation, 19 || medical records or other documents subject to privilege) that is otherwise 20 || generally unavailable to the public, or which may be privileged or otherwise 21 || protected from disclosure under state or federal statutes, court rules, case 22 || decisions, or common law. Accordingly, to expedite the flow of information, to 23 || facilitate the prompt resolution of disputes over confidentiality of discovery 24 || materials, to adequately protect information the parties are entitled to keep 25 || confidential, to ensure that the parties are permitted reasonable necessary uses of 26 || such material in preparation for and in the conduct of trial, to address their 27 || handling at the end of the litigation, and serve the ends of justice, a protective 28 || order for such information is justified in this matter. It 1s the intent of the parties

1 || that information will not be designated as confidential for tactical reasons and that 2 || nothing be so designated without a good faith belief that it has been maintained in 3 || a confidential, non-public manner, and there is good cause why it should not be 4 || part of the public record of this case. 5 6 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER 7 SEAL. 8 The parties further acknowledge, as set forth in Section 12.3, below, that 9 || this Stipulated Protective Order does not entitle them to file confidential 10 || information under seal; Local Civil Rule 79-5 sets forth the procedures that must 11 || be followed and the standards that will be applied when a party seeks permission 12 || from the court to file material under seal. 13 There is a strong presumption that the public has a right to access judicial 14 || proceedings and records in civil cases. In connection with non-dispositive 15 || motions, good cause must be shown to support a filing under seal. See Kamakana 16 || v. City and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. 17 || Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. 18 || Sony Electrician., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated 19 || protective orders require good cause showing), and a specific showing of good 20 || cause or compelling reasons with proper evidentiary support and legal 21 || justification must be made with respect to Protected Material that a party seeks to 22 || file under seal. The parties’ mere designation of Disclosure or Discovery 23 || Material as CONFIDENTIAL does not—without the submission of competent 24 || evidence by declaration, establishing that the material sought to be filed under 25 || seal qualifies as confidential, privileged, or otherwise protectable—constitute 26 || good cause. 27 Further, if a party requests sealing related to a dispositive motion or trial, 28 || then compelling reasons, not only good cause, for the sealing must be shown, and

1 || the relief sought shall be narrowly tailored to serve the specific interest to be 2 || protected. See Pintos v. Pacific Creditors Ass ’n, 605 F.3d 665, 677-79 (9th Cir. 3 || 2010). For each item or type of information, document, or thing sought to be 4 || filed or introduced under seal in connection with a dispositive motion or trial, the 5 || party seeking protection must articulate compelling reasons, supported by specific 6 || facts and legal justification, for the requested sealing order. Again, competent 7 || evidence supporting the application to file documents under seal must be 8 || provided by declaration. 9 Any document that is not confidential, privileged, or otherwise protectable 10 || in its entirety will not be filed under seal if the confidential portions can be 11 || redacted. If documents can be redacted, then a redacted version for public 12 || viewing, omitting only the confidential, privileged, or otherwise protectable 13 || portions of the document, shall be filed. Any application that seeks to file 14 || documents under seal in their entirety should include an explanation of why 15 || redaction is not feasible. 16 17 || 2. DEFINITIONS. 18 22.1 Action: Jeffrey Paul v. Los Angeles County, et al. 19 (Case No. 2:25-cv-0008-WLH-E). 20 22.2 Challenging Party: a Party or Non-Party that challenges 21 || the designation of information or items under this Order. 22 22.3. “CONFIDENTIAL” Information or Items: information (regardless of 23 || how it is generated, stored or maintained) or tangible things that qualify for 24 || protection under Federal Rule of Civil Procedure 26(c), and as specified above in 25 || the Good Cause Statement. 26 2.4 Counsel: Outside Counsel of Record (including, where necessary, 27 || their support staff). 28 | //

1 2.5 Designating Party: a Party or Non-Party that designates information 2 || or items thatit produces in disclosures or in responses to discovery as 3 || “CONFIDENTIAL.” 4 2.6 Disclosure or Discovery Material: all items or information, 5 || regardless of the medium or manner in which it is generated, stored, or 6 || maintained (including, among other things, testimony, transcripts, and tangible 7 || things), that are produced or generated in disclosures or responses to discovery in 8 || this matter, 9 2.7 Expert: a person with specialized knowledge or experience in a 10 || matter pertinent to the litigation who has been retained by a Party or its counsel to 11 || serve as an expert witness or as a consultant in this Action. 12 2.8 In-House Counsel: attorneys who are employees of a party to this 13 || Action. House Counsel does not include Outside Counsel of Record or any other 14 || outside counsel. 15 2.9 Non-Party: any natural person, partnership, corporation, association, 16 || of other legal entity not named as a Party to this action. 17 2.10 Outside Counsel of Record: attorneys who are not employees of a 18 || party to this Action but are retained to represent or advise a party to this Action 19 || and have appeared in this Action on behalf of that party or are affiliated with a 20 || law firm which has appeared on behalf of that party, and includes support staff. 21 2.11 Party: any party to this Action, including all of its officers, directors, 22 || employees, consultants, retained experts, and Outside Counsel of Record (and 23 || their support staffs). 24 2.12 Producing Party: a Party or Non-Party that produces Discovery 25 || Material in this Action. 26 2.13 Professional Vendors: persons or entities that provide litigation 27 || support services (e.g., photocopying, videotaping, translating, preparing exhibits 28

1 || or demonstrations, and organizing, storing, or retrieving data in any form or 2 || medium) and their employees and subcontractors. 3 2.14 Protected Material: any Disclosure or Discovery Material that is 4 || designated as “CONFIDENTIAL.” 5 2.15 Receiving Party: a Party that receives Disclosure or Discovery 6 || Material from a Producing Party. 7 8 13. SCOPE 9 The protections conferred by this Stipulation and Order cover not only 10 || Protected Material (as defined above), but also (1) any information copied or 11 || extracted from Protected Material; (2) all copies, excerpts, summaries, or 12 || compilations of Protected Material; and (3) any testimony, conversations, or 13 || presentations by Parties or their Counsel that might reveal Protected Material. 14 Any use of Protected Material at trial shall be governed by the orders of the 15 || trial judge. This Order does not govern the use of Protected Material at trial. 16 17 || 4. DURATION 18 FINAL DISPOSITION of the action is defined as the conclusion of any 19 || appellate proceedings, or, if no appeal is taken, when the time for filing of an 20 || appeal has run. Except as set forth below, the terms of this protective order apply 21 || through FINAL DISPOSITION of the action. The parties may stipulate that they 22 || will be contractually bound by the terms of this agreement beyond FINAL 23 || CONFIDENTIAL or maintained pursuant to this protective order used or 24 || appellate proceedings, or, if no appeal is taken, when the time for filing of an 25 || appeal has run. Except as set forth below, the terms of this protective order apply 26 || through FINAL DISPOSITION of the action. The parties may stipulate that they 27 || will be contractually bound by the terms of this agreement beyond FINAL 28

1 | DISPOSITION, but will have to file a separate action for enforcement of the 2 || agreement once all proceedings in this case are complete. 3 Once a case proceeds to trial, information that was designated as 4 | CONFIDENTIAL or maintained pursuant to this protective order used or 5 || introduced as an exhibit at trial becomes public and will be presumptively 6 || available to all members of the public, including the press, unless compelling 7 || reasons supported by specific factual findings to proceed otherwise are made to 8 || the trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81 9 || (distinguishing “good cause “showing for sealing documents produced in 10 || discovery from “compelling reasons “standard when merits-related documents are 11 || part of court record). Accordingly, for such materials, the terms of this protective 12 || order do not extend beyond the commencement of the trial. 13 14 | 5. DESIGNATING PROTECTED MATERIAL 15 5.1 Exercise of Restraint and Care in Designating Material for Protection. 16 || ach Party or Non-Party that designates information or items for protection under 17 || this Order must take care to limit any such designation to specific material that 18 || qualifies under the appropriate standards. The Designating Party must designate 19 || for protection only those parts of material, documents, items, or oral or written 20 || communications that qualify so that other portions of the material, documents, 21 || items, or communications for which protection 1s not warranted are not swept 22 || unjustifiably within the ambit of this Order. 23 Mass, indiscriminate, or routine designations are prohibited. Designations 24 || that are shown to be clearly unjustified or that have been made for an improper 25 || purpose (e.g., to unnecessarily encumber the case development process or to 26 || impose unnecessary expenses and burdens on other parties) may expose the 27 || Designating Party to sanctions. 28 | //

1 If it comes to a Designating Party’s attention that information or items that 2 || it designated for protection do not qualify for protection, that Designating Party 3 || must promptly notify all other Parties that it is withdrawing the inapplicable 4 || designation. 5 5.2. Manner and Timing of Designations. Except as otherwise provided 6 || in his Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 7 || stipulated or ordered, Disclosure or Discovery Material that qualifies for 8 || protection under this Order must be clearly so designated before the material is 9 || disclosed or produced. 10 Designation in conformity with this Order requires: 11 (a) for information in documentary form (e.g., paper or electronic 12 || documents, but excluding transcripts of depositions or other pretrial or trial 13 || proceedings), that the Producing Party affix at a minimum, the legend 14 || “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 15 || contains protected material. If only a portion or portions of the material on a page 16 || qualifies for protection, the Producing Party also must clearly identify the 17 || protected portion(s) (e.g., by making appropriate markings in the margins). The 18 || CONFIDENTIAL legend shall not obscure the contents of any page to which it is 19 || affixed, impede the ability to readily read the page’s contents, or appear over any 20 || words contained in the document. 21 A Party or Non-Party that makes original documents available for 22 || inspection need not designate them for protection until after the inspecting Party 23 || has indicated which documents it would like copied and produced. During the 24 || inspection and before the designation, all of the material made available for 25 || inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has 26 || identified the documents it wants copied and produced, the Producing Party must 27 || determine which documents, or portions thereof, qualify for protection under this 28 || Order. Then, before producing the specified documents, the Producing Party

1 || must affix the “CONFIDENTIAL legend” to each page that contains Protected 2 || Material. If only a portion or portions of the material on a page qualifies for 3 || protection, the Producing Party also must clearly identify the protected portion(s) 4 || (e.g., by making appropriate markings in the margins). 5 (b) for testimony given in depositions that the Designating Party identify 6 || the Disclosure or Discovery Material on the record, before the close of the 7 || deposition all protected testimony. 8 (c) for information produced in some form other than documentary and for 9 || any other tangible items, that the Producing Party affix in a prominent place on 10 || the exterior of the container or containers in which the information is stored the 11 || legend “CONFIDENTIAL.” If only a portion or portions of the information 12 || warrants protection, the Producing Party, to the extent practicable, shall identify 13 || the protected portion(s). 14 5. Inadvertent Failures to Designate. If timely corrected, an inadvertent 15 || failure to designate qualified information or items does not, standing alone, waive 16 || the Designating Party’s right to secure protection under this Order for such 17 || material. Upon timely correction of a designation, the Receiving Party must 18 || make reasonable efforts to assure that the material is treated in accordance with 19 || the provisions of this Order. 20 21 | 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 22 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 23 || designation of confidentiality at any time that is consistent with the Court’s 24 6.2. Meet and Confer. The Challenging Party shall initiate the dispute 25 || resolution process under Local Rule 37.1 et seq. 26 6.3. The burden of persuasion in any such challenge proceeding shall be 27 || on the Designating Party. Frivolous challenges, and those made for an improper 28 || purpose (e.g., to harass or impose unnecessary expenses and burdens on other

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

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 Professional 7 || Vendors to whom disclosure is reasonably necessary for this Action and who 8 || have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 9 (g) the author or recipient of a document containing the information or a 10 || custodian or other person who otherwise possessed or knew the information; 11 (h) during their depositions, witnesses, and attorneys for witnesses, in the 12 || Action to whom disclosure is reasonably necessary provided: 13 (1) the deposing party requests that the witness sign the form attached as 14 || Exhibit 1 hereto; and (2) they will not be permitted to keep any confidential 15 || information unless they sign the “Acknowledgment and Agreement to Be Bound” 16 || (Exhibit A), unless otherwise agreed by the Designating Party or ordered by the 17 || court. Pages of transcribed deposition testimony or exhibits to depositions that 18 || reveal Protected Material may be separately bound by the court reporter and may 19 || not be disclosed to anyone except as permitted under this Stipulated Protective 20 || Order; and 21 (1) any mediator or settlement officer, and their supporting personnel, 22 || mutually agreed upon by any of the parties engaged in settlement discussions. 23 24 | 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 25 IN OTHER LITIGATION. 26 Ifa 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:

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 8 || pursued 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 18 || 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 19 PRODUCED IN THIS LITIGATION. 20 (a) The terms of this Order are applicable to information produced by a 21 || Non-Party in this Action and designated as “CONFIDENTIAL.” Such 22 || information produced by Non-Parties in connection with this litigation is 23 || protected by the remedies and relief provided by this Order. Nothing in these 24 || provisions should be construed as prohibiting a Non-Party from seeking 25 || additional protections. 26 (b) In the event that a Party is required, by a valid discovery request, to 27 || produce a Non-Party’s confidential information in its possession, and the Party 1s 28

1 || subject to an agreement with the Non-Party not to produce the Non-Party’s 2 || confidential information, then the Party shall: 3 (1) promptly notify in writing the Requesting Party and the Non- 4 Party that some or all of the information requested is subject to a 5 confidentiality agreement with a Non-Party; 6 (2) promptly provide the Non-Party with a copy of the Stipulated 7 Protective Order in this Action, the relevant discovery request(s), and a 8 reasonably specific description of the information requested; and 9 (3) make the information requested available for inspection by the 10 Non-Party, if requested. 11 (c) If the Non-Party fails to seek a protective order from this court within 12 || 14 days of receiving the notice and accompanying information, the Receiving 13 || Party may produce the Non-Party’s confidential information responsive to the 14 || discovery request. If the Non-Party timely seeks a protective order, the Receiving 15 || Party shall not produce any information in its possession or control that is subject 16 || to the confidentiality agreement with the Non-Party before a determination by the 17 || court. Absent a court order to the contrary, the Non-Party shall bear the burden 18 || and expense of seeking protection in this court of its Protected Material. 19 20 | 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL. 21 If a Receiving Party learns that, by inadvertence or otherwise, it has 22 || disclosed Protected Material to any person or in any circumstance not authorized 23 || under this Stipulated Protective Order, the Receiving Party must immediately (a) 24 || notify in writing the Designating Party of the unauthorized disclosures, (b) use its 25 || best efforts to retrieve all unauthorized copies of the Protected Material, (c) 26 || inform the person or persons to whom unauthorized disclosures were made of all 27 || the terms of this Order, and (d) request such person or persons to execute the 28

1 || “Acknowledgment and Agreement to Be Bound” that is attached hereto as 2 || Exhibit A. 3 4/11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 5 PROTECTED MATERIAL. 6 When a Producing Party gives notice to Receiving Parties that certain 7 || inadvertently produced material is subject to a claim of privilege or other 8 || protection, the obligations of the Receiving Parties are those set forth in Federal 9 || Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 10 || whatever procedure may be established in an e-discovery order that provides for 11 || production without prior privilege review. Pursuant to Federal Rule of Evidence 12 || 502(d) and (e), insofar as the parties reach an agreement on the effect of 13 || disclosure of a communication or information covered by the attorney-client 14 || privilege or work product protection, the parties may incorporate their agreement 15 || in the stipulated protective order submitted to the court. 16 17 ||} 12. MISCELLANEOUS. 18 12.1 Right to Further Relief. Nothing in this Order abridges the right of 19 || any person to seek its modification by the Court in the future. 20 12.2 Right to Assert Other Objections. By stipulating to the entry of this 21 || Protective Order no Party waives any right it otherwise would have to object to 22 || disclosing or producing any information or item on any ground not addressed in 23 || this Stipulated Protective Order. Similarly, no Party waives any right to object on 24 || any ground to use in evidence of any of the material covered by this Protective 25 || Order, 26 12.3 Filing Protected Material. A Party that seeks to file under seal any 27 || Protected Material must comply with Civil Local Rule 79-5. Protected Material 28 || may only be filed under seal pursuant to a court order authorizing the sealing of

1 || the specific Protected Material at issue. If a Party's request to file Protected 2 || Material under seal is denied by the court, then the Receiving Party may file the 3 || information in the public record unless otherwise instructed by the court. 4 5 |} 13. FINAL DISPOSITION. 6 After the final disposition of this Action, as defined in paragraph 4, within 7 || 60 days of a written request by the Designating Party, each Receiving Party must 8 || return all Protected Material to the Producing Party or destroy such material. As 9 || used in this subdivision, “all Protected Material” includes all copies, abstracts, 10 || compilations, summaries, and any other format reproducing or capturing any of 11 || the Protected Material. Whether the Protected Material is returned or destroyed, 12 || the Receiving Party must submit a written certification to the Producing Party 13 || (and, if not the same person or entity, to the Designating Party) by the 60 day 14 || deadline that (1) identifies (by category, where appropriate) all the Protected 15 || Material that was returned or destroyed and (2) affirms that the Receiving Party 16 || has not retained any copies, abstracts, compilations, summaries or any other 17 || format reproducing or capturing any of the Protected Material. Notwithstanding 18 || this provision, Counsel are entitled to retain an archival copy of all pleadings, 19 || motion papers, trial, deposition, and hearing transcripts, legal memoranda, 20 || correspondence, deposition and trial exhibits, expert reports, attorney work 21 || product, and consultant and expert work product, even if such materials contain 22 || Protected Material. Any such archival copies that contain or constitute Protected 23 || Material remain subject to this Protective Order as set forth in Section 4 24 | (DURATION). 25 || 14. Any violation of this Order may be punished by any and all appropriate 26 || measures including, without limitation, contempt proceedings and/or monetary 27 || sanctions. 28 | //

1 | ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD. 2 3 || Dated: March 11, 2025 Respectfully submitted, 4 KIRAKOSIAN LAW, 5 By___/s/ Gregory L. Kirakosian 6 Gregory L. Kirakosian 7 Attorney for Plaintiff g Jeffrey Paul 9 . 0 Dated: March 11, 2025 Respectfully submitted, 4 LAWRENCE BEACH ALLEN & CHOI, PC

12 3 By /s/_ Justin W. Clark! 14 Justin W. Clark 15 Shawyane Emadi Attorneys for Defendants 16 County of Los Angeles and 17 Deputy Larry Parks 18 19 99 | FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 21 22 □

ELIZ

34 DATED: March 12, 2025 Charles F. Eick 25 United States Magistrate Judge 26 27 ' Pursuant to L.R. 5-4.3.4, the filer of this stipulation attests that all other 9g || signatories listed, and on whose behalf this filing is submitted, concur in the filing’s content and have authorized the filing.

EXHIBIT A

2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 1, [print or type full name], of [print or type full address], 6 declare under penalty of perjury that I 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 [DATE] in the case of Jeffrey Paul v. Los ° Angeles County, et al., 2:25-cv-00008-WLH-E. 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 could expose me to sanctions and 3 punishment in the nature of contempt. I solemnly promise that I will not disclose 14 in any manner any information or item that is subject to this Stipulated Protective 15 || Order to any person or entity except in strict compliance with the provisions of 16 || this Order. 17 I further agree to submit to the jurisdiction of the United States District 18 || Court for the Central District of California for enforcing the terms of this 19 || Stipulated Protective Order, even if such enforcement proceedings occur after 20 || termination of this action. I hereby appoint [print or type 21 || full name] of [print or type full 22 || address and telephone number] as my California agent for service of process in 23 | connection with this action or any proceedings related to enforcement of this 24 Stipulated Protective Order. 29 Date: 26 City and State where sworn and signed: a Printed name: 8 Signature: