1 Denisse O. Gastélum, SBN 282771 Christian Contreras, SBN 330269 2 Selene Estrada-Villela, SBN 354994 LAW OFFICES OF CHRISTIAN CONTRERAS

GASTÉLUM LAW, APC PROFESSIONAL LAW CORPORATION

3 A PROFESSIONAL CORPORATION 360 E. 2nd St., 8th Floor 3767 Worsham Ave. Los Angeles, California 90012 4 Long Beach, California 90808 Tel: (323) 435-8000 Tel: (213) 340-6112 Fax: (323) 597-0101 5 Fax: (213) 402-8622 Email: CC@Contreras-Law.com Email: dgastelum@gastelumfirm.com 6

7 Attorneys for Plaintiffs, ESTATE OF TAVEA STARKS-WALKER, by and through successors in interest, JB 8 Starks, Jr. and Eula Walker; JB STARKS, JR., individually; EULA WALKER, individually 9

10 UNITED STATES DISTRICT COURT

11 THE CENTRAL DISTRICT OF CALIFORNIA

12

13 ESTATE OF TAVEA STARKS- ) CASE NO. 5:24−cv−01879−JGB−SHK ) [Assigned to the Hon. Jesus G. Bernal, 14 WALKER, by and through successors ) District Judge; Referred to the Hon. Shashi in interest, JB Starks, Jr. and Eula ) H. Kewalramani, Magistrate Judge] 15 Walker; JB STARKS, JR., ) ) 16 individually; EULA WALKER, ) individually, ) [PROPOSED] STIPULATED 17 ) PROTECTIVE ORDER Plaintiffs, ) 18 v. ) ) 19 COUNTY OF RIVERSIDE, a public ) ) 20 entity; RIVERSIDE COUNTY )

SHERIFF’S DEPARTMENT; )

21 SHERIFF CHAD BIANCO, in his ) ) 22 individual and official capacities; )

EDWARD DELGADO; JAMES )

23 KRACHMER; ALYSSA VERNAL; ) ) 24 DOES 1 through 10, individually, ) jointly and severally, ) 25 ) ) Defendants. 26 ) ) 27 )

28 1 2 1. A. PURPOSES AND LIMITATIONS 3 Discovery in this action is likely to involve production of confidential, 4 proprietary, or private information for which special protection from public 5 disclosure and from use for any purpose other than prosecuting this litigation may be 6 warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter 7 the following Stipulated Protective Order. The parties acknowledge that this Order 8 does not confer blanket protections on all disclosures or responses to discovery and 9 that the protection it affords from public disclosure and use extends only to the limited information or items that are entitled to confidential treatment under the applicable 10 legal principles. The parties further acknowledge, as set forth in Section 12.3, below, 11 that this Stipulated Protective Order does not entitle them to a file confidential 12 information under seal; Civil Local Rule 79-5 sets forth the procedures that must be 13 followed and the standards that will be applied when a party seeks permission from 14 the court to file material under seal. 15

B. GOOD CAUSE STATEMENT

16 Plaintiffs and the individual Defendants may produce certain documents in this 17 case that contain personal medical, employment or financial information. Such 18 information may implicate the privacy interests of the party and are properly 19 protected through a Fed. R. Civ. P. 26(c) protective order. Seattle Times Co. v. 20 Rhinehart, 467 U.S. 20, 35 n.21 (1984) (“Rule 26(c) includes among its express 21 purposes the protection of a ‘party or person from annoyance, embarrassment, 22 oppression or undue burden or expense.’ Although the Rule contains no specific 23 reference to privacy or to other rights or interests that may be implicated, such matters 24 are implicit in the broad purpose and language of the Rule.”); Soto v. City of Concord, 25 162 F.R.D. 603, 617 (N.D. Cal. 1995) (a party’s privacy rights are to be protected 26 through a “carefully crafted protective order.”). 27 2. DEFINITIONS 28 2.1 Action: This pending federal law suit, Estate of Tavea Starks-Walker v. 1 County of Riverside, et al. Case Number 5:24−cv−01879−JGB−SHK. 2 2.2 Challenging Party: a Party or Non-Party that challenges the designation 3 of information or items under this Order. 4 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 5 how it is generated, stored, or maintained) or tangible things that qualify for 6 protection under Federal Rule of Civil Procedure 26(c), and as specified above in the 7 Good Cause Statement. 8 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 9 their support staff). 10 2.5 Designating Party: a Party or Non-Party that designates information or 11 items that it produces in disclosures or in responses to discovery as 12 “CONFIDENTIAL.” 13 2.6 Disclosure or Discovery Material: all items or information, regardless 14 of the medium or manner in which it is generated, stored, or maintained (including, 15 among other things, testimony, transcripts, and tangible things), that are produced or 16 generated in disclosures or responses to discovery in this matter. 17 2.7 Expert: a person with specialized knowledge or experience in a matter 18 pertinent to the litigation who has been retained by a Party or its counsel to serve as 19 an expert witness or as a consultant in this Action. 20 2.8 House Counsel: attorneys who are employees of a party to this Action. 21 House Counsel does not include Outside Counsel of Record or any other outside 22 counsel. 23 2.9 Non-Party: any natural person, partnership, corporation, association, or 24 other legal entity not named as a Party to this action. 25 2.10 Outside Counsel of Record: attorneys who are not employees of a party 26 to this Action but are retained to represent or advise a party to this Action and have 27 appeared in this Action on behalf of that party or are affiliated with a law firm which 28 has appeared on behalf of that party, including support staff. 1 2.11 Party: any party to this Action, including all of its officers, directors, 2 employees, consultants, retained experts, and Outside Counsel of Record (and their 3 support staffs). 4 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 5 Discovery Material in this Action. 6 2.13 Professional Vendors: persons or entities that provide litigation support 7 services (e.g., photocopying, videotaping, translating, preparing exhibits or 8 demonstrations, and organizing, storing, or retrieving data in any form or medium) 9 and their employees and subcontractors. 10 2.14 Protected Material: any Disclosure or Discovery Material that is 11 designated as “CONFIDENTIAL.” 12 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 13 from a Producing Party. 14 3. SCOPE 15 The protections conferred by this Stipulation and Order cover not only 16 Protected Material (as defined above), but also (1) any information copied or extracted from Protected Material; (2) all copies, excerpts, summaries, or 17 compilations of Protected Material; and (3) any testimony, conversations, or 18 presentations by Parties or their Counsel that might reveal Protected Material. 19 Any use of Protected Material at trial shall be governed by the orders of the 20 trial judge. This Order does not govern the use of Protected Material at trial. 21 4. DURATION 22 Once a case proceeds to trial, all of the information that was designated as 23 confidential or maintained pursuant to this protective order becomes public and will 24 be presumptively available to all members of the public, including the press, unless 25 compelling reasons supported by specific factual findings to proceed otherwise are 26 made to the trial judge in advance of the trial. See Kamakana v. City and County of 27 Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing “good cause” 28 1 standard when merits-related documents are part of court record). Accordingly, the 2 terms of this protective order do not extend beyond the commencement of the trial. 3 5. DESIGNATING PROTECTED MATERIAL 4 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each Party or Non-Party that designates information or items for protection under 5 this Order must take care to limit any such designation to specific material that 6 qualifies under the appropriate standards. The Designating Party must designate for 7 protection only those parts of material, documents, items, or oral or written 8 communications that qualify so that other portions of the material, documents, items, 9 or communications for which protection is not warranted are not swept unjustifiably 10 within the ambit of this Order. 11 Mass, indiscriminate, or routinized designations are prohibited. Designations 12 that are shown to be clearly unjustified or that have been made for an improper 13 purpose (e.g., to unnecessarily encumber the case development process or to impose 14 unnecessary expenses and burdens on other parties) may expose the Designating 15 Party to sanctions. 16 If it comes to a Designating Party’s attention that information or items that it 17 designated for protection do not qualify for protection, that Designating Party must 18 promptly notify all other Parties that it is withdrawing the inapplicable designation. 19 5.2 Manner and Timing of Designations. Except as otherwise provided in 20 this Order (see, e.g., second paragraph of Section 5.2(a) below), or as otherwise 21 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 22 under this Order must be clearly so designated before the material is disclosed or 23 produced. 24 Designation in conformity with this Order requires: 25 (a) for information in documentary form (e.g., paper or electronic 26 documents, but excluding transcripts of depositions or other pretrial or trial 27 proceedings), that the Producing Party affix at a minimum, the legend 28 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 1 contains protected material. If only a portion or portions of the material on a page 2 qualifies for protection, the Producing Party also must clearly identify the protected portion(s) (e.g., by making appropriate markings in the margins). 3 A Party or Non-Party that makes original documents available for 4 inspection need not designate them for protection until after the inspecting Party has 5 indicated which documents it would like copied and produced. During the inspection 6 and before the designation, all of the material made available for inspection shall be 7 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents 8 it wants copied and produced, the Producing Party must determine which documents, 9 or portions thereof, qualify for protection under this Order. Then, before producing 10 the specified documents, the Producing Party must affix the “CONFIDENTIAL 11 legend” to each page that contains Protected Material. If only a portion or portions of 12 the material on a page qualifies for protection, the Producing Party also must clearly 13 identify the protected portion(s) (e.g., by making appropriate markings in the 14 margins). Markings added to documents pursuant to this paragraph shall not obscure 15 the content or text of the documents produced. 16 (b) for testimony given in depositions that the Designating Party identify 17 the Disclosure or Discovery Material on the record, before the close of the deposition 18 all protected testimony. The court reporter must affix to each such transcript page 19 containing Protected Material the “CONFIDENTIAL legend”, as instructed by the 20 Designating Party. 21 (c) for information produced in some form other than documentary and for any other tangible items, that the Producing Party affix in a prominent place on 22 the exterior of the container or containers in which the information is stored the 23 legend “CONFIDENTIAL.” If only a portion or portions of the information warrants 24 protection, the Producing Party, to the extent practicable, shall identify the protected 25 portion(s). 26 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 27 failure to designate qualified information or items does not, standing alone, waive the 28 1 Designating Party’s right to secure protection under this Order for such material. 2 Upon timely correction of a designation, the Receiving Party must make reasonable 3 efforts to assure that the material is treated in accordance with the provisions of this 4 Order. 5 5.4 6 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 7 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 8 designation of confidentiality at any time that is consistent with the Court’s 9 Scheduling Order. 10 6.2 Meet and Confer. The Challenging Party Shall initiate the dispute 11 resolution process under Civil Local Rule 37-1 et seq. 12 6.3 Burden of Persuasion 13 The burden of persuasion in any such challenge proceeding shall be on the 14 Designating Party. Frivolous challenges, and those made for an improper purpose 15 (e.g., to harass or impose unnecessary expenses and burdens on other parties), may 16 expose the Challenging Party to sanctions. Unless the Designating Party has waived 17 or withdrawn the confidentiality designation, all parties shall continue to afford the 18 material in question the level of protection to which it is entitled under the 19 Producing Party’s designation until the Court rules on the challenge. 20 7. ACCESS TO AND USE OF PROTECTED MATERIAL 21 7.1 Basic Principles. A Receiving Party may use Protected Material that is 22 disclosed or produced by another Party or by a Non-Party in connection with this 23 Action only for prosecuting, defending, or attempting to settle this Action. Such 24 Protected Material may be disclosed only to the categories of persons and under the 25 conditions described in this Order. When the Action has been terminated, a 26 Receiving Party must comply with the provisions of Section 13 below (FINAL 27 DISPOSITION). 28 1 Protected Material must be stored and maintained by a Receiving Party at a 2 location and in a secure manner that ensures that access is limited to the persons authorized under this Order. 3 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 4 otherwise ordered by the Court or permitted in writing by the Designating Party, a 5 Receiving Party may disclose any information or item designated 6 “CONFIDENTIAL” only to: 7 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 8 well as employees of said Outside Counsel of Record to whom it is reasonably 9 necessary to disclose the information for this Action; 10 (b) the officers, directors, and employees (including House Counsel) of 11 the Receiving Party to whom disclosure is reasonably necessary for this Action; 12 (c) Experts (as defined in this Order) of the Receiving Party to whom 13 disclosure is reasonably necessary for this Action and who have signed the 14 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 15 (d) the Court and its personnel; 16 (e) court reporters and their staff; 17 (f) professional jury or trial consultants, mock jurors, and Professional 18 Vendors to whom disclosure is reasonably necessary for this Action and who have 19 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 20 (g) the author or recipient of a document containing the information or a 21 custodian or other person who otherwise possessed or knew the information; 22 (h) during their depositions, witnesses, and attorneys for witnesses, in the 23 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 24 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will 25 not be permitted to keep any confidential information unless they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 26 agreed by the Designating Party or ordered by the Court. Pages of transcribed 27 deposition testimony or exhibits to depositions that reveal Protected Material may be 28 1 separately bound by the court reporter and may not be disclosed to anyone except as 2 permitted under this Stipulated Protective Order; and (i) any mediator or settlement officer, and their supporting personnel, 3 mutually agreed upon by any of the parties engaged in settlement discussions. 4 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 5

PRODUCED IN OTHER LITIGATION

6 If a Party is served with a subpoena or a court order issued in other litigation 7 that compels disclosure of any information or items designated in this Action as 8 “CONFIDENTIAL,” that Party must: 9 (a) promptly notify in writing the Designating Party. Such notification 10 shall include a copy of the subpoena or court order; 11 (b) promptly notify in writing the party who caused the subpoena or order 12 to issue in the other litigation that some or all of the material covered by the subpoena 13 or order is subject to this Protective Order. Such notification shall include a copy of 14 this Stipulated Protective Order; and 15 (c) cooperate with respect to all reasonable procedures sought to be 16 pursued by the Designating Party whose Protected Material may be affected. 17 If the Designating Party timely seeks a protective order, the Party served with 18 the subpoena or court order shall not produce any information designated in this 19 action as “CONFIDENTIAL” before a determination by the court from which the 20 subpoena or order issued, unless the Party has obtained the Designating Party’s 21 permission. The Designating Party shall bear the burden and expense of seeking 22 protection in that court of its confidential material, and nothing in these provisions 23 should be construed as authorizing or encouraging a Receiving Party in this Action to disobey a lawful directive from another court. 24 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 25

PRODUCED IN THIS LITIGATION

26 (a) The terms of this Order are applicable to information produced by a 27 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 28 1 produced by Non-Parties in connection with this litigation is protected by the 2 remedies and relief provided by this Order. Nothing in these provisions should be construed as prohibiting a Non-Party from seeking additional protections. 3 (b) In the event that a Party is required, by a valid discovery request, to 4 produce a Non-Party’s confidential information in its possession, and the Party is 5 subject to an agreement with the Non-Party not to produce the Non-Party’s 6 confidential information, then the Party shall: 7 (1) promptly notify in writing the Requesting Party and the Non-Party 8 that some or all of the information requested is subject to a confidentiality agreement 9 with a Non-Party; 10 (2) promptly provide the Non-Party with a copy of the Stipulated 11 Protective Order in this Action, the relevant discovery request(s), and a reasonably 12 specific description of the information requested; and 13 (3) make the information requested available for inspection by the Non- 14 Party, if requested. 15 (c) If the Non-Party fails to seek a protective order from this Court within 16 14 days of receiving the notice and accompanying information, the Receiving Party 17 may produce the Non-Party’s confidential information responsive to the discovery 18 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 19 not produce any information in its possession or control that is subject to the 20 confidentiality agreement with the Non-Party before a determination by the Court. 21 Absent a court order to the contrary, the Non-Party shall bear the burden and expense of seeking protection in this Court of its Protected Material. 22 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 23 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 24 Protected Material to any person or in any circumstance not authorized under this 25 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 26 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 27 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 28 1 and (d) request such person or persons to execute the “Acknowledgment and 2 Agreement to Be Bound” that is attached hereto as Exhibit A. 3 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 4 PROTECTED MATERIAL When a Producing Party gives notice to Receiving Parties that certain 5 inadvertently produced material is subject to a claim of privilege or other protection, 6 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 7 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 8 may be established in an e-discovery order that provides for production without prior 9 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 10 parties reach an agreement on the effect of disclosure of a communication or 11 information covered by the attorney-client privilege or work product protection, the 12 parties may incorporate their agreement in the stipulated protective order submitted 13 to the Court. 14 12. MISCELLANEOUS 15 12.1 Right to Relief. Nothing in this Order abridges the right of any person 16 to seek its modification by the Court in the future. 17 12.2 Right to Assert Other Objections. By stipulating to the entry of this 18 Protective Order, no Party waives any right it otherwise would have to object to 19 disclosing or producing any information or item on any ground not addressed in this 20 Stipulated Protective Order. Similarly, no Party waives any right to object on any 21 ground to use in evidence of any of the material covered by this Protective Order. 22 12.3 Filing Protected Material. A Party that seeks to file under seal any 23 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 24 only be filed under seal pursuant to a court order authorizing the sealing of the specific 25 Protected Material at issue. If a Party’s request to file Protected Material under seal 26 is denied by the court, then the Receiving Party may file the information in the public 27 record unless otherwise instructed by the court. 28 1 13. FINAL DISPOSITION 2 After the final disposition of this Action, as defined in paragraph 4, within 60 3 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 4 this 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 same 8 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 9 (by category, where appropriate) all the Protected Material that was returned or 10 destroyed; and (2) affirms that the Receiving Party has not retained any copies, 11 abstracts, compilations, summaries, or any other format reproducing or capturing any 12 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 13 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 14 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 15 reports, attorney work product, and consultant and expert work product, even if such 16 materials contain Protected Material. Any such archival copies that contain or 17 constitute Protected Material remain subject to this Protective Order as set forth in 18 Section 4 (DURATION). 19 14. Any violation of this Order may be punished by any and all appropriate 20 measures including, without limitation, contempt proceedings and/or monetary 21 sanctions. 22 23 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 24 /// 25 /// /// 26 /// 27 /// 28 1 |} Dated: March 24, 2025 By: /s/ Denisse O. Gastélum 5 Denisse O. Gastélum, Esq. Selene Estrada-Villela, Esq. 3 Attorneys for Plaintiffs, 4 ESTATE OF TAVEA STARKS-WALKER, by and through successors in interest, JB Starks, Jr. and Eula 5 Walker; JB STARKS, JR., individually; EULA 6 WALKER, individually,

Dated: March 24, 2025 LAW OFFICES OF CHRISTIAN CONTRERAS 8 A Professional Law Corporation 9 By: /c/ Christian Contreras 10 Christian Contreras, Esq. 11 Attorneys for Plaintiffs, ESTATE OF TAVEA STARKS-WALKER, by and 12 through successors in interest, JB Starks, Jr. and Eula 13 Walker; JB STARKS, JR., individually; EULA 4 WALKER, individually, 15 Dated: March 24, 2025 BURKE, WILLIAMS & SORENSEN, LLP 16 17 18 By: /s/Caylin W. Jones Nathan A. Oyster 19 Caylin W. Jones Attorneys for Defendants 20 COUNTY OF RIVERSIDE, SHERIFF CHAD 2] BIANCO, EDWARD DELGADO; JAMES KRACHMER; and ALYSSA VERNAL

| OR GOOD CAUSE SHOWN, IT IS SO ORDERED. 24 25 |! DATED: March 25, 2025 26 27 - Mpeg 2g || Honorable Shashi H. Kewalramani United States Magistrate Judge 13

1 2 EXHIBIT A

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3

4 I, _____________________________ [print or type full name], of 5 _________________ [print or type full address], declare under penalty of perjury that 6 I have read in its entirety and understand the Stipulated Protective Order that was 7 issued by the United States District Court for the Central District of California on 8 [date] in the case of Estate of Tavea Starks−Walker, et al. v. County of Riverside, et 9 al.; Case No. 5:24−cv−01879−JGB−SHK. I agree to comply with and to be bound 10 by all the terms of this Stipulated Protective Order, and I understand and acknowledge 11 that failure to so comply could expose me to sanctions and punishment in the nature 12 of contempt. I solemnly promise that I will not disclose in any manner any 13 information or item that is subject to this Stipulated Protective Order to any person 14 or entity except in strict compliance with the provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District Court 16 for the Central District of California for the purpose of enforcing the terms of this 17 Stipulated Protective Order, even if such enforcement proceedings occur after 18 termination of this action. I hereby appoint __________________________ [print or 19 type full name] of _______________________________________ [print or type full 20 address and telephone number] as my California agent for service of process in 21 connection with this action or any proceedings related to enforcement of this Stipulated Protective Order. 22 Date: ______________________________________ 23 City and State where sworn and signed: _________________________________ 24

25 Printed name: _______________________________ 26

27 Signature: __________________________________ 28