1 LEWIS BRISBOIS BISGAARD & SMITH LLP

TONY M. SAIN, SB# 251626

2 E-Mail: Tony.Sain@lewisbrisbois.com

TORI L. N. BAKKEN, SB# 329069

3 E-Mail: Tori.Bakken@lewisbrisbois.com ABIGAIL J. R. McLAUGHLIN, SB# 313208 4 E-Mail: Abigail.McLaughlin@lewisbrisbois.com 633 West 5th Street, Suite 4000 5 Los Angeles, California 90071 Telephone: 213.250.1800 6 Facsimile: 213.250.7900 7 Attorneys for Defendants,

COUNTY OF LOS ANGELES,

8 MICHAEL ALBUREZ, BRANDON VANARSDALE, and TERRIE COATS 9 10 UNITED STATES DISTRICT COURT 11 CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION 12 13 COREY CRITTENDEN, Case No. 2:25-CV-02852-MWC (MAAx) 14 Plaintiff, [Hon. Michelle Williams Court, Dist. Judge; Hon. Maria A. Audero, M. 15 vs. Judge] 16 COUNTY OF LOS ANGELES, a public entity; MICHAEL ALBUREZ, [DISCOVERY MATTER] 17 an individual; BRANDON VANARSDALE, an individual; 18 TERRIE COATS, an individual; and STIPULATED PROTECTIVE DOES 1 through 20, individuals, ORDER 19 inclusive, 20 Defendants. [Proposed Order filed concurrently herewith] 21 22 Complaint Filed: 04/02/2025 Trial: 07/20/2026 23 24 1. PURPOSES AND LIMITATIONS 25 Discovery in this action is likely to involve production of confidential, 26 proprietary, or private information for which special protection from public disclosure 27 and from use for any purpose other than prosecuting this litigation may be warranted. 1 following Stipulated Protective Order. The parties acknowledge that this Stipulated 2 Protective Order does not confer blanket protections on all disclosures or responses 3 to discovery and that the protection it affords from public disclosure and use extends 4 only to the limited information or items that are entitled to confidential treatment 5 under the applicable legal principles. The parties further acknowledge, as set forth in 6 Section 13.3 below, that this Stipulated Protective Order does not entitle them to 7 confidential information under seal; Local Rule 79-5 sets forth the procedures that 8 must be followed and the standards that will be applied when a party seeks permission 9 from the Court to file material under seal. 10 11 2. GOOD CAUSE STATEMENT 12 2.1. Contentions re Harm from Disclosure of Confidential Materials. 13 Defendants contend that there is good cause and a particularized need for a 14 protective order to preserve the interests of confidentiality and privacy in peace officer 15 personnel file records and associated investigative or confidential records for the 16 following reasons. 17 First, Defendants contend that peace officers have a federal privilege of privacy 18 in their personnel file records: a reasonable expectation of privacy therein that is 19 underscored, specified, and arguably heightened by the Pitchess protective procedure 20 of California law. See Sanchez v. Santa Ana Police Dept., 936 F.2d 1027, 1033-1034 21 (9th Cir. 1990); Hallon v. City of Stockton, 2012 U.S. Dist. LEXIS 14665, *2-3, 12- 22 13 (E.D. Cal. 2012) (concluding that “while “[f]ederal law applies to privilege based 23 discovery disputes involving federal claims,” the “state privilege law which is 24 consistent with its federal equivalent significantly assists in applying [federal] 25 privilege law to discovery disputes”); Soto v. City of Concord, 162 F.R.D. 603, 613 26 n. 4, 616 (N.D. Cal. 1995) (peace officers have constitutionally-based “privacy rights 27 [that] are not inconsequential” in their police personnel records); cf. Cal. Penal Code 1 uncontrolled disclosure of such personnel file information can threaten the safety of 2 non-party witnesses, officers, and their families/associates. 3 Second, Defendants contend that municipalities and law enforcement agencies 4 have federal deliberative-executive process privilege, federal official information 5 privilege, federal law enforcement privilege, and federal attorney-client privilege 6 (and/or attorney work product protection) interests in the personnel files of their peace 7 officers – particularly as to those portions of peace officer personnel files that contain 8 critical self-analysis, internal deliberation/decision-making or evaluation/analysis, or 9 communications for the purposes of obtaining or rendering legal advice or analysis – 10 potentially including but not limited to evaluative/analytical portions of Internal 11 Affairs type records or reports, evaluative/analytical portions of supervisory records 12 or reports, and/or reports prepared at the direction of counsel, or for the purpose of 13 obtaining or rendering legal advice. See Sanchez, 936 F.2d at 1033-1034; Maricopa 14 Audubon Soc’y v. United States Forest Serv., 108 F.3d 1089, 1092-1095 (9th Cir. 15 1997); Soto, 162 F.R.D. at 613, 613 n. 4; Kelly v. City of San Jose, 114 F.R.D. 654, 16 668-671 (N.D. Cal. 1987); Tuite v. Henry, 181 F.R.D. 175, 176-177 (D. D.C. 1998); 17 Hamstreet v. Duncan, 2007 U.S. Dist. LEXIS 89702 (D. Or. 2007); Admiral Ins. Co. 18 v. United States Dist. Ct., 881 F.2d 1486, 1492, 1495 (9th Cir. 1988). Defendants 19 further contend that such personnel file records are restricted from disclosure by the 20 public entity’s custodian of records pursuant to applicable California law and that 21 uncontrolled release is likely to result in needless intrusion of officer privacy; 22 impairment in the collection of third-party witness information and statements 23 and related legitimate law enforcement investigations/interests; and a chilling of 24 open and honest discussion regarding and/or investigation into alleged 25 misconduct that can erode a public entity’s ability to identify and/or implement 26 any remedial measures that may be required. 27 Third, Defendants contend that, since peace officers do not have the same rights 1 fundamental principles of fairness to permit uncontrolled release of officers’ 2 compelled statements. See generally Lybarger v. City of Los Angeles, 40 Cal.3d 822, 3 828-830 (1985); cf. U.S. Const., amend V. 4 Accordingly, Defendants contend that, without a protective order preventing 5 such, production of confidential records in the case can and will likely substantially 6 impair and harm defendant public entity’s interests in candid self-critical analysis, 7 frank internal deliberations, obtaining candid information from witnesses, preserving 8 the safety of witnesses, preserving the safety of peace officers and peace officers’ 9 families and associates, protecting the privacy officers of peace officers, and 10 preventing pending investigations from being detrimentally undermined by 11 publication of private, sensitive, or confidential information – as can and often does 12 result in litigation. 13 2.2. Plaintiff does not agree with and does not stipulate to Defendants’ 14 contentions herein above, and nothing in this Stipulation or its associated Order shall 15 resolve the parties’ disagreement, or bind them, concerning the legal statements and 16 claimed privileges set forth above. 17 However, plaintiff agrees that there is Good Cause for a Protective Order so as 18 to preserve the respective interests of the parties without the need to further burden 19 the Court with such issues. Specifically, the parties jointly contend that, absent this 20 Stipulation and its associated Protective Order, the parties' respective privilege 21 interests may be impaired or harmed, and that this Stipulation and its associated 22 Protective Order may avoid such harm by permitting the parties to facilitate discovery 23 with reduced risk that privileged and/or sensitive/confidential information will 24 become matters of public record. 25 2.3. The parties jointly contend that there is typically a particularized need 26 for protection as to any medical or psychotherapeutic records and autopsy 27 photographs, because of the privacy interests at stake therein. Because of these 1 agreement between the parties. 2 2.4. The parties therefore stipulate that there is Good Cause for, and hereby 3 jointly request that the honorable Court issue/enter, a Protective Order re confidential 4 documents consistent with the terms and provisions of this Stipulation. However, the 5 entry of a Protective Order by the Court pursuant to this Stipulation shall not be 6 construed as any ruling by the Court on the aforementioned legal statements or 7 privilege claims in this section (§ 1), nor shall this section be construed as part of any 8 such Court Order. 9 10 3. DEFINITIONS. 11 3.1. Action: This pending federal lawsuit. 12 3.2. Challenging Party: A Party or Nonparty that challenges the designation 13 of information or items under this Stipulated Protective Order. 14 3.3. “CONFIDENTIAL” Information or Items: Information (regardless of 15 how it is generated, stored, or maintained) or tangible things that qualify for 16 protection under standards developed under Federal Rule of Civil Procedure 17 26(c), and as specified above in the Good Cause Statement. 18 3.4. Counsel: Outside Counsel of Record and In-House Counsel (as well as 19 their support staff). 20 3.5. Designating Party: A Party or Nonparty that designates information or 21 items that it produces in disclosures or in responses to discovery as 22 “CONFIDENTIAL.” 23 3.6. Disclosure or Discovery Material: All items or information, regardless 24 of the medium or manner in which it is generated, stored, or maintained 25 (including, among other things, testimony, transcripts, and tangible things), that 26 is produced or generated in disclosures or responses to discovery in this matter. 27 3.7. Expert: A person with specialized knowledge or experience in a matter 1 serve as an expert witness or as a consultant in this Action. 2 3.8. In-House Counsel: Attorneys who are employees of a party to this Action. 3 In-House Counsel does not include Outside Counsel of Record or any other 4 outside counsel. 5 3.9. Nonparty: Any natural person, partnership, corporation, association, or 6 other legal entity not named as a Party to this action. 7 3.10. Outside Counsel of Record: Attorneys who are not employees of a party 8 to this Action but are retained to represent or advise a party to this Action and 9 have appeared in this Action on behalf of that party or are affiliated with a law 10 firm which has appeared on behalf of that party, and includes support staff. 11 3.11. Party: Any party to this Action, including all of its officers, directors, 12 employees, consultants, retained experts, In-House Counsel, and Outside 13 Counsel of Record (and their support staffs). 14 3.12. Producing Party: A Party or Nonparty that produces Disclosure or 15 Discovery Material in this Action. 16 3.13. Professional Vendors: Persons or entities that provide litigation support 17 services (e.g., photocopying, videotaping, translating, preparing exhibits or 18 demonstrations, and organizing, storing, retrieving data in any form or 19 medium) and their employees and subcontractors. 20 3.14. Protected Material: Any Disclosure or Discovery Material that is 21 designated as “CONFIDENTIAL.” 22 3.15. Receiving Party: A Party that receives Disclosure or Discovery Material 23 from a Producing Party. 24 4. SCOPE 25 The protections conferred by this Stipulated Protective Order cover not only 26 Protected Material, but also (1) any information copied or extracted from Protected 27 Material; (2) all copies, excerpts, summaries, or compilations of Protected Material; 1 might reveal Protected Material. 2 Any use of Protected Material at trial shall be governed by the orders of the 3 trial judge. This Stipulated Protective Order does not govern the use of Protected 4 Material at trial. 5 6 5. DURATION OF PROTECTION. 7 Even after final disposition of this litigation, the confidentiality obligations 8 imposed by this Stipulated Protective Order shall remain in effect until a Designating 9 Party agrees otherwise in writing or a court order otherwise directs. Final disposition 10 shall be deemed to be the later of (1) dismissal of all claims and defenses in this action, 11 with or without prejudice; and (2) final judgment herein after the completion and 12 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 13 including the time limits for filing any motions or applications for extension of time 14 pursuant to applicable law. 15 16 6. DESIGNATING PROTECTED MATERIAL 17 6.1. Exercise of Restraint and Care in Designating Material for Protection. 18 Each Party or Nonparty that designates information or items for 19 protection under this Stipulated Protective Order must take care to limit 20 any such designation to specific material that qualifies under the 21 appropriate standards. The Designating Party must take care to designate 22 for protection only those parts of material, documents, items, or oral or 23 written communications that qualify so that other portions of the 24 material, documents, items or communications for which protection is 25 not warranted are not swept unjustifiably within the ambit of this 26 Stipulated Protective Order. 27 Mass, indiscriminate, or routinized designations are prohibited. 1 made for an improper purpose (e.g., to unnecessarily encumber the case 2 development process or to impose unnecessary expenses and burdens on 3 other parties) may expose the Designating Party to sanctions. 4 6.2. Manner and Timing of Designations. 5 Except as otherwise provided in this Stipulated Protective Order 6 (see, e.g., Section 6.2(a)), or as otherwise stipulated or ordered, 7 Disclosure or Discovery Material that qualifies for protection under this 8 Stipulated Protective Order must be clearly so designated before the 9 material is disclosed or produced. 10 Designation in conformity with this Stipulated Protective Order 11 requires the following: 12 (a) For information in documentary form (e.g., paper or electronic 13 documents, but excluding transcripts of depositions or other 14 pretrial or trial proceedings), that the Producing Party affix at a 15 minimum, the legend “CONFIDENTIAL” to each page that 16 contains Protected Material. If only a portion or portions of the 17 material on a page qualifies for protection, the Producing Party 18 also must clearly identify the protected portion(s) (e.g., by making 19 appropriate markings in the margins). 20 A Party or Nonparty that makes original documents or 21 materials available for inspection need not designate them for 22 protection until after the inspecting Party has indicated which 23 material it would like copied and produced. During the inspection 24 and before the designation, all of the material made available for 25 inspection shall be deemed “CONFIDENTIAL.” After the 26 inspecting Party has identified the documents it wants copied and 27 produced, the Producing Party must determine which documents, 1 Protective Order. Then, before producing the specified 2 documents, the Producing Party must affix the legend 3 “CONFIDENTIAL” to each page that contains Protected 4 Material. If only a portion or portions of the material on a page 5 qualifies for protection, the Producing Party also must clearly 6 identify the protected portion(s) (e.g., by making appropriate 7 markings in the margins). 8 (b) For testimony given in depositions, or in other pretrial or trial 9 proceedings, that the Designating Party identify the Disclosure or 10 Discovery Material on the record, before the close of the 11 deposition, hearing, or other proceeding, all protected testimony, 12 and further specify any portions of the testimony that qualify as 13 “CONFIDENTIAL.” When it is impractical to identify separately 14 each portion of testimony that is entitled to protection, and when 15 it appears that substantial portions of the testimony may qualify 16 for protection, the Producing Party may invoke on the record 17 (before the deposition or proceeding is concluded) a right to have 18 up to twenty (20) days to identify the specific portions of the 19 testimony as “CONFIDENTIAL.” Only those portions of the 20 testimony that are appropriately designated as 21 “CONFIDENTIAL” for protection within the 20 days shall be 22 covered by the provisions of this Stipulated Protective Order. 23 The court reporter must affix to each such transcript page 24 containing Protected Material the legend “CONFIDENTIAL,” as 25 instructed by the Producing Party. 26 (c) For information produced in some form other than documentary, 27 and for any other tangible items, that the Producing Party affix in 1 which the information is stored the legend “CONFIDENTIAL.” 2 If only a portion or portions of the information warrants 3 protection, the Producing Party, to the extent practicable, shall 4 identify the protected portion(s). 5 6.3. Inadvertent Failures to Designate. 6 If timely corrected (preferably, though not necessarily, within 30 7 days of production or disclosure of such material), an inadvertent failure 8 to designate qualified information or items does not, standing alone, 9 waive the Designating Party’s right to secure protection under this 10 Stipulated Protective Order for such material. Upon timely correction of 11 a designation, the Receiving Party must make reasonable efforts to 12 assure that the material is treated in accordance with the provisions of 13 this Stipulated Protective Order. 14 15 7. CHALLENGING CONFIDENTIALITY DESIGNATIONS. 16 7.1. Timing of Challenges. 17 Any Party or Non-Party may challenge a designation of 18 confidentiality at any time that is consistent with the Court's Scheduling 19 Order. 20 7.2. Meet and Confer. 21 The Challenging Party shall initiate the dispute resolution process, 22 which shall comply with Local Rule 37.1 et seq., and with Section 4 of 23 Judge Audero’s Procedures (“Mandatory Telephonic Conference for 24 Discovery Disputed”).1 25 . 26 27 1 Judge Audero’s Procedures are available at https://www.cacd.uscourts.gov/honorable-maria-audero. 1 7.3. Burden of Persuasion. 2 The burden of persuasion n any such challenge proceeding shall 3 be on the Designating Party. Frivolous challenges, and those made for 4 an improper purpose (e.g., to harass or impose unnecessary expenses and 5 burdens on other parties) may expose the Challenging Party to sanctions. 6 Unless the Designating Party has waived or withdrawn the 7 confidentiality designation, all parties shall continue to afford the 8 material in question the level of protection to which it is entitled under 9 the Producing Party’s designation until the Court rules on the challenge. 10 11 8. ACCESS TO AND USE OF PROTECTED MATERIALS 12 8.1. Basic Principles. 13 A Receiving Party may use Protected Material that is disclosed or 14 produced by another Party or by a Nonparty in connection with this 15 Action only for prosecuting, defending, or attempting to settle this 16 Action. Such Protected Material may be disclosed only to the categories 17 of persons and under the conditions described in this Stipulated 18 Protective Order. When the Action reaches a final disposition, a 19 Receiving Party must comply with the provisions of Section 14 below. 20 Protected Material must be stored and maintained by a Receiving 21 Party at a location and in a secure manner that ensures that access is 22 limited to the persons authorized under this Stipulated Protective Order. 23 8.2. Disclosure of “CONFIDENTIAL” Information or Items. 24 Unless otherwise ordered by the Court or permitted in writing by 25 the Designating Party, a Receiving Party may disclose any information 26 or item designated “CONFIDENTIAL” only to: 27 (a) The Receiving Party’s Outside Counsel of record in this action, as 1 necessary to disclose the information for this Action; 2 (b) The officers, directors, and employees (including In-House 3 Counsel) of the Receiving Party to whom disclosure is reasonably 4 necessary for this Action; 5 (c) Experts of the Receiving Party to whom disclosure is reasonably 6 necessary for this Action and who have signed the 7 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 8 (d) The Court and its personnel; 9 (e) Court reporters and their staff; 10 (f) Professional jury or trial consultants, mock jurors, and 11 Professional Vendors to whom disclosure is reasonably necessary 12 for this Action and who have signed the “Acknowledgment and 13 Agreement to be Bound” (Exhibit A); 14 (g) The author or recipient of a document containing the information 15 or a custodian or other person who otherwise possessed or knew 16 the information; 17 (h) During their depositions, witnesses, and attorneys for witnesses, 18 in the Action to whom disclosure is reasonably necessary 19 provided: (i) the deposing party requests that the witness sign the 20 “Acknowledgment and Agreement to Be Bound” (Exhibit A); and 21 (ii) the witness will not be permitted to keep any confidential 22 information unless they sign the “Acknowledgment and 23 Agreement to Be Bound,” unless otherwise agreed by the 24 Designating Party or ordered by the Court. Pages of transcribed 25 deposition testimony or exhibits to depositions that reveal 26 Protected Material may be separately bound by the court reporter 27 and may not be disclosed to anyone except as permitted under this 1 (i) Any mediator or settlement officer, and their supporting 2 personnel, mutually agreed upon by any of the parties engaged in 3 settlement discussions. 4 5 9. PROTECTED MATERIAL SUBPOENAED OR ORDERED 6 PRODUCED IN OTHER LITIGATION 7 If a Party is served with a subpoena or a court order issued in other litigation 8 that compels disclosure of any information or items designated in this Action as 9 “CONFIDENTIAL,” that Party must: 10 (a) Promptly notify in writing the Designating Party. Such notification shall 11 include a copy of the subpoena or court order; 12 (b) Promptly notify in writing the party who caused the subpoena or order 13 to issue in the other litigation that some or all of the material covered by 14 the subpoena or order is subject to this Stipulated Protective Order. Such 15 notification shall include a copy of this Stipulated Protective Order; and 16 (c) Cooperate with respect to all reasonable procedures sought to be pursued 17 by the Designating Party whose Protected Material may be affected. 18 If the Designating Party timely seeks a protective order, the Party served with 19 the subpoena or court order shall not produce any information designated in this action 20 as “CONFIDENTIAL” before a determination by the court from which the subpoena 21 or order issued, unless the Party has obtained the Designating Party’s permission. The 22 Designating Party shall bear the burden and expense of seeking protection in that court 23 of its confidential material – and nothing in these provisions should be construed as 24 authorizing or encouraging a Receiving Party in this action to disobey a lawful 25 directive from another court. 26 27 10. A NON PARTYS’ PROTECTED MATERIAL SOUGHT TO BE 1 10.1. Application. 2 The terms of this Stipulated Protective Order are applicable to 3 information produced by a Nonparty in this Action and designated as 4 “CONFIDENTIAL.” Such information produced by Nonparties in 5 connection with this litigation is protected by the remedies and relief 6 provided by this Stipulated Protective Order. Nothing in these provisions 7 should be construed as prohibiting a Nonparty from seeking additional 8 protections. 9 10.2. Notification. 10 In the event that a Party is required, by a valid discovery request, 11 to produce a Nonparty’s confidential information in its possession, and 12 the Party is subject to an agreement with the Nonparty not to produce the 13 Nonparty’s confidential information, then the Party shall: 14 (a) Promptly notify in writing the Requesting Party and the Nonparty 15 that some or all of the information requested is subject to a 16 confidentiality agreement with a Nonparty; 17 (b) Promptly provide the Nonparty with a copy of the Stipulated 18 Protective Order in this Action, the relevant discovery request(s), 19 and a reasonably specific description of the information requested; 20 and 21 (c) Make the information requested available for inspection by the 22 Nonparty, if requested. 23 10.3. Conditions of Production. 24 If the Nonparty fails to seek a protective order from this Court 25 within fourteen (14) days after receiving the notice and accompanying 26 information, the Receiving Party may produce the Nonparty’s 27 confidential information responsive to the discovery request. If the 1 produce any information in its possession or control that is subject to the 2 confidentiality agreement with the Nonparty before a determination by 3 the Court. Absent a court order to the contrary, the Nonparty shall bear 4 the burden and expense of seeking protection in this Court of its 5 Protected Material. 6 7 11. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 8 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 9 Protected Material to any person or in any circumstance not authorized under this 10 Stipulated Protective Order, the Receiving Party must immediately: (1) notify in 11 writing the Designating Party of the unauthorized disclosures; (2) use its best efforts 12 to retrieve all copies of the Protected Material; (3) inform the person or persons to 13 whom unauthorized disclosures were made of all the terms of this Stipulated 14 Protective Order; and (4) request such person or persons to execute the 15 “Acknowledgement and Agreement to be Bound” (Exhibit A). 16 17 12. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 18 PROTECTED MATERIAL 19 When a Producing Party gives notice to Receiving Parties that certain 20 inadvertently produced material is subject to a claim of privilege or other protection, 21 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 22 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 23 may be established in an e-discovery order that provides for production without prior 24 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 25 parties reach an agreement on the effect of disclosure of a communication or 26 information covered by the attorney-client privilege or work product protection, the 27 parties may incorporate their agreement in the Stipulated Protective Order submitted 1 2 13. PUBLICATION OF PROTECTED MATERIAL PROHIBITED. 3 13.1. Public Dissemination of Protected Material. 4 A Receiving Party shall not publish, release, post, or disseminate Protected 5 Material to any persons except those specifically delineated and authorized by this 6 Stipulated Protective Order; nor shall a Receiving Party publish, release, leak, post, 7 or disseminate Protected Material to any news media, member of the press, website, 8 or public forum. 9 10 14. MISCELLANEOUS 11 14.1. Right to Further Relief. 12 Nothing in this Stipulated Protective Order abridges the right of 13 any person to seek its modification by the Court in the future. 14 14.2. Right to Assert Other Objections. 15 By stipulating to the entry of this Stipulated Protective Order, no 16 Party waives any right it otherwise would have to object to disclosing or 17 producing any information or item on any ground not addressed in this 18 Stipulated Protective Order. Similarly, no Party waives any right to 19 object on any ground to use in evidence any of the material covered by 20 this Stipulated Protective Order. 21 14.3. Filing Protected Material. 22 A Party that seeks to file under seal any Protected Material must 23 comply with Local Rule 79-5. Protected Material may only be filed 24 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 26 under seal is denied by the Court, then the Receiving Party may file the 27 information in the public record unless otherwise instructed by the Court. 1 15. FINAL DISPOSITION. 2 After the final disposition of this Action, within sixty (60) days of a written 3 request by the Designating Party, each Receiving Party must return all Protected 4 Material to the Producing Party or destroy such material. As used in this subdivision, 5 “all Protected Material” includes all copies, abstracts, compilations, summaries, and 6 any other format reproducing or capturing any of the Protected Material. Whether the 7 Protected Material is returned or destroyed, the Receiving Party must submit a written 8 certification to the Producing Party (and, if not the same person or entity, to the 9 Designating Party) by the 60-day deadline that (1) identifies (by category, where 10 appropriate) all the Protected Material that was returned or destroyed and (2) affirms 11 that the Receiving Party has not retained any copies, abstracts, compilations, 12 summaries or any other format reproducing or capturing any of the Protected Material. 13 Notwithstanding this provision, Counsel is entitled to retain an archival copy of all 14 pleadings; motion papers; trial, deposition, and hearing transcripts; legal memoranda; 15 correspondence; deposition and trial exhibits; expert reports; attorney work product; 16 and 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 Stipulate Protective Order as set forth in Section 5. 19 20 16. VIOLATION. 21 Any violation of this Stipulated Order may be punished by any and all 22 appropriate measures including, without limitation, contempt proceedings and/or 23 monetary sanctions. 24 25 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 26 27 1 || DATED: August 6, 2025 QURESHI LAW PC 2 3 By: Mar Schocning 4 MAX A. SCHOENING

OMAR G. QURESHI

5 Attorneys for Plaintiff, 6 COREY CRITTENDEN 7 9 DATED: August 6, 2025 LEWIS BRISBOIS BISGAARD & SMITH LLP

10 By: Fort L.1. Caklen

TONY SAIN

12 TORI L. N. BAKKEN Attorneys for Defendants,

COUNTY OF LOS ANGELES,

14 MICHAEL ALBUREZ, BRANDON 15 VANARSDALE, and TERRIE COATS 16 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. ' t iy 17 Dated: 08/08/2025 + 18 Maria Al Widére 19 United States"Magistrate Judge 20 21 22 23 24 25 26 27 28

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1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, ________________________ [full name], of ________________________ 4 ________________ [address], declare under penalty of perjury that I have read in its 5 entirety and 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 ___________________________________________________ 8 [case name and number]. I agree to comply with and to be bound by all the terms of 9 this Stipulated Protective Order, and I understand and acknowledge that failure to so 10 comply could expose me to sanctions and punishment in the nature of contempt. I 11 solemnly promise that I will not disclose in any manner any information or item that 12 is subject to this Stipulated Protective Order to any person or entity except in strict 13 compliance with the provisions of this Stipulated Protective Order. 14 I further agree to submit to the jurisdiction of the United States District Court 15 for the Central District of California for the purpose of enforcing the terms of this 16 Stipulated Protective Order, even if such enforcement proceedings occur after 17 termination of this action. I hereby appoint ________________________ [full name] 18 of ________________________________________ [address and telephone number] 19 as my California agent for service of process in connection with this action or any 20 proceedings related to enforcement of this Stipulated Protective Order. 21 22 Signature: __________________________ 23 Printed Name: __________________________ 24 Date: __________________________ 25 City and State Where Sworn and Signed: __________________________ 26 27 1 FEDERAL COURT PROOF OF SERVICE Crittenden, Corey v. County of Los Angeles, et al. 2 USDC Case No. 3:25-CV-02852- WC (MAAx); C/M# 58702-06 3 || STATE OF CALIFORNIA, COUNTY OF LOS ANGELES 4 At the time of service, I was over 18 years of age and not a party to the action. My business address is 633 West 5th Street, Suite 4000, Los Angeles, CA 90071. I 5 ||am employed in the office of a member of the bar of this Court at whose direction the service was made. 6 On August 6, 2025, I served the following document(s): STIPULATED 7|| PROTECTIVE ORDER I served the documents on the following persons at the following addresses 9 || (including fax numbers and e-mail addresses, 1f applicable): 10 || Omar G. Qureshi, Esq. Attorneys for Plaintiff, Max A. Sc ogning. Esq. COREY CRITTENDEN 11 QURESHI LAW PC 700 Flower Street, Suite 1000 12 || Los Angeles, CA 90017 Telephone: 213.786.3478 13 || Facsimile: 213.277.8989 14 The documents were served by the following means: 15 (BY E-MAIL OR ELECTRONIC TRANSMISSION) Based on a court order or an agreement of the parties to accept service by e-mail or electronic _ 16 transmission, I caused the documents to be sent to the persons at the e-mail addresses listed above. I did not receive, within a reasonable time after the 17 transmission, any electronic message or other indication that the transmission was unsuccessful. 18 I declare under penalty of perjury under the laws of the United States of 19 || America and the State of California that the foregoing is true and correct. 20 Executed on August 6, 2025, at Los Angeles, California. 21 /s! Carfew F, Wileon Curfew F. Wilson 23 24 25 26 27 28