1 Eugene P. Ramirez (State Bar No. 134865) eugene.ramirez@manningkass.com 2 Geoffrey Plowden (State Bar No. 146602) geoffrey.plowden@manningkass.com 3 Eugene Hanrahan (State Bar No. 185826) eugene.hanrahan@manningkass.com 4 MANNING & KASS

ELLROD, RAMIREZ, TRESTER LLP

5 801 S. Figueroa St, 15th Floor Los Angeles, California 90017-3012 6 Telephone: (213) 624-6900 Facsimile: (213) 624-6999 7

8 Attorneys for Defendants CITY OF DOWNEY,

GILBERT TOLEDO, DWAYNE COOPER,

9 DAN PONDER and DANIEL SAMANO

10

11 UNITED STATES DISTRICT COURT 12 CENTRAL DISTRICT OF CALIFORNIA 13 RONNIE VELAZQUEZ, Case No. 2:25-cv-00975-HDV-PD

ABRAHAM VILLALOBOS,

14 Plaintiff, 15 v. STIPULATED PROTECTIVE 16 ORDER

CITY OF DOWNEY, COUNTY OF

17 LOS ANGELES, DOWNEY PD

DET. GILBERT TOLEDO, DET.

18 DWAYNE COOPER, DET. DAN

PONDER, DET. DANIEL SAMANO,

19 AND DOES 1-10, Inclusive,

20 Defendants 21 22 23 24 1. GENERAL 25 1.1 Purposes and Limitations. Discovery in this action is likely to involve 26 production of confidential, proprietary, or private information for which special protection 27 from public disclosure and from use for any purpose other than prosecuting this litigation may be warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter 1 the following Stipulated Protective Order. The parties acknowledge that this Order does not 2 confer blanket protections on all disclosures or responses to discovery and that the protection 3 it affords from public disclosure and use extends only to the limited information or items that 4 are entitled to confidential treatment under the applicable legal principles. The parties further 5 acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective Order does 6 not entitle them to file confidential information under seal; Civil Local Rule 79-5 sets forth 7 the procedures that must be followed and the standards that will be applied when a party seeks 8 permission from the court to file material under seal. 9 1.2 Good Cause Statement. 10 This is a Section 1983 action which stems from the alleged wrongful arrest, 11 prosecution, and incarceration of Plaintiffs Ronnie Velasquez and Abraham Villalobos. 12 In connection with these proceedings the parties will be required to exchange information 13 and disclose documents in discovery which they deem confidential. Such information 14 includes documents containing personal, medical, psychiatric, mental health, criminal 15 history, financial information, and official information of the parties and third-party 16 witnesses, District Attorney's notes and files, and gory crime scene photographs, which 17 are otherwise generally unavailable to the public, or which may be otherwise protected 18 from disclosure under state or federal statutes, court rules, case decisions, or common 19 law. The parties object to disclosure of this information and production of these 20 documents unless appropriate protection for their confidentiality is assured. 21 Accordingly, to expedite the flow of information, to facilitate the prompt 22 resolution of disputes over confidentiality of discovery materials, to adequately protect 23 information the parties are entitled to keep confidential, to ensure that the parties are 24 permitted reasonable necessary uses of such material in preparation for and in the 25 conduct of trial, to address their handling at the end of the litigation, and serve the ends 26 of justice, a protective order for such information is justified in this matter. It is the 27 intent of the parties that information will not be designated as confidential for tactical 1 reasons and that nothing be so designated without a good faith belief that it has been 2 maintained in a confidential, non-public manner, and there is good cause why it should 3 not be part of the public record of this case. 4 2. DEFINITIONS 5 2.1 Action: this pending federal lawsuit. 6 2.2 Challenging Party: a Party or Non-Party that challenges the designation of 7 information or items under this Order 8 2.3 "CONFIDENTIAL" Information or Items: information (regardless of how 9 it is generated, stored or maintained) or tangible things that qualify for protection under 10 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 11 Statement, which the Designating Party marks as "CONFIDENTIAL" with a bates stamp 12 or otherwise identifies and designates as "CONFIDENTIAL" in a writing to all parties. 13 Documents and information shall not be designated or considered Confidential 14 Information to the extent they are otherwise publicly available or already rightfully in the 15 Receiving Party's possession from another source without confidentiality restrictions. 16 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 17 support staff). 18 2.5 Designating Party: a Party or Non-Party that designates information or 19 items that it produces in disclosures or in responses to discovery as 20 "CONFIDENTIAL." 21 2.6 Disclosure or Discovery Material: all items or information, regardless of the 22 medium or manner in which it is generated, stored, or maintained (including, among other 23 things, testimony, transcripts, and tangible things), that are produced or generated in disclosures 24 or responses to discovery in this matter,. 25 2.7 Expert: a person with specialized knowledge or experience in a matter pertinent 26 to the litigation who has been retained by a Party or its counsel to serve as an expert witness or 27 as a consultant in this Action, and investigators. 1 2.8 House Counsel: attorneys who are employees of a party to this Action. 2 House Counsel does not include Outside Counsel of Record or any other outside 3 counsel. 4 2.9 Non-Party: any natural person, partnership, corporation, association, or 5 other legal entity not named as a Party to this action. 6 2.10 Outside Counsel of Record: attorneys who are not employees of a party 7 to this Action but are retained to represent or advise a party to this Action and have 8 appeared in this Action on behalf of that party or are affiliated with a law firm that has 9 appeared on behalf of that party, including support staff and retained investigators. 10 2.11 Party: any party to this Action, including all of its officers, directors, 11 employees, consultants, retained experts, and Outside Counsel of Record (and their 12 support staffs). 13 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 14 Discovery Material in this Action. 15 2.13 Professional Vendors: persons or entities that provide litigation support 16 services (e.g., photocopying, videotaping, translating, preparing exhibits or 17 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 18 their employees and subcontractors. 19 2.14 Protected Material: any Disclosure or Discovery Material that is designated 20 as "CONFIDENTIAL." 21 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material from 22 a Producing Party. 23 3. SCOPE 24 The protections conferred by this Stipulation and Order cover not only Protected 25 Material (as defined above), but also (1) any information copied or extracted from 26 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 27 Material; and (3) any testimony, conversations, or presentations by Parties or their Counsel 1 Any use of Protected Material at trial shall be governed by the orders of the trial 2 judge. This Order does not govern the use of Protected Material at trial. 3 4. DURATION 4 Once a case proceeds to trial, all of the court-filed information to be introduced 5 that was previously designated as confidential or maintained pursuant to this 6 protective order becomes public and will be presumptively available to all members 7 of the public, including the press, unless compelling reasons supported by specific 8 factual findings to proceed otherwise are made to the trial judge in advance of the 9 trial. See Kamakana v. City and Cty. of Honolulu, 447 F.3d 1172, 1180-81 10 (9th Cir. 2006) (distinguishing "good cause" showing for sealing documents produced 11 in discovery from "compelling reasons" standard when merits-related documents are 12 part of court record). Accordingly, the terms of this protective order do not extend 13 beyond the commencement of the trial. 14 5. DESIGNATING PROTECTED MATERIAL 15 5.1 Exercise of Restraint and Care in Designating Material for 16 Protection. Each Party or Non-Party that designates information or items for protection 17 under 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 for 19 protection only those parts of material, documents, items, or oral or written 20 communications that qualify so that other portions of the material, documents, items, or 21 communications for which protection is not warranted are not swept unjustifiably within 22 the ambit of this Order. 23 Mass, indiscriminate, or routinized 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 impose 26 unnecessary expenses and burdens on other parties) may expose the Designating 27 Party to sanctions. 1 If it comes to a Designating Party's attention that information or items that it 2 designated for protection do not qualify for protection, that Designating Party must 3 promptly notify all other Parties that it is withdrawing the inapplicable designation. 4 5.2 Manner and Timing of Designations. Except as otherwise provided 5 in this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 6 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 7 under this Order must be clearly so designated before or at the time the material is 8 disclosed or produced. 9 Designation in conformity with this Order requires: 10 (a) for information in documentary form (e.g., paper or electronic 11 documents, but excluding transcripts of depositions or other pretrial or trial 12 proceedings), that the Producing Party affix, at a minimum, the legend 13 "CONFIDENTIAL" (hereinafter "CONFIDENTIAL legend"), to each page that 14 contains protected material or otherwise identify the designated material as 15 "CONFIDENTIAL" by bates stamp in a writing to all parties. If only a portion or 16 portions of the material on a page qualifies for protection, the Producing Party also 17 must clearly identify the protected portion(s) (e.g., by making appropriate markings 18 in the margins). 19 A Party or Non-Party that makes original documents available for inspection 20 need not designate them for protection until after the inspecting Party has indicated 21 which documents it would like copied and produced. During the inspection and before 22 the designation, all of the material made available for inspection shall be deemed 23 "CONFIDENTIAL." After the inspecting Party has identified the documents it wants 24 copied and produced, the Producing Party must determine which documents, or 25 portions thereof, qualify for protection under this Order. Then, before producing the 26 specified documents, the Producing Party must affix the "CONFIDENTIAL legend" 27 to each page that contains Protected Material. If only a portion or portions of the 1 identify the protected portion(s) (e.g., by making appropriate markings in the 2 margins). 3 (b) for testimony given in depositions that the Designating Party identify 4 the Disclosure or Discovery Material on the record as "CONFIDENTIAL" and clearly 5 indicate which portions of the deposition transcript should be marked confidential, either 6 before the close of the deposition or after the close of the deposition in a writing to all 7 parties identifying protected portions marked "CONFIDENTIAL" by page numb et, 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 the 10 exterior of the container or containers in which the information is stored the legend 11 "CONFIDENTIAL." If only a portion or portions of the information warrants protection, 12 the Producing Party, to the extent practicable, shall identify the protected portion(s). 13 (d) no material produced in this litigation shall be considered "CONFIDENTIAL" 14 or protected information unless and until it is explicitly so designated in accordance with the 15 terms of this subsection 5.2. 16 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 17 failure to designate qualified information or items does not, standing alone, waive the 18 Designating Party's right to secure protection under this Order for such material. Upon 19 timely correction of a designation, the Receiving Party must make reasonable efforts 20 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 23 designation of confidentiality at any time that is consistent with the Court's 24 Scheduling Order. 25 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution 26 process under Local Rule 37-1, et seq. 27 6.3 Burden. The burden of persuasion in any such challenge proceeding 1 shall be on the Designating Party. Frivolous challenges, and those made for an improper 2 purpose (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 3 expose the Challenging Party to sanctions. Unless the Designating Party has waived or 4 withdrawn the confidentiality designation, all parties shall continue to afford the material in 5 question the level of protection to which it is entitled under the Producing Party's designation 6 until the Court rules on the challenge. 7 7. ACCESS TO AND USE OF PROTECTED MATERIAL 8 7.1 Basic Principles. A Receiving Party may use Protected Material that is 9 disclosed or produced by another Party or by a Non-Party in connection with this Action 10 only for prosecuting, defending, or attempting to settle this Action. Such Protected 11 Material may be disclosed only to the categories of persons and under the conditions 12 described in this Order. When the Action has been terminated, a Receiving Party must 13 comply with the provisions of section 13 below (FINAL DISPOSITION). 14 Protected Material must be stored and maintained by a Receiving Party at a location 15 and in a secure manner that ensures that access is limited to the persons authorized under 16 this Order 17 7.2 Disclosure of "CONFIDENTIAL" Information or Items. Unless 18 otherwise ordered by the Court or permitted in writing by the Designating Party, 19 a Receiving Party may disclose any information or item designated 20 "CONFIDENTIAL" only to: 21 (a) the Receiving Party or the Receiving Party's Outside Counsel of Record 22 in this Action, as well as employees of said Outside Counsel of Record to whom it is 23 reasonably necessary to disclose the information for this Action; 24 (b) the officers, directors, and employees (including House Counsel) of the 25 Receiving Party to whom disclosure is reasonably necessary for this Action; 26 (c) Experts (as defined in this Order) of the Receiving Party to whom 27 disclosure is reasonably necessary for this Action and who have signed the 1 (d) the Court and its personnel; 2 (e) court reporters and their staff; 3 (f) professional jury or trial consultants, mock jurors, and Professional 4 Vendors to whom disclosure is reasonably necessary for this Action and who have signed 5 the "Acknowledgment and Agreement to Be Bound" (Exhibit A); 6 (g) the author or recipient of a document containing the information or a 7 custodian or other person who otherwise possessed or knew the information; 8 (h) during their depositions or in preparation for their depositions, 9 witnesses, and attorneys for witnesses, in the Action to whom disclosure is reasonably 10 necessary for the prosecution or defense of the case provided: (1) the witness is 11 informed of the confidential nature of the information consistent with the terms of this 12 order and (2) they will not be permitted to keep any confidential information other than 13 documents authored by or specifically pertaining to the witness unless they sign the 14 "Acknowledgment and Agreement to Be Bound" (Exhibit A), unless otherwise agreed 15 by the Designating Party or ordered by the Court. Pages of transcribed deposition 16 testimony or exhibits to depositions that reveal Protected Material may be separately 17 bound by the court reporter and may not be disclosed to anyone except as permitted 18 under this Stipulated Protective Order; and 19 (i) any mediator or settlement officer, and their supporting personnel, 20 mutually agreed upon by any of the parties engaged in settlement discussions. 21 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 22

PRODUCED IN OTHER LITIGATION

23 If a Party is served with a subpoena or a court order issued in other litigation that 24 compels disclosure of any information or items designated in this Action as 25 "CONFIDENTIAL," that Party must: 26 (a) promptly notify in writing the Designating Party. Such notification shall include 27 a copy of the subpoena or court order; 1 (b) promptly notify in writing the party who caused the subpoena or order to issue 2 in the other litigation that some or all of the material covered by the subpoena or order is 3 subject to this Protective Order. Such notification shall include a copy of this Stipulated 4 Protective Order; and 5 (c) cooperate with respect to all reasonable procedures sought to be pursued by the 6 Designating Party whose Protected Material may be affected. 7 If the Designating Party timely seeks a protective order, the Party served with the 8 subpoena or court order shall not produce any information designated in this action as 9 "CONFIDENTIAL" before a determination by the court from which the subpoena or order 10 issued, unless the Party has obtained the Designating Party's permission. The Designating 11 Party shall bear the burden and expense of seeking protection in that court of its confidential 12 material and nothing in these provisions should be construed as authorizing or encouraging 13 a Receiving Party in this Action to disobey a lawful directive from another court. 14 9. A NON-PARTY'S PROTECTED MATERIAL SOUGHT TO BE 15 PRODUCED IN THIS LITIGATION 16 (a) The terms of this Order are applicable to information produced by a Non- 17 Party in this Action and designated as "CONFIDENTIAL." Such information 18 produced by Non-Parties in connection with this litigation is protected by the 19 remedies and relief provided by this Order. Nothing in these provisions should be 20 construed as prohibiting a Non-Party from seeking additional protections. 21 (b) In the event that a Party is required, by a valid discovery request, to produce a 22 Non-Party's confidential information in its possession, and the Party is subject to an 23 agreement with the Non-Party not to produce the Non-Party's confidential information, 24 then the Party shall: 25 (1) promptly notify in writing the Requesting Party and the Non-Party that 26 some or all of the information requested is subject to a confidentiality agreement with a 27 Non-Party; 1 Order in this Action, the relevant discovery request(s), and a reasonably specific 2 description of the information requested; and 3 (3) make the information requested available for inspection by the Non- 4 Party, if requested. 5 (c) If the Non-Party fails to seek a protective order from this Court within 14 days 6 of receiving the notice and accompanying information, the Receiving Party may produce 7 the Non-Party's confidential information responsive to the discovery request. If the Non- 8 Party timely seeks a protective order, the Receiving Party shall not produce any 9 information in its possession or control that is subject to the confidentiality agreement 10 with the Non-Party before a determination by the Court. Absent a court order to the 11 contrary, the Non-Party shall bear the burden and expense of seeking protection in this 12 Court of its Protected Material. 13 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 14 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 15 Protected Material to any person or in any circumstance not authorized under this 16 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 17 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 18 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 19 persons to whom unauthorized disclosures were made of all the terms of this Order, 20 and (d) request such person or persons to execute the "Acknowledgment and 21 Agreement to Be Bound" that is attached hereto as Exhibit A. 22 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 23 PROTECTED MATERIAL 24 When a Producing Party gives notice to Receiving Parties that certain 25 inadvertently produced material is subject to a claim of privilege or other protection, the 26 obligations of the Receiving Parties are those set forth in Federal Rule of Civil 27 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 1 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 2 parties reach an agreement on the effect of disclosure of a communication or information 3 covered by the attorney-client privilege or work product protection, the parties may 4 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 7 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 9 Protective Order, no Party waives any right it otherwise would have to object to 10 disclosing or producing any information or item on any ground not addressed in this 11 Stipulated Protective Order. Similarly, no Party waives any right to object on any 12 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 14 Material must comply with Civil Local Rule 79-5. Protected Material may only be filed 15 under seal pursuant to a court order authorizing the sealing of the specific Protected 16 Material at issue. If a Party's request to file Protected Material under seal is denied by the 17 Court, then the Receiving Party may file the information in the public record unless 18 otherwise instructed by the Court. 19 13. FINAL DISPOSITION 20 After the final disposition of this Action, including any appeals, within 180 days 21 of a written request by the Designating Party, each Receiving Party must return all 22 Protected Material to the Producing Party or destroy such material. As used in this 23 subdivision, "all Protected Material" includes all copies, abstracts, compilations, 24 summaries, and any other format reproducing or capturing any of the Protected Material. 25 Whether the Protected Material is returned or destroyed, the Receiving Party must submit 26 a written certification to the Producing Party (and, if not the same person or entity, to the 27 Designating Party) by the 60 day deadline that (1) identifies (by category, where 1 the Receiving Party has not retained any copies, abstracts, compilations, summaries or 2 any other format reproducing or capturing any of the Protected Material. 3 Notwithstanding this provision, counsel are entitled to retain an archival copy of 4 all pleadings, motion papers, trial, deposition, and hearing transcripts, legal 5 memoranda, correspondence, deposition and trial exhibits, expert reports, attorney 6 work product, and consultant and expert work product, even if such materials contain 7 Protected Material. Any such archival copies that contain or constitute Protected 8 Material remain subject to this Protective Order as set forth in Section 4 (DURATION). 9 14. VIOLATION OF ORDER 10 Any violation of this Order may be punished by any and all appropriate measures 11 including, without limitation, contempt proceedings and/or monetary sanctions. 12

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

13

14 Dated: August 15, 2025 /s/___Tome Beck___________________ 15 Thomas Beck Attorney for Plaintiff 16 17 18 19 Dated: August 15, 2025 /s/___Dave McLane_____________ David McLane 20 McLane, Bednarski & Litt, LLC 21 Attorneys for Plaintiff 22 23 Dated: August 15, 2025 /s/ Geoffrey Plowden________________ 24 Eugene Ramirez 25 Geoffrey Plowden 26 Eugene Hanrahan Manning Kass, LLC 27 Attorneys for Defendants City of Downey 5 Dated: August 15, 2025 /s/ Christine Adams Christine Adams 3 Adam Kamenstein 4 Adams, Duerk & Kamenstein LLP Attorneys for Defendant County of Los 5 Angeles 6 || FOR GOOD CAUSE HAVING BEEN SHOW, IT IS SO ORDERED. 8 Los Dated: Aug. 15, 2025 Talia Lrnakoe_ 10 Hon. Patricia Donahue United States Magistrate Judge 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28