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77 88 UNITED STATES DISTRICT COURT 99 CENTRAL DISTRICT OF CALIFORNIA 1100 SOUTHERN DIVISION

1111 MARISELLA MACIAS, Case No: 8:19-cv-01082-DOC (JDEx) 1122 Plaintiff, 1133 STIPULATED PROTECTIVE vs. ORDER 1144

CITY OF FULLERTON, JOSEPH

1155 ZUNIGA, individually and as a peace officer, DOES 1-10, inclusive 1166 Defendants. 1177

1188 Pursuant to the Stipulation of the parties (Dkt. 16), the Court makes the 1199 following findings and enters the following Order. 2200 1. PURPOSES AND LIMITATIONS 2211 Discovery in this action involves production of confidential, proprietary, or 2222 private information for which special protection from public disclosure and from 2233 use for any purpose other than prosecuting this litigation may be warranted. 2244 Accordingly, the parties hereby stipulate to and petition the Court to enter the 2255 following Order. The parties acknowledge that this Order does not confer blanket 2266 protections on all disclosures or responses to discovery and that the protection it 2277 11 affords from public disclosure and use extends only to the limited information or

22 items that are entitled to confidential treatment under the applicable legal 33 principles. The parties further acknowledge, as set forth in Section 13.3, below, 44 that this Order does not entitle them to file confidential information under seal; 55 Local Civil Rule 79-5 sets forth the procedures that must be followed and the 66 standards that will be applied when a party seeks permission from the court to file 77 material under seal. There is a strong presumption that the public has a right of 88 access to judicial proceedings and records in civil cases. In connection with non- 99 dispositive motions, good cause must be shown to support a filing under seal. See 1100 Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), 1111 Phillips v. Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar- 1122 Welbon v. Sony Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even 1133 stipulated protective orders require good cause showing), and a specific showing of 1144 good cause or compelling reasons with proper evidentiary support and legal 1155 justification, must be made with respect to Protected Material that a party seeks to 1166 file under seal. The parties’ mere designation of Disclosure or Discovery Material 1177 (as defined below) as CONFIDENTIAL does not— without the submission of 1188 competent evidence by declaration, establishing that the material sought to be filed 1199 under seal qualifies as confidential, privileged, or otherwise protectable— 2200 constitute good cause. 2211 Further, if a party requests sealing related to a dispositive motion or trial, 2222 then compelling reasons, not only good cause, for the sealing must be shown, and 2233 the relief sought shall be narrowly tailored to serve the specific interest to be 2244 protected. See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 2255 2010). For each item or type of information, document, or thing sought to be filed 2266 or introduced under seal, the party seeking protection must articulate compelling 2277 reasons, supported by specific facts and legal justification, for the requested sealing

order. Again, competent evidence supporting the application to file documents 11 under seal must be provided by declaration.

22 Any document that is not confidential, privileged, or otherwise protectable 33 in its entirety will not be filed under seal if the confidential portions can be 44 redacted. If documents can be redacted, then a redacted version for public viewing, 55 omitting only the confidential, privileged, or otherwise protectable portions of the 66 document, shall be filed. Any application that seeks to file documents under seal in 77 their entirety should include an explanation of why redaction is not feasible. 88 2. GOOD CAUSE STATEMENT 99 This action involves law enforcement tactics, procedures, training, 1100 regulations, personnel, investigations and rules for which special protection from 1111 public disclosure and from use for any purpose other than prosecution of this 1122 action is warranted. Such confidential and proprietary materials and information 1133 consist of, among other things, documents maintained by the Fullerton Police 1144 Department and include, but are not limited to, internal policies and procedures, 1155 internal affairs investigation files, criminal investigation files, personnel files of 1166 current and/or former FPD officers, and other documents and information which 1177 implicate the privacy rights of parties and non-parties, which information is 1188 generally unavailable to the public and which is privileged or otherwise protected 1199 from disclosure under state and federal statutes, court rules, case decisions, or 2200 common law. Accordingly, to expedite the flow of information, to facilitate the 2211 prompt resolution of disputes over confidentiality of discovery materials, to 2222 adequately protect information the parties are entitled to keep confidential, to 2233 ensure that the parties are permitted reasonable necessary uses of such material in 2244 preparation for and in the conduct of trial, to address their handling at the end of 2255 the litigation, and serve the ends of justice, a protective order for such information 2266 is justified in this matter. It is the intent of the parties that information will not be 2277 designated as confidential for tactical reasons and that nothing be so designated

without a good faith belief that it has been maintained in a confidential, non-public 11 manner, and there is good cause why it should not be part of the public record in

22 this case. 33 3. DEFENITIONS 44 3.1 Action: This pending lawsuit filed by Marisella Macias against 55 the City of Fullerton and Cpl. Joseph Zuniga, Case No. 8:19-cv-01082 DOC 66 (JDEx) (C.D. Cal.). 77 3.2 Challenging Party: A Party that challenges the designation of 88 information or items under this Order. 99 3.3 "CONFIDENTIAL" Information or Items: Disclosure or 1100 Discovery Material (as defined in sub-paragraph 3.6 below) that qualify for 1111 protection under Fed. R. Civ. P. 26(c), and as specified above in the Good Cause 1122 Statement. 1133 3.4 Counsel: Outside Counsel of Record and House Counsel (as 1144 well as their support staff). 1155 3.5 Designating Party: A Party that designates information or items 1166 that it produces in disclosures or in responses to discovery as "CONFIDENTIAL" 1177 or "ATTORNEYS EYES ONLY." 1188 3.6 Disclosure or Discovery Material: All items or information, 1199 regardless of the medium or manner in which it is generated, stored, or maintained 2200 (including, among other things, testimony, transcripts, and tangible things), that are 2211 produced or generated in disclosures or responses to discovery in this Action. 2222 3.7 Expert: A person with specialized knowledge or experience in a 2233 matter pertinent to the litigation who has been retained by a Party or its counsel to 2244 serve as an expert witness or as a consultant in this Action. 2255 3.8 "ATTORNEYS EYES ONLY" Information or Items: 2266 Disclosure or Discovery Material (as defined in sub-paragraph 3.6 above) that 2277 qualify for protection under Fed. R. Civ. P. 26(c), and as specified above in the

Good Cause Statement, and that qualify for the highest level of confidentiality. 11 3.9 House Counsel: Attorneys who are employees of a Party to this

22 Action. House Counsel does not include Outside Counsel of Record or any other 33 outside counsel. 44 3.10 Non-Party: Any natural person, partnership, corporation, 55 association, or other legal entity not named as a Party to this action. 66 3.11 Order: This Stipulated Protective Order. 77 3.12 Outside Counsel of Record: Attorneys who are not employees 88 of a Party to this Action but are retained to represent or advise a Party to this 99 Action and have appeared in this Action on behalf of that Party or are affiliated 1100 with a law firm which has appeared on behalf of that Party. 1111 3.13 Party: Any party to this Action, including all of its officers, and 1122 directors (and their support staffs). 1133 3.14 Personal Information: Personal Information includes, but is not 1144 limited to, Social Security numbers, home addresses, telephone numbers, driver's 1155 license numbers, and license plate numbers. 1166 3.15 Producing Party: A Party or Non-Party that produces 1177 Disclosure or Discovery Material in this Action. 1188 3.16 Professional Vendors: Persons or entities that provide litigation 1199 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 2200 demonstrations, and organizing, storing, or retrieving data in any form or medium) 2211 and their employees and subcontractors. 2222 3.17 Protected Material: Any Disclosure or Discovery Material that 2233 is designated as "CONFIDENTIAL" or "ATTORNEYS EYES ONLY." 2244 3.18 Receiving Party: A Party that receives Disclosure or Discovery 2255 Material from a Producing Party. 2266 4. SCOPE 2277 The protections conferred by this Order cover not only Protected Material

(as defined above), but also (1) any information copied or extracted from Protected 11 Material; (2) all copies, excerpts, abstracts, summaries, or compilations of

22 Protected Material; and (3) any deposition testimony, conversations, or 33 presentations by Parties or their Counsel that might reveal Protected Material. 44 The protections conferred by this Order do not cover the following 55 information: (a) any information that is in the public domain at the time of 66 disclosure to a Receiving Party or becomes part of the public domain after its 77 disclosure to a Receiving Party as a result of publication not involving a violation 88 of this Order, including becoming part of the public record through trial or 99 otherwise; and (b) any information known to the Receiving Party prior to the 1100 disclosure or obtained by the Receiving Party after the disclosure from a source 1111 who obtained the information lawfully and under no obligation of confidentiality to 1122 the Designating Party. 1133 Any use of Protected Material at trial shall be governed by the orders of the 1144 trial judge. This Order does not govern the use of Protected Material at trial. 1155 5. DURATION 1166 Once a case proceeds to trial, all of the court-filed information that is to be 1177 introduced that was previously designated as confidential or maintained pursuant 1188 to this protective Order becomes public and will be presumptively available to all 1199 members of the public, including the press, unless compelling reasons supported 2200 by specific factual findings to proceed otherwise are made to the trial judge in 2211 advance of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing "good 2222 cause" showing for sealing documents produced in discovery from "compelling 2233 reasons" standard when merits-related documents are part of court record). The 2244 terms of this Order do not extend beyond the commencement of the trial. 2255 6. DESIGNATING PROTECTED MATERIAL 2266 6.1 Exercise of Restraint and Care in Designating Material for 2277 Protection: Each Party or Non-Party that designates information or items for

protection under this Order must take care to limit any such designation to specific 11 material that qualifies under the appropriate standards. The Designating Party must

22 designate for protection only those parts of material, documents, items, or oral or 33 written communications that qualify so that other portions of the material, 44 documents, items, or communications for which protection is not warranted are not 55 swept unjustifiably within the ambit of this Order. Mass, indiscriminate, or 66 routinized designations are prohibited. Designations that are shown to be clearly 77 unjustified or that have been made for an improper purpose (e.g., to unnecessarily 88 encumber the case development process or to impose unnecessary expenses and 99 burdens on other Parties) may expose the Designating Party to sanctions. If it 1100 comes to a Designating Party's attention that information or items that it designated 1111 for protection do not qualify for protection, that Designating party must promptly 1122 notify all other Parties that it is withdrawing the inapplicable designation. 1133 6.2 Manner and Timing of Designations: Except as otherwise 1144 provided in this Order, or as otherwise stipulated or ordered, Disclosure or 1155 Discovery Material that qualifies for protection under this Order must be clearly so 1166 designated before the material is disclosed or produced. 1177 Designation in conformity with this Order requires: 1188 (a) For information in documentary form (e.g., paper or electronic 1199 documents, but excluding transcripts of depositions or other pretrial or trial 2200 proceedings), that the Producing Party affix, at a minimum, the legend 2211 "CONFIDENTIAL" (hereinafter "CONFIDENTIAL legend") or the legend 2222 "ATTORNEYS EYES ONLY" (hereinafter "ATTORNEYS EYES ONLY legend") 2233 to each page that contains protected material. If only a portion of the material on a 2244 page qualifies for protection, the Producing Party also must clearly identify the 2255 protected portion(s) (e.g., by making appropriate markings in the margins). 2266 A Party or Non-Party that makes original documents or materials available 2277 for inspection need not designate them for protection until after the inspecting

Party has indicated which documents or materials it would like copied and 11 produced. During the inspection and before the designation, all of the material

22 made available for inspection shall be deemed "ATTORNEYS EYES ONLY." 33 After the inspecting Party has identified the documents or materials it wants copied 44 and produced, the Producing Party must determine which documents, or portions 55 thereof, qualify for protection under this Order. Then, before producing the 66 specified documents, the Producing Party must affix the "CONFIDENTIAL 77 legend" or the "ATTORNEYS EYES ONLY legend" to each page that contains 88 Protected Material. If only a portion or portions of the material on a page qualifies 99 for protection, the Producing Party also must clearly identify the protected 1100 portion(s) (e.g., by making appropriate markings in the margins). 1111 (b) For testimony given in depositions that the Designating Party identify 1122 the Disclosure or Discovery Material on the record, before the close of the 1133 deposition, hearing, or other proceeding. 1144 (c) For information produced in some form other than documentary and 1155 for any other tangible items, that the Producing Party affix in a prominent place on 1166 the exterior of the container or containers in which the information or item is 1177 stored the "CONFIDENTIAL legend" or the "ATTORNEYS EYES ONLY 1188 legend." If only a portion or portions of the information warrants protection, the 1199 Producing Party, to the extent practicable, shall identify the protected portion(s). 2200 6.3 Inadvertent Failures to Designate: If timely corrected, an 2211 inadvertent failure to designate qualified information or items does not, standing 2222 alone, waive the Designating Party's right to secure protection under this Order for 2233 such material. Upon timely correction of a designation, the Receiving Party must 2244 make reasonable efforts to assure that the material is treated in accordance with the 2255 provisions of this Order. 2266 6.4 Redacting Personal Information: 2277 (a) In addition to and/or in lieu of affixing the "CONFIDENTIAL" legend or

the "ATTORNEYS EYES ONLY" legend to Disclosure or Discovery Material 11 subject to this Order, the Parties reserve the right to redact Personal Information

22 contained in Disclosure or Discovery Material. 33 (b) Information that may be redacted pursuant to this Order includes, but 44 is not limited to, any Party's Personal Information as defined in sub-paragraph 3.14 55 above, and the Personal Information of any Party's family members. 66 (c) Any Party may challenge another Party's redaction of Personal 77 Information in accordance with paragraph 7 below. 88 7. CHALLENGING CONFIDENTIALITY DESIGNATIONS 99 7.1 Timing of Challenges: Any Party may challenge a designation 1100 of confidentiality at any time that is consistent with the Court's Scheduling Order 1111 and any amendments thereto. 1122 7.2 Meet and Confer: The Challenging Party shall initiate the 1133 dispute resolution process under Local Rule 37.1, et seq. Any discovery motion 1144 must strictly comply with the procedures set forth in Local Rules 37-1, 37-2, and 1155 37-3. 1166 7.3 Burden: The burden of persuasion in any such challenge 1177 proceeding shall be on the Designating Party, Frivolous challenges, and those 1188 made for an improper purpose (e.g., to harass or impose unnecessary expenses and 1199 burdens on other Parties) may expose the Challenging Party to sanctions. Unless 2200 the Designating Party has waived or withdrawn the confidentiality designation, all 2211 Parties shall continue to afford the material in question the level of protection to 2222 which it is entitled under the Producing Party's designation until the Court rules on 2233 the challenge. 2244 8. ACCESS TO AND USE OF PROTECTED MATERIAL 2255 8.1 Basic Principles: A Receiving Party may use Protected Material 2266 that is disclosed or produced by another Party or by a Non-Party in connection 2277 with this Action only for prosecuting, defending, or attempting to settle this

Action. Such Protected Material may be disclosed only to the categories of persons 11 and under the conditions described in this Order, When the Action has been

22 terminated, a Receiving Party must comply with the provisions of section 14 below 33 (FINAL DISPOSITION). 44 Protected Material must be stored and maintained by a Receiving 55 Party at a location and in a secure manner that ensures that access is limited to the 66 persons authorized under this Order. 77 8.2 Disclosure of "CONFIDENTIAL" Disclosure or Discovery 88 Material. Unless otherwise ordered by the Court or permitted in writing by the 99 Designating Party, a Receiving Party may disclose any Disclosure or Discovery 1100 Material designated "CONFIDENTIAL" only to: 1111 (a) The Receiving Party's Outside Counsel of Record in this Action, as 1122 well as employees of said Outside Counsel of Record to whom it is reasonably 1133 necessary to disclose the information for this Action; 1144 (b) The officers, directors, and employees (including House Counsel) of 1155 the Receiving Party to whom disclosure is reasonably necessary for this Action; 1166 (c) EXPERTS (as defined in this Order) of the Receiving Party to whom 1177 disclosure is reasonably necessary for this Action and who have signed the 1188 "Acknowledgment and Agreement to Be Bound" (Exhibit A); 1199 (d) The Court and its personnel; 2200 (e) Court reporters and their staff; 2211 (f) Professional jury or trial consultants, mock jurors, and Professional 2222 Vendors to whom disclosure is reasonably necessary for this Action and who have 2233 signed the "Acknowledgement and Agreement to Be Bound" (Exhibit A); 2244 (g) The author or recipient of a document containing the information or a 2255 custodian or other person who otherwise possessed or knew the information; 2266 (h) During their depositions, witnesses and attorneys for witnesses in the 2277 Action to whom disclosure is reasonably necessary provided: (1) the deposing

party requests that the witness sign the form attached as Exhibit 1 hereto; and (2) 11 they will not be permitted to .keep any confidential information unless they sign

22 the "Acknowledgment and Agreement to Be Bound" (Exhibit A), unless otherwise 33 agreed by the Designating Party or ordered by the Court. Pages of transcribed 44 deposition testimony or exhibits to depositions that reveal Protected Material must 55 be separately bound by the court reporter and may not be disclosed to anyone 66 except as permitted under this Order; and 77 (i) Any mediator or settlement officer, and their supporting personnel, 88 mutually agreed upon by any of the Parties engaged in settlement discussions. 99 8.3 Disclosure of "ATTORNEYS EYES ONLY" Disclosure or 1100 Discovery Material. Unless otherwise ordered by the Court or permitted in writing 1111 by the Designating Party, a Receiving Party may disclose any Disclosure or 1122 Discovery Material designated "ATTORNEYS EYES ONLY" only to: 1133 (a) Counsel as defined in sub-paragraph 3.4 above, so long as they do not 1144 share the content of any ATTORNEYS EYES ONLY material with any Party); 1155 and 1166 (b) Anyone identified in the foregoing sub-paragraphs 8.2(c), (d), (e), (g) 1177 and (h). In the event any ATTORNEYS EYES ONLY material is used in a 1188 deposition and/or attached to a deposition transcript as an exhibit, the provisions of 1199 sub-paragraph 8.2(h) above shall apply. 2200 9. PROTECTED MATERIAL SUBPOENAED OR ORDERED 2211 PRODUCED IN OTHER LITIGATION 2222 If a Party is served with a subpoena or a court order issued in other litigation 2233 that compels disclosure of any information or items designated in this Action as 2244 "CONFIDENTIAL" or "ATTORNEYS EYES ONLY," that Party must: 2255 (a) Promptly notify in writing the Designating Party and provide a copy 2266 of the subpoena or court order unless a court order prohibits such notification; 2277 (b) Promptly notify in writing the party who caused the subpoena or order

to issue in the other litigation that some or all of the material covered by the 11 subpoena or order is subject to this Order. Such notification shall include a copy of

22 this Order; and 33 (c) Cooperate with respect to all reasonable procedures sought to be 44 pursued by the Designating Party whose Protected Material may be affected. If the 55 Designating Party timely seeks a protective order, the Party served with the 66 subpoena or court order shall not produce any information designated in this action 77 as "CONFIDENTIAL" or "ATTORNEYS EYES ONLY" before a determination 88 by the court from which the subpoena or order issued, unless the Party has 99 obtained the Designating Party's permission. The Designating Party shall bear the 1100 burden and expense of seeking protection in that court of its confidential material, 1111 and nothing in these provisions should be construed as authorizing or encouraging 1122 a Receiving Party in this Action to disobey a lawful directive from another court. 1133 10. A NON-PARTY'S PROTECTED MATERIAL SOUGHT TO BE 1144 PRODUCED IN THIS LITIGATION 1155 (a) The terms of this Order are applicable to information produced by a 1166 Non-Party in this action and designated as "CONFIDENTIAL" or "ATTORNEYS 1177 EYES ONLY". Such information produced by Non-Parties in connection with this 1188 litigation is protected by the remedies and relief provided by this Order. Nothing in 1199 these provisions should be construed as prohibiting a Non-Party from seeking 2200 additional protections. 2211 (b) In the event that a Party is required, by a valid discovery request, to 2222 produce a Non-Party's confidential information in its possession, and the Party is 2233 subject to an agreement with the Non-Party not to produce the Non-Party's 2244 confidential information, then the Party shall: 2255 (1) Promptly notify in writing the Requesting Party and the Non- 2266 Party that some or all of the information requested is subject to a confidentiality 2277 agreement with a Non-Party;

(2) Promptly provide the Non-Party with a copy of this Order, the 11 relevant discovery request(s), and a reasonably specific description of the

22 information requested; and 33 (3) Make the information requested available for inspection by the 44 Non-Party, if requested. 55 (c) If the Non-Party fails to seek a protective order from this Court within 66 14 days of receiving the notice and accompanying information, the Receiving 77 Party may produce the Non-Party's confidential information responsive to the 88 discovery request. If the Non-Party timely seeks a protective order, the Receiving 99 Party shall not produce any information in its possession or control that is subject 1100 to the confidentiality agreement with the Non-Party before a determination by the 1111 Court. Absent a court order to the contrary, the Non-Party shall bear the burden 1122 and expense of seeking protection in this Court of its Protected Material. 1133 11. UNAUTHORIZED DISCLOSURE OF PROTECTED 1144 MATERIAL 1155 If a Receiving Party learns that, by inadvertence or otherwise, it has 1166 disclosed Protected Material to any person or in any circumstance not authorized 1177 under this Order, the Receiving Party must immediately (a) notify in writing the 1188 Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 1199 all unauthorized copies of the Protected Material, (c) inform the person or persons 2200 to whom unauthorized disclosures were made of all the terms of this Order, and (d) 2211 request such person or persons to execute the "Acknowledgment and Agreement to 2222 Be Bound" that is attached hereto as Exhibit A. 2233 12. INADVERTENT PRODUCTION OF PRIVILEGED OR 2244 OTHERWISE PROTECTED MATERIAL 2255 When a Producing Party gives notice to Receiving Parties that certain 2266 inadvertently produced material is subject to a claim of privilege or other 2277 protection, the obligations of the Receiving Parties are those set forth in Fed. R.

Civ. P. 26(b)(5)(B). This provision is not intended to modify whatever procedure 11 may be established in an e-discovery order that provides for production without

22 prior privilege review. Pursuant to Fed. R. Evid. 502(d) and (e), insofar as the 33 parties reach an agreement on the effect of disclosure of a communication or 44 information covered by the attorney-client privilege or work product protection, 55 the parties may incorporate their agreement in the stipulated protective order 66 submitted to the Court. 77 13. MISCELLANEOUS 88 13.1 Right to Further Relief: Nothing in this Order abridges the right 99 of any person to seek its modification by the Court in the future. 1100 13.2 Right to Assert Other Objections: By stipulating to the entry of 1111 this Order, no Party waives any right it otherwise would have to object to 1122 disclosing or producing any information or item on any ground not addressed in 1133 this Order. Similarly, no Party waives any right to object on any ground to use in 1144 evidence of any of the material covered by this Order. 1155 13.3 Filing Protected Material: A Party that seeks to file under seal 1166 any Protected Material must comply with Civil Local Rule 79-5. Protected 1177 Material may only be filed under seal pursuant to a court order authorizing the 1188 sealing of the specific Protected Material at issue. If a Party's request to file 1199 Protected Material under seal is denied by the Court, then the Receiving Party may 2200 file the information in the public record unless otherwise instructed by the Court. 2211 14. FINAL DISPOSITION 2222 After the final disposition of this action, within 60 days of a written request 2233 by the Designating Party, each Receiving Party must return all Protected Material 2244 to the Producing Party or destroy such material. As used in this subdivision, "all 2255 Protected Material" includes all copies, abstracts, compilations, summaries, and 2266 any other format reproducing or capturing any of the Protected Material. Whether 2277 the Protected Material is returned or destroyed, the Receiving Party must submit a

written certification to the Producing Party (and, if not the same person or entity, to 1 || the Designating Party) by the 60 day deadline that (1) identifies (by category, 2 || where appropriate) all the Protected Material that was returned or destroyed and 3 | (2) affirms that the Receiving Party has not retained any copies, abstracts, 4 | compilations, summaries or any other format reproducing or capturing any of the 5 || Protected Material. Notwithstanding this provision, Counsel are entitled to retain 6 || an archival copy of all pleadings, motion papers, trial, deposition, and hearing 7 || transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 8 || reports, attorney work product, and consultant and expert work product, even if 9 || such materials contain Protected Material, Any such archival copies that contain or 10 || constitute Protected Material remain subject to this Order as set forth in Section 5 11 | (DURATION). 12 13 | FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 14 IS | DATED: August 05, 2019 16 17 18 JOBR 6. fe ited States Magistrate JndGe 19 20 21 22 23 24 25 26 27 28 DN

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22 EXHIBIT A 33 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 44 _______________________________________[print or type full name], of 55 ___________________[print or type full address], declare under penalty of perjury 66 that I have read in its entirety and understand the Stipulated Protective Order that 77 was issued by the United States District Court for the Central District of California 88 on August 5, 2019 in the case of Marisella Macias v. City of Fullerton, et al., Case 99 No. 8:19-cv-01082-DOC (JDEx). I agree to comply with and to be bound by all the 1100 terms this Stipulated Protective Order and I understand and acknowledge that 1111 failure to comply could expose me to sanctions and punishment in the nature of 1122 contempt. I solemnly promise that I will not disclose in any manner any 1133 information or item that is subject to this Stipulated Protective Order to any person 1144 or entity except in strict compliance with the provisions of this Order. 1155 I further agree to submit to the jurisdiction of the United States District 1166 Court for the Central District of California for the purpose of enforcing the terms 1177 of this Stipulated Protective Order, even if such enforcement proceedings occur 1188 after termination of this action. I hereby appoint ____________________ [print or 1199 type full name] of __________________________________________print or type 2200 full address and telephone number] as my California agent for service of process in 2211 connection with this action or any proceedings related to enforcement of this 2222 Stipulated Protective Order. 2233 2244 Date: 2255 City and State where sworn and signed:_____________________________ 2266 Printed name:________________________________________ 2277

Signature:__________________________________