Case 2:21-cv-09509-FWS-MAR Document 39 Filed 11/14/22 Page 1 of 17 Page ID #:307 1 Tomas A. Guterres, Esq. (State Bar No. 152729) Daniel D. Hoffman, Esq. (State Bar No. 296794) 2

COLLINS + COLLINS LLP

3 790 E. Colorado Boulevard, Suite 600 Pasadena, CA 91101 4 (626) 243-1100 – FAX (626) 243-1111 5 Email: tguterres@ccllp.law Email: dhoffman@ccllp.law 6 7 Attorneys for Defendant,

COUNTY OF LOS ANGELES

8 9

UNITED STATES DISTRICT COURT

10

CENTRAL DISTRICT OF CALIFORNIA

11 12

ANDRE OLIVAS, CASE NO. 2:21-CV-9509-FWS-MAR

13 [Assigned to Hon. Fred W. Slaughter, 14 Plaintiffs, Courtroom 10D] 15 vs. STIPULATED PROTECTIVE ORDER 16 COUNTY OF LOS ANGELES, a 17 municipal entity; DEPUTY 18 PASQUALE MASTANTUONO;

DEPUTY OSCAR LOPEZ-POSADA;

19 and DOES 3-10 inclusive, Complaint Filed: 12/08/2021 20 Trial Date: 06/06/2023 Defendants. 21 22 23 TO THE HONORABLE COURT: 24 1. INTRODUCTION 25 1.1 Purpose and Limitations 26 The parties stipulate and petition the Court to enter this Stipulated Protective 27 Order Discovery in this lawsuit because the parties will likely produce confidential, 28 proprietary, or private information that require special protection from public 23671 7 S9 u0 it eE . 6 C 0o 0 lorado Boulevard 1 Pasadena, CA 91101 P Fah xone (( 66 22 66 )) 2 24 43 3- -1 11 10 10 1 STIPULATED PROTECTIVE ORDER Case 2:21-cv-09509-FWS-MAR Document 39 Filed 11/14/22 Page 2 of 17 Page ID #:308 1 disclosure and from use for any purpose other than prosecuting this litigation. The 2 parties acknowledge that this Order does not confer blanket protections on all 3 disclosures or responses to discovery, and that the protection it affords from public 4 disclosure and use extends only to the limited information or items that are entitled to 5 confidential treatment under the applicable legal principles. The parties acknowledge, 6 as set forth in Section 12.3, below, that this Stipulated Protective Order does not entitle 7 them to file confidential information under seal; Civil Local Rule 79-5 sets forth the 8 procedures that must be followed and the standards that will be applied when a party 9 seeks permission from the court to file material under seal. 10 1.2 Good Cause Statement 11 This case arises from a February 18, 2021 traffic stop of Plaintiff ANDRE 12 OLIVAS by Los Angeles County Deputies Pasquale Mastantuono and Oscar Lopez- 13 Posada. The traffic stop was initially peaceful, but tensions between Plaintiff and the 14 Deputies escalated, resulting in the Deputies using force and ultimately arresting 15 Plaintiff. The gravamen of Plaintiff’s complaint is that Defendants’ use of force was 16 unreasonable, tortious, and violated Plaintiff’s constitutional rights. 17 This lawsuit will likely involve materials protected by California Evidence Code 18 section 1040, California Code of Civil Procedure section 129, California Penal Code 19 section 632, the official information privilege or other state or federal statutes, court 20 rules, case decisions, or common law prohibiting dissemination and disclosure. This 21 lawsuit will likely involve other proprietary information concerning police practices 22 and security protocols for which special protection from public disclosure and from 23 use for any purpose other than prosecution of this action is warranted. 24 County of Los Angeles believes a protective order is necessary for the following 25 evidence: (1) surveillance and body camera footage of the parties before, during, and 26 after the arrest that contain sensitive personal information, traffic stop tactics, details 27 of County’s use of force investigation, detention and arrest tactics, and medical 28 treatment of the parties; (2) recordings of telephone calls which may include 23671 7 S9 u0 it eE . 6 C 0o 0 lorado Boulevard 2 Pasadena, CA 91101 P Fah xone (( 66 22 66 )) 2 24 43 3- -1 11 10 10 1 STIPULATED PROTECTIVE ORDER Case 2:21-cv-09509-FWS-MAR Document 39 Filed 11/14/22 Page 3 of 17 Page ID #:309

1 confidential communication with attorneys, medical professionals, and clergy; (3) 2 personnel and administrative records of peace officers; (4) mental health and medical 3 records protected by HIPPA; (5) photographs the arrest scene and the parties; and (6) 4 other evidence for which should be limited for use in this action only. 5 Without waiving the ability to challenge designated protected materials, the 6 parties believe a protective order in this lawsuit for sensitive information is justified to 7 expedite the flow of information, to facilitate the prompt resolution of disputes over 8 confidentiality of discovery materials, to adequately protect information the parties are 9 entitled to keep confidential, to ensure that the parties are permitted reasonable 10 necessary uses of such material in preparation for and in the conduct of trial, to address 11 their handling at the end of the litigation, and serve to the ends of justice. The parties 12 do not intend to designate evidence as confidential for tactical reasons. The parties 13 intend to designate evidence with a good faith belief that it has been maintained in a 14 confidential, non-public manner, and there is good cause why it should not be part of 15 the public record of this case. 16 2. DEFINITIONS 17 2.1 Action: Andre Olivas v. County of Los Angeles, et al. 18 2.2 Challenging Party: a Party or Non-Party that challenges the designation 19 of information or items under this Order. 20 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 21 how it is generated, stored or maintained) or tangible things that qualify for protection 22 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 23 Statement. [Note: any request for a two-tiered, attorney-eyes-only protective 24 order that designates certain material as “Highly Confidential” will require a 25 separate and detailed showing of need.] 26 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 27 support staff). 28 /// 23671 7 S9 u0 it eE . 6 C 0o 0 lorado Boulevard 3 Pasadena, CA 91101 P Fah xone (( 66 22 66 )) 2 24 43 3- -1 11 10 10 1 STIPULATED PROTECTIVE ORDER Case 2:21-cv-09509-FWS-MAR Document 39 Filed 11/14/22 Page 4 of 17 Page ID #:310

1 2.5 Designating Party: a Party or Non-Party that designates information or 2 items that it produces in disclosures or in responses to discovery as 3 “CONFIDENTIAL.” 4 2.6 Disclosure or Discovery Material: all items or information, regardless of 5 the medium or manner in which it is generated, stored, or maintained (including, 6 among other things, testimony, transcripts, and tangible things), that are produced or 7 generated in disclosures or responses to discovery in this matter. 8 2.7 Expert: a person with specialized knowledge or experience in a matter 9 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 10 expert witness or as a consultant in this Action. 11 2.8 House Counsel: attorneys who are employees of a party to this Action. 12 House Counsel does not include Outside Counsel of Record or any other outside 13 counsel. 14 2.9 Non-Party: any natural person, partnership, corporation, association, or 15 other legal entity not named as a Party to this action. 16 2.10 Outside Counsel of Record: attorneys who are not employees of a party 17 to this Action but are retained to represent or advise a party to this Action and have 18 appeared in this Action on behalf of that party or are affiliated with a law firm which 19 has appeared on behalf of that party, and includes support staff. 20 2.11 Party: any party to this Action, including all of its officers, directors, 21 employees, consultants, retained experts, and Outside Counsel of Record (and their 22 support staffs). 23 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 24 Discovery Material in this Action. 25 2.13 Professional Vendors: persons or entities that provide litigation support 26 services (e.g., photocopying, videotaping, translating, preparing exhibits or 27 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 28 their employees and subcontractors. 23671 7 S9 u0 it eE . 6 C 0o 0 lorado Boulevard 4 Pasadena, CA 91101 P Fah xone (( 66 22 66 )) 2 24 43 3- -1 11 10 10 1 STIPULATED PROTECTIVE ORDER Case 2:21-cv-09509-FWS-MAR Document 39 Filed 11/14/22 Page 5 of 17 Page ID #:311

1 2.14 Protected Material: any Disclosure or Discovery Material that is 2 designated as “CONFIDENTIAL.” 3 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 4 from a Producing Party. 5 3. SCOPE 6 The protections conferred by this Stipulation and Order cover not only Protected 7 Material (as defined above), but also: (1) any information copied or extracted from 8 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 9 Material; and (3) any testimony, conversations, or presentations by Parties or their 10 Counsel that might reveal Protected Material. 11 Any use of Protected Material at trial will be governed by the orders of the trial 12 judge. This Order does not govern the use of Protected Material at trial. The mere 13 existence of this stipulation and Order is not a basis to preclude the admission of any 14 protected materials as evidence at the time of trial. 15 4. DURATION 16 4.1 Except for information specified in 4.2, the confidentiality obligations 17 imposed by this Order will remain in effect until a Designating Party agrees otherwise 18 in writing or a court order otherwise directs. Final disposition will be deemed to be 19 the later of: (1) dismissal of all claims and defenses in this Action, with or without 20 prejudice; and (2) final judgment herein after the completion and exhaustion of all 21 appeals, rehearings, remands, trials, or reviews of this Action, including the time limits 22 for filing any motions or applications for extension of time pursuant to applicable law. 23 4.2 If the case proceeds to trial, information designated as CONFIDENTIAL 24 under this protective order that is authorized for use at trial by stipulation, order or is 25 otherwise admitted as an exhibit will become public and will be presumptively 26 available to all members of the public, including the press, unless compelling reasons 27 supported by specific factual findings to proceed otherwise are made to the trial judge 28 in advance of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good 23671 7 S9 u0 it eE . 6 C 0o 0 lorado Boulevard 5 Pasadena, CA 91101 P Fah xone (( 66 22 66 )) 2 24 43 3- -1 11 10 10 1 STIPULATED PROTECTIVE ORDER Case 2:21-cv-09509-FWS-MAR Document 39 Filed 11/14/22 Page 6 of 17 Page ID #:312

1 cause” showing for sealing documents produced in discovery from “compelling 2 reasons” standard when merits-related documents are part of court record). 3 5. DESIGNATING PROTECTED MATERIAL 4 5.1 Exercise of Restraint and Care in Designating Material for Protection. 5 Each Party or Non-Party that designates information or items for protection 6 under this Order must take care to limit any such designation to specific material that 7 qualifies under the appropriate standards. The Designating Party must designate for 8 protection only those parts of material, documents, items, or oral or written 9 communications that qualify so that other portions of the material, documents, items, 10 or communications for which protection is not warranted are not swept unjustifiably 11 within the ambit of this Order. 12 Mass, indiscriminate, or routinized designations are prohibited. Designations 13 that are shown to be clearly unjustified or that have been made for an improper purpose 14 (e.g., to unnecessarily encumber the case development process or to impose 15 unnecessary expenses and burdens on other parties) may expose the Designating Party 16 to sanctions. 17 If it comes to a Designating Party’s attention that information or items that it 18 designated for protection do not qualify for protection, that Designating Party must 19 promptly notify all other Parties that it is withdrawing the inapplicable designation. 20 5.2 Manner and Timing of Designations. Except as otherwise provided in 21 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 22 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 23 under this Order must be clearly so designated before the material is disclosed or 24 produced. 25 Designation in conformity with this Order requires: 26 a) for information in documentary form (e.g., paper or electronic documents, 27 but excluding transcripts of depositions or other pretrial or trial proceedings), that the 28 Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 23671 7 S9 u0 it eE . 6 C 0o 0 lorado Boulevard 6 Pasadena, CA 91101 P Fah xone (( 66 22 66 )) 2 24 43 3- -1 11 10 10 1 STIPULATED PROTECTIVE ORDER Case 2:21-cv-09509-FWS-MAR Document 39 Filed 11/14/22 Page 7 of 17 Page ID #:313

1 “CONFIDENTIAL legend”), to each page that contains protected material. If only a 2 portion or portions of the material on a page qualifies for protection, the Producing 3 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 4 markings in the margins). 5 A Party or Non-Party that makes original documents available for inspection 6 need not designate them for protection until after the inspecting Party has indicated 7 which documents it would like copied and produced. During the inspection and before 8 the designation, all of the material made available for inspection will be deemed 9 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 10 copied and produced, the Producing Party must determine which documents, or 11 portions thereof, qualify for protection under this Order. Then, before producing the 12 specified documents, the Producing Party must affix the “CONFIDENTIAL legend” 13 to each page that contains Protected Material. If only a portion or portions of the 14 material on a page qualifies for protection, the Producing Party also must clearly 15 identify the protected portion(s) (e.g., by making appropriate markings in the margins). 16 b) for testimony given in depositions that the Designating Party identify the 17 Disclosure or Discovery Material on the record, before the close of the deposition all 18 protected testimony. 19 c) for information produced in some form other than documentary and for 20 any other tangible items, that the Producing Party affix in a prominent place on the 21 exterior of the container or containers in which the information is stored the legend 22 “CONFIDENTIAL.” If only a portion or portions of the information warrants 23 protection, the Producing Party, to the extent practicable, will identify the protected 24 portion(s). 25 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 26 failure to designate qualified information or items does not, standing alone, waive the 27 Designating Party’s right to secure protection under this Order for such material. Upon 28 timely correction of a designation, the Receiving Party must make reasonable efforts 23671 7 S9 u0 it eE . 6 C 0o 0 lorado Boulevard 7 Pasadena, CA 91101 P Fah xone (( 66 22 66 )) 2 24 43 3- -1 11 10 10 1 STIPULATED PROTECTIVE ORDER Case 2:21-cv-09509-FWS-MAR Document 39 Filed 11/14/22 Page 8 of 17 Page ID #:314

1 to assure that the material is treated in accordance with the provisions of this Order. 2 5.4 Independent Source The protections conferred by this Stipulation and 3 Order shall not apply to materials which have been lawfully obtained by the Receiving 4 party through means independent of discovery in this case even if the Designating 5 Party later designates the same materials as CONFIDENTIAL in accordance with the 6 provisions of this Order. 7 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 8 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 9 designation of confidentiality at any time that is consistent with the Court’s Scheduling 10 Order. 11 6.2 Meet and Confer. The Challenging Party will initiate the dispute 12 resolution process (and, if necessary, file a discovery motion) under Local Rule 37.1 13 et seq. 14 6.3 The burden of persuasion in any such challenge proceeding will be on the 15 Designating Party. Frivolous challenges, and those made for an improper purpose 16 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 17 expose the Challenging Party to sanctions. Unless the Designating Party has waived 18 or withdrawn the confidentiality designation, all parties will continue to afford the 19 material in question the level of protection to which it is entitled under the Producing 20 Party’s designation until the Court rules on the challenge. 21 7. ACCESS TO AND USE OF PROTECTED MATERIAL 22 7.1 Basic Principles. A Receiving Party may use Protected Material that is 23 disclosed or produced by another Party or by a Non-Party in connection with this 24 Action only for prosecuting, defending, or attempting to settle this Action. Such 25 Protected Material may be disclosed only to the categories of persons and under the 26 conditions described in this Order. When the Action has been terminated, a Receiving 27 Party must comply with the provisions of section 13 below (FINAL DISPOSITION). 28 Protected Material must be stored and maintained by a Receiving Party at a location 23671 7 S9 u0 it eE . 6 C 0o 0 lorado Boulevard 8 Pasadena, CA 91101 P Fah xone (( 66 22 66 )) 2 24 43 3- -1 11 10 10 1 STIPULATED PROTECTIVE ORDER Case 2:21-cv-09509-FWS-MAR Document 39 Filed 11/14/22 Page 9 of 17 Page ID #:315

1 and in a secure manner that ensures that access is limited to the persons authorized 2 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 “CONFIDENTIAL” 6 only to: 7 a) the Receiving Party’s Outside Counsel of Record in this Action, as well 8 as employees of said Outside Counsel of Record to whom it is reasonably necessary to 9 disclose the information for this Action; 10 b) the officers, directors, and employees (including House Counsel) of the 11 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 or agreed to 14 the “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 A hereto; and (2) they will 25 not be permitted to keep any confidential information unless they sign the 26 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed 27 by the Designating Party or ordered by the court. Pages of transcribed deposition 28 testimony or exhibits to depositions that reveal Protected Material may be separately 23671 7 S9 u0 it eE . 6 C 0o 0 lorado Boulevard 9 Pasadena, CA 91101 P Fah xone (( 66 22 66 )) 2 24 43 3- -1 11 10 10 1 STIPULATED PROTECTIVE ORDER Case 2:21-cv-09509-FWS-MAR Document 39 Filed 11/14/22 Page 10 of 17 Page ID #:316

1 bound by the court reporter and may not be disclosed to anyone except as permitted 2 under this Stipulated Protective Order; and 3 i) any mediator or settlement officer, and their supporting personnel, 4 mutually agreed upon by any of the parties engaged in settlement discussions. 5 j) during trial preparations, witnesses, and attorneys for witnesses, in the 6 Action to whom disclosure is reasonably necessary provided: (1) the appropriate party 7 requests that the witness sign the form attached as Exhibit A hereto 8 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 9 IN OTHER LITIGATION 10 If a Party is served with a subpoena or a court order issued in other litigation that 11 compels disclosure of any information or items designated in this Action as 12 “CONFIDENTIAL,” that Party must: 13 a) promptly notify in writing the Designating Party. Such notification will 14 include a copy of the subpoena or court order; 15 b) promptly notify in writing the party who caused the subpoena or order to 16 issue in the other litigation that some or all of the material covered by the subpoena or 17 order is subject to this Protective Order. Such notification will include a copy of this 18 Stipulated Protective Order; and 19 c) cooperate with respect to all reasonable procedures sought to be pursued 20 by the Designating Party whose Protected Material may be affected. 21 If the Designating Party timely seeks a protective order, the Party served with 22 the subpoena or court order will not produce any information designated in this action 23 as “CONFIDENTIAL” before a determination by the court from which the subpoena 24 or order issued, unless the Party has obtained the Designating Party’s permission. The 25 Designating Party will bear the burden and expense of seeking protection in that court 26 of its confidential material and nothing in these provisions should be construed as 27 authorizing or encouraging a Receiving Party in this Action to disobey a lawful 28 directive from another court. 23671 7 S9 u0 it eE . 6 C 0o 0 lorado Boulevard 10 Pasadena, CA 91101 P Fah xone (( 66 22 66 )) 2 24 43 3- -1 11 10 10 1 STIPULATED PROTECTIVE ORDER Case 2:21-cv-09509-FWS-MAR Document 39 Filed 11/14/22 Page 11 of 17 Page ID #:317

1 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 2 PRODUCED IN THIS LITIGATION 3 a) The terms of this Order are applicable to information produced by a Non- 4 Party in this Action and designated as “CONFIDENTIAL.” Such information 5 produced by Non-Parties in connection with this litigation is protected by the remedies 6 and relief provided by this Order. Nothing in these provisions should be construed as 7 prohibiting a Non-Party from seeking additional protections. 8 b) In the event that a Party is required, by a valid discovery request, to 9 produce a Non-Party’s confidential information in its possession, and the Party is 10 subject to an agreement with the Non-Party not to produce the Non-Party’s confidential 11 information, then the Party will: 12 1) promptly notify in writing the Requesting Party and the Non-Party 13 that some or all of the information requested is subject to a confidentiality agreement 14 with a Non-Party; 15 2) promptly provide the Non-Party with a copy of the Stipulated 16 Protective Order in this Action, the relevant discovery request(s), and a reasonably 17 specific description of the information requested; and 18 3) make the information requested available for inspection by the 19 Non-Party, if requested. 20 c) If the Non-Party fails to seek a protective order from this court within 14 21 days of receiving the notice and accompanying information, the Receiving Party may 22 produce the Non-Party’s confidential information responsive to the discovery request. 23 If the Non-Party timely seeks a protective order, the Receiving Party will not produce 24 any information in its possession or control that is subject to the confidentiality 25 agreement with the Non-Party before a determination by the court. Absent a court 26 order to the contrary, the Non-Party will bear the burden and expense of seeking 27 protection in this court of its Protected Material. 28 /// 23671 7 S9 u0 it eE . 6 C 0o 0 lorado Boulevard 11 Pasadena, CA 91101 P Fah xone (( 66 22 66 )) 2 24 43 3- -1 11 10 10 1 STIPULATED PROTECTIVE ORDER Case 2:21-cv-09509-FWS-MAR Document 39 Filed 11/14/22 Page 12 of 17 Page ID #:318

1 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 2 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 3 Protected Material to any person or in any circumstance not authorized under this 4 Stipulated Protective Order, the Receiving Party must immediately: (a) notify in 5 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts to 6 retrieve all unauthorized copies of the Protected Material, (c) inform the person or 7 persons to whom unauthorized disclosures were made of all the terms of this Order, 8 and (d) request such person or persons to execute the “Acknowledgment and 9 Agreement to Be Bound” that is attached hereto as Exhibit A. 10 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 11 PROTECTED MATERIAL 12 When a Producing Party gives notice to Receiving Parties that certain 13 inadvertently produced material is subject to a claim of privilege or other protection, 14 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 15 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 16 may be established in an e-discovery order that provides for production without prior 17 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 18 parties reach an agreement on the effect of disclosure of a communication or 19 information covered by the attorney-client privilege or work product protection, the 20 parties may incorporate their agreement in the stipulated protective order submitted to 21 the court. 22 12. MISCELLANEOUS 23 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 24 person to seek its modification by the Court in the future. 25 12.2 Right to Assert Other Objections. By stipulating to the entry of this 26 Protective Order no Party waives any right it otherwise would have to object to 27 disclosing or producing any information or item on any ground not addressed in this 28 Stipulated Protective Order. Similarly, no Party waives any right to object on any 23671 7 S9 u0 it eE . 6 C 0o 0 lorado Boulevard 12 Pasadena, CA 91101 P Fah xone (( 66 22 66 )) 2 24 43 3- -1 11 10 10 1 STIPULATED PROTECTIVE ORDER Case 2:21-cv-09509-FWS-MAR Document 39 Filed 11/14/22 Page 13 of 17 Page ID #:319

1 ground to use in evidence of any of the material covered by this Protective Order. 2 12.3 Filing Protected Material. A Party that seeks to file under seal any 3 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 4 only be filed under seal pursuant to a court order authorizing the sealing of the specific 5 Protected Material at issue. If a Party's request to file Protected Material under seal is 6 denied by the court, then the Receiving Party may file the information in the public 7 record unless otherwise instructed by the court. 8 13. FINAL DISPOSITION 9 After the final disposition of this Action, as defined in paragraph 4, within 60 10 days of a written request by the Designating Party, each Receiving Party must return 11 all Protected Material to the Producing Party or destroy such material. As used in this 12 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 13 summaries, and any other format reproducing or capturing any of the Protected 14 Material. Whether the Protected Material is returned or destroyed, the Receiving Party 15 must submit a written certification to the Producing Party (and, if not the same person 16 or entity, to the Designating Party) by the 60 day deadline that: (1) identifies (by 17 category, where appropriate) all the Protected Material that was returned or destroyed; 18 and (2) affirms that the Receiving Party has not retained any copies, abstracts, 19 compilations, summaries or any other format reproducing or capturing any of the 20 Protected Material. Notwithstanding this provision, Counsel are entitled to retain an 21 archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, 22 legal memoranda, correspondence, deposition and trial exhibits, expert reports, 23 attorney work product, and consultant and expert work product, even if such materials 24 contain Protected Material. Any such archival copies that contain or constitute 25 Protected Material remain subject to this Protective Order as set forth in Section 4. 26 /// 27 /// 28 /// 23671 7 S9 u0 it eE . 6 C 0o 0 lorado Boulevard 13 Pasadena, CA 91101 P Fah xone (( 66 22 66 )) 2 24 43 3- -1 11 10 10 1 STIPULATED PROTECTIVE ORDER Case □□□□□□□□□□□□□□□□□□□□□ Document 39 Filed 11/14/22 Page 14of17 Page 1ID#:320

1 14. VIOLATIONS 2 Any willful violation of this Order may be punished by civil or criminal 3 |/contempt proceedings, financial or evidentiary sanctions, reference to disciplinary 4 || authorities, or other appropriate action at the discretion of the Court. 5 |/ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD. 7 IIDATED: 10/31/2022 /s/ Ryann Hall 8 Attorneys for Plaintiff

10 || DATED: October 28, 2022 f in u Attomeys for Del¥ndant 12 13 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 14 15 16 || DATED:November 14, 2022 oO Pr 17 HON. MARGO A. ROCCONI United States Magistrate Judge 18 19 20 21 22 23 24 25 26 27 28 Gera” || 23671 Pasadena, CA 91101 14 Fax fe26} 248-111 _s SFIPULATED PROTECTIVEORDER————C

Case 2:21-cv-09509-FWS-MAR Document 39 Filed 11/14/22 Page 15 of 17 Page ID #:321 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 I, _____________________________ [full name], of _________________ 5 [full address], declare under penalty of perjury that I have read in its entirety and 6 understand the Stipulated Protective Order that was issued by the United States District 7 Court for the Central District of California on [date] in the case of ___________ [insert 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 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] of _______________________________________ [full address and 18 telephone number] as my California agent for service of process in connection with 19 this action or any proceedings related to enforcement of this Stipulated Protective 20 Order. 21 Date: ______________________________________ 22 City and State where signed: _________________________________ 23 Printed name: _______________________________ 24 Signature: __________________________________ 25 26 27 28 23671 7 S9 u0 it eE . 6 C 0o 0 lorado Boulevard 15 Pasadena, CA 91101 P Fah xone (( 66 22 66 )) 2 24 43 3- -1 11 10 10 1 STIPULATED PROTECTIVE ORDER Case 2:21-cv-09509-FWS-MAR Document 39 Filed 11/14/22 Page 16o0f17 Page ID #:322

PROOF OF SERVICE

(CCP §§ 1013(a) and 2015.5; FRCP State of California, ) ) ss. County of Los Angeles. ) Iam employed in the County of Los Angeles. I am over the age of 18 and not a party to the within action. My business address is 790 E. Colorado Boulevard, Suite 600, Pasadena, California 91101. On this date, I served the foregoing document described as STIPULATED PROTECTIVE ORDER on the interested parties in this action by placing same in a sealed envelope, addressed as follows:

SEE ATTACHED SERVICE LIST

L] (BY MAIL) - I caused such envelope(s) with postage thereon fully prepaid to be placed in the United States mail in Pasadena, California to be served on the parties as indicated on the attached service list. I am “readily familiar” with the firm’s practice of collection and processing correspondence for mailing. Under that practice, it would be deposited with the U.S. Postal Service on that same day with postage thereon fully prepaid at Pasadena, California in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after date of deposit for mailing in affidavit. L] (BY CERTIFIED MAIL) — | caused such envelope(s) with postage thereon fully prepaid via Certified Mail Return Receipt Requested to be placed in the United States Mail in Pasadena, California. [] FEDERAL EXPRESS - I caused the envelope to be delivered to an authorized courier or driver authorized to receive documents with delivery fees provided for, XX (BY ELECTRONIC FILING AND/OR SERVICE) — | served a true copy, with all exhibits, electronically on designated recipients listed on the attached service list L] (ELECTRONIC SERVICE PER CODE CIV, PROC., § 1010.6) — By prior consent or request or as required by rules of court (Code Civ. Proc., § 1010.6 (amended Jan. 1, 2021); Code Civ. Proc., § 1013(g); Cal. Rules of Court, rule 2.251(a)). L] (BY PERSONAL SERVICE) - I caused such envelope(s) to be delivered by hand to the office(s) of the addressee(s). Executed on November 1, 2022 at Pasadena, California. L] (STATE) - I declare under penalty of perjury under the laws of the State of California that the above is true and correct. (FEDERAL) - I declare that I am employed in the office of a member of the bar of this court at whose direction the service was made.

Amy ot anarber@ccllp.law

Case 2:21-cv-09509-FWS-MAR Document 39 Filed 11/14/22 Page 17 of 17 Page ID #:323

ANDRE OLIVAS VS. COUNTY OF LOS ANGELES ET AL.

USDC Case Number: 2:21-CV-9509-FWS CCLLP File Number: 23671

SERVICE LIST

V. James DeSimone

Ryann E. Hall

V. JAMES DESIMONE LAW

13160 Mindanao Way, Suite 280 Marina del Rey, California 90292 Telephone: 310.693.5561 - Facsimile: 323.544.6880 vjdesimone@gmail.com rhall@bohmlaw.com VJD000106@bohmlaw.com

ATTORNEYS FOR PLAINTIFF, ANDRE OLIVAS