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1 JILL WILLIAMS – State Bar No. 221793 KIMBERLY MOROSI – State Bar No. 345641 2 CARPENTER, ROTHANS & DUMONT 500 S. Grand Avenue, 19th Floor 3 Los Angeles, CA 90071 (213) 228-0400 / (213) 228-0401 [Fax] 4 jwilliams@crdlaw.com / kmorosi@crdlaw.com 5 Attorneys for Defendants 6 7 8

UNITED STATES DISTRICT COURT

9

CENTRAL DISTRICT OF CALIFORNIA

10 11 MARCO ANTONIO PESCINA, ) Case No.: 8:20-cv-01781-CJC-DFM 12 ) Plaintiff, ) ORDER ON 13 ) v. ) STIPULATED PROTECTIVE 14 ) ORDER

CITY OF SANTA ANA; GERARADO )

15 RAYA; RONALD SANDOVAL; and ) DOES 1-50, et al. ) 16 ) [DISCOVERY DOCUMENT: Defendants. ) REFERRED TO MAGISTRATE 17 ) JUDGE] ) 18 ) ) 19 IT IS SO STIPULATED BY AND BETWEEN Plaintiff MARCO 20 ANTONIO PESCINA, and Defendants CITY OF SANTA ANA, DETECTIVE 21 GERARDO RAYA, and DETECTIVE RONALD SANDOVAL, by and through 22 their respective counsel, as follows: 23 1. A. PURPOSES AND LIMITATIONS 24 Discovery in this action is likely to involve production of confidential, 25 proprietary, or private information for which special protection from public 26 disclosure and from use for any purpose other than prosecuting this litigation may 27 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 28 - 1 -

STIPULATED PROTECTIVE ORDER

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1 enter the following Stipulated Protective Order. The parties acknowledge that this 2 Order does not confer blanket protections on all disclosures or responses to 3 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 6 in Section 12.3, below, that this Stipulated Protective Order does not entitle them 7 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 9 party seeks permission from the court to file material under seal. 10 B. GOOD CAUSE STATEMENT 11 This action is likely to involve proprietary and confidential information for 12 which special protection from public disclosure and from use for any purpose other 13 than prosecution of this action is warranted. Such confidential and proprietary 14 materials and information include those not otherwise generally unavailable to the 15 public, or which may be privileged or otherwise protected from disclosure under 16 state or federal statutes, court rules, case decisions, or common law. Accordingly, 17 to expedite the flow of information, to facilitate the prompt resolution of disputes 18 over confidentiality of discovery materials, to adequately protect information the 19 parties are entitled to keep confidential, to ensure that the parties are permitted 20 reasonably necessary uses of such material in preparation for and in the conduct of 21 trial, to address their handling at the end of the litigation, and serve the ends of 22 justice, a protective order for such information is justified in this matter. It is the 23 intent of the parties that information will not be designated as confidential for 24 tactical reasons and that nothing be so designated without a good faith belief that it 25 has been maintained in a confidential, non-public manner, and there is good cause 26 why it should not be part of the public record of this case. 27 /// 28 /// - 2 -

STIPULATED PROTECTIVE ORDER

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1 2. DEFINITIONS 2 2.1 Action: Marco Antonio Pescina v. City of Santa Ana, et al., 8:20-cv- 3 01781-CJC-DFM. 4 2.2 Challenging Party: A Party or Non-Party that challenges the 5 designation of information or items under this Order. 6 2.3 “CONFIDENTIAL” Information or Items: Information (regardless 7 of how it is generated, stored or maintained) or tangible things that a Designating 8 Party believes is entitled to confidential treatment under Federal Rule of Civil 9 Procedure 26(c), and as specified above in the Good Cause Statement. 10 This also includes (1) any information copied or extracted from the Confidential 11 information; (2) all copies, excerpts, summaries, abstracts or compilations of 12 Confidential information; and (3) any testimony, conversations, or presentations 13 that might reveal Confidential information. 14 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 15 support staff). 16 2.5 Designating Party: A Party or Non-Party that designates information 17 or items that it produces in disclosures or in responses to discovery as 18 “CONFIDENTIAL.” 19 2.6 Disclosure or Discovery Material: All items or information, regardless 20 of the medium or manner in which it is generated, stored, or maintained (including, 21 among other things, testimony, transcripts, and tangible things), that are produced 22 or generated in disclosures or responses to discovery in this matter. 23 2.7 Expert: A person with specialized knowledge or experience in a matter 24 pertinent to the litigation who has been retained by a Party or its counsel to serve 25 as an expert witness or as a consultant in this Action. 26 2.8 House Counsel: Attorneys who are employees of a party to this Action. 27 House Counsel does not include Outside Counsel of Record or any other outside 28 counsel. - 3 -

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1 2.9 Non-Party: Any natural person, partnership, corporation association, or 2 other legal entity not named as a Party to this action. 3 2.10 Outside Counsel of Record: attorneys who are not employees of a party 4 to this Action but are retained to represent or advise a party to this Action and have 5 appeared in this Action on behalf of that party or are affiliated with a law firm 6 which has appeared on behalf of that party and includes support staff. 7 2.11 Party: any party to this Action, including all of its officers, directors, 8 employees, consultants, retained experts, and Outside Counsel of Record (and their 9 support staffs). 10 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 11 Discovery Material in this Action. 12 2.13 Professional Vendors: persons or entities that provide litigation support 13 services (e.g., photocopying, videotaping, translating, preparing exhibits or 14 demonstrations, and organizing, storing, or retrieving data in any form or medium) 15 and their employees and subcontractors. 16 2.14 Protected Material: any Disclosure or Discovery Material that is 17 designated as “CONFIDENTIAL.” 18 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 19 from a Producing Party. 20 3. SCOPE 21 The protections conferred by this Stipulation and Order cover not only 22 Protected Material (as defined above), but also (1) any information copied or 23 extracted from Protected Material; (2) all copies, excerpts, abstracts, summaries, or 24 compilations of Protected Material; and (3) any deposition testimony, 25 conversations, or presentations by Parties or their Counsel that might reveal 26 Protected Material. 27 Any use of Protected Material at trial shall be governed by the orders of the 28 trial judge. This Order does not govern the use of Protected Material at trial. - 4 -

STIPULATED PROTECTIVE ORDER

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1 4. DURATION 2 Once a case proceeds to trial, all of the information that was designated as 3 confidential or maintained pursuant to this protective order becomes public and 4 will be presumptively available to all members of the public, including the press, 5 unless compelling reasons supported by specific factual findings to proceed 6 otherwise are made to the trial judge in advance of the trial. See Kamakana v. City 7 and County of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing 8 “good cause” showing for sealing documents produced in discovery from 9 “compelling reasons” standard when merits-related documents are part of court 10 record). Accordingly, the terms of this protective order do not extend beyond the 11 commencement of the trial. 12 5. DESIGNATED PROTECTED MATERIAL 13 5.1 Exercise of Restraint and Care in Designating Material for Protection. 14 Each Party or Non-Party that designates information or items for protection 15 under this Order must take care to limit any such designation to specific material 16 that qualifies under the appropriate standards. The Designating Party must 17 designate for protection only those parts of material, documents, items or oral or 18 written communications that qualify so that other portions of the material, 19 documents, items or communications for which protection is not warranted are not 20 swept unjustifiably within the ambit of this Order. 21 Mass, indiscriminate or routinized designations are prohibited. Designations 22 that are shown to be clearly unjustified or that have been made for an improper 23 purpose (e.g., to unnecessarily encumber the case development process or to 24 impose unnecessary expenses and burdens on other parties) may expose the 25 Designating Party to sanctions. 26 If it comes to a Designating Party’s attention that information or items that it 27 designated for protection do not qualify for protection, that Designating Party must 28 promptly notify all other Parties that it is withdrawing the inapplicable designation. - 5 -

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1 5.2 Manner and Timing of Designations. 2 Except as otherwise provided in this Order (see, e.g., second paragraph of 3 section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure or 4 Discovery Material that qualifies for protection under this Order must be clearly so 5 designated before the material is disclosed or produced. 6 Designation in conformity with this Order requires: 7 (a) for information in documentary form (e.g., paper or electronic 8 documents, but excluding transcripts of depositions or other pretrial or trial 9 proceedings), that the Producing Party affix at a minimum, the legend 10 “CONFIDENTIAL” or words of a similar effect, and that includes the case name 11 and case number (hereinafter “CONFIDENTIAL legend”), to each page that 12 contains protected material. If only a portion of the material on a page qualifies for 13 protection, the Producing Party also must clearly identify the protected portion(s) 14 (e.g., by making appropriate markings in the margins). 15 A Party or Non-Party that makes original documents available for inspection 16 need not designate them for protection until after the inspecting Party has indicated 17 which documents it would like copied and produced. During the inspection and 18 before the designation, all of the material made available for inspection shall be 19 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 20 documents it wants copied and produced, the Producing Party must determine 21 which documents, or portions thereof, qualify for protection under this Order. 22 Then, before producing the specified documents, the Producing Party must affix 23 the “CONFIDENTIAL legend” to each page that contains Protected Material. If 24 only a portion of the material on a page qualifies for protection, the Producing 25 Party also must clearly identify the protected portion(s) (e.g., by making 26 appropriate markings in the margins). 27 (b) for testimony given in depositions that the Designating Party identifies 28 the Disclosure or Discovery Material on the record, before the close of the - 6 -

STIPULATED PROTECTIVE ORDER

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1 deposition all protected testimony. 2 (c) for information produced in some form other than documentary and for 3 any other tangible items, that the Producing Party affix in a prominent place on the 4 exterior of the container or containers in which the information is stored the legend 5 “CONFIDENTIAL.” If only a portion or portions of the information warrants 6 protection, the Producing Party, to the extent practicable, shall identify the 7 protected portion(s). 8 5.3 Inadvertent Failures to Designate. 9 If timely corrected, an inadvertent failure to designate qualified information 10 or items does not, standing alone, waive the Designating Party’s right to secure 11 protection under this Order for such material. Upon timely correction of an 12 inadvertent failure to designate, the Receiving Party must make reasonable efforts 13 to assure that the material is treated in accordance with the provisions of this 14 Order. 15 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 16 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 17 designation of confidentiality at any time that is consistent with the Court’s 18 Scheduling Order. 19 6.2 Meet and Confer. The Challenging Party shall initiate the information 20 dispute resolution process set forth in the Court’s Procedures and Schedules. 21 6.3 The burden of persuasion in any such challenge proceeding shall be 22 on the Designating Party. Frivolous challenges, and those made for an improper 23 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 24 parties) may expose the Challenging Party to sanctions. Unless the Designating 25 Party has waived or withdrawn the confidentiality designation, all parties shall 26 continue to afford the material in question the level of protection to which it is 27 entitled under the Producing Party’s designation until the Court rules on the 28 challenge. - 7 -

STIPULATED PROTECTIVE ORDER

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1 7. ACCESS TO AND USE OF PROTECTED MATERIAL 2 7.1 Basic Principles. A Receiving Party may use Protected Material that 3 is disclosed or produced by another Party or by a Non-Party in connection with 4 this Action only for prosecuting, defending or attempting to settle this Action. 5 Such Protected Material may be disclosed only to the categories of persons and 6 under the conditions described in this Order. When the Action has been 7 terminated, a Receiving Party must comply with the provisions of section 13 below 8 (FINAL DISPOSITION). 9 Protected Material must be stored and maintained by a Receiving Party at a 10 location and in a secure manner that ensures that access is limited to the persons 11 authorized under this Order. 12 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 13 otherwise ordered by the court or permitted in writing by the Designating Party, a 14 Receiving Party may disclose any information or item designated 15 “CONFIDENTIAL” only to: 16 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 17 as employees of said Outside Counsel of Record to whom it is reasonably 18 necessary to disclose the information for this Action; 19 (b) the officers, directors, and employees (including House Counsel) of the 20 Receiving Party to whom disclosure is reasonably necessary for this Action; 21 (c) Experts (as defined in this Order) of the Receiving Party to whom 22 disclosure is reasonably necessary for this Action and who have signed the 23 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 24 (d) the court and its personnel; 25 (e) court reporters and their staff; 26 (f) professional jury or trial consultants, mock jurors, and Professional 27 Vendors to whom disclosure is reasonably necessary for this Action and who have 28 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); - 8 -

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1 (g) the author or recipient of a document containing the information or a 2 custodian or other person who otherwise possessed or knew the information; 3 (h) during their depositions, witnesses, and attorneys for witnesses, in the 4 Action to whom disclosure is reasonably necessary provided: (1) the deposing 5 party requests that the witness sign the form attached as Exhibit A hereto; and (2) 6 they will not be permitted to keep any confidential information unless they sign the 7 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 8 agreed by the Designating Party or ordered by the court. Pages of transcribed 9 deposition testimony or exhibits to depositions that reveal Protected Material may 10 be separately bound by the court reporter and may not be disclosed to anyone 11 except as permitted under this Stipulated Protective Order; 12 (i) any mediator or settlement officer, and their supporting personnel, 13 mutually agreed upon by any of the parties engaged in settlement discussions. 14 discussions; and 15 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 16 PRODUCED IN OTHER LITIGATION 17 If a Party is served with a subpoena or a court order issued in other litigation 18 that compels disclosure of any information or items designated in this Action as 19 “CONFIDENTIAL,” that Party must: 20 (a) promptly notify in writing the Designating Party. Such notification shall 21 include a copy of the subpoena or court order; 22 (b) promptly notify in writing the party who caused the subpoena or order to 23 issue in the other litigation that some or all of the material covered by the subpoena 24 or order is subject to this Protective Order. Such notification shall include a copy 25 of this Stipulated Protective Order; and 26 (c) cooperate with respect to all reasonable procedures sought to be pursued 27 by the Designating Party whose Protected Material may be affected. If the 28 Designating Party timely seeks a protective order in the action in which the - 9 -

STIPULATED PROTECTIVE ORDER

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1 subpoena or order was issued, the Party served with the subpoena or court order 2 shall not produce any information designated in this action as “CONFIDENTIAL” 3 before a determination by the court from which the subpoena or order issued, 4 unless the Party has obtained the Designating Party’s permission. The Designating 5 Party shall bear the burden and expense of seeking protection in that court of its 6 confidential material – and nothing in these provisions should be construed as 7 authorizing or encouraging a Receiving Party in this action to disobey a lawful 8 directive from another court. 9 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 10 PRODUCED IN THIS LITIGATION 11 (a) The terms of this Order are applicable to information produced by a Non- 12 Party in this Action and designated as “CONFIDENTIAL.” Such information 13 produced by Non-Parties in connection with this litigation is protected by the 14 remedies and relief provided by this Order. Nothing in these provisions should be 15 construed as prohibiting a Non-Party from seeking additional protections. 16 (b) In the event that a Party is required, by a valid discovery request, to 17 produce a Non-Party’s confidential information in its possession, and the Party is 18 subject to an agreement with the Non-Party not to produce the Non-Party’s 19 confidential information, then the Party shall: 20 (1) promptly notify in writing the Requesting Party and the Non-Party that 21 some or all of the information requested is subject to a confidentiality agreement 22 with a Non-Party; 23 (2) promptly provide the Non-Party with a copy of the Stipulated Protective 24 Order in this Action, the relevant discovery request(s), and a reasonably specific 25 description of the information requested; and 26 (3) make the information requested available for inspection by the Non- 27 Party, if requested. 28 (c) If the Non-Party fails to seek a protective order from this court within 14 - 10 -

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1 days of receiving the notice and accompanying information, the Receiving Party 2 may produce the Non-Party’s confidential information responsive to the discovery 3 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 4 not produce any information in its possession or control that is subject to the 5 confidentiality agreement with the Non-Party before a determination by the court. 6 Absent a court order to the contrary, the Non-Party shall bear the burden and 7 expense of seeking protection in this court of its Protected Material. 8 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 9 If a Receiving Party learns that, by inadvertence or otherwise, it has 10 disclosed Protected Material to any person or in any circumstance not authorized 11 under this Stipulated Protective Order, the Receiving Party must immediately (a) 12 notify in writing the Designating Party of the unauthorized disclosures, (b) use its 13 best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform 14 the person or persons to whom unauthorized disclosures were made of all the terms 15 of this Order, and (d) request such person or persons to execute the 16 “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit 17 A. 18 11. INADVERTANT PRODUCTION OF PRIVILEGED OR 19 OTHERWISE PROTECTED MATERIAL 20 When a Producing Party gives notice to Receiving Parties that certain 21 inadvertently produced material is subject to a claim of privilege or other 22 protection, the obligations of the Receiving Parties are those set forth in Federal 23 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 24 whatever procedure may be established in an e-discovery order that provides for 25 production without prior privilege review. Pursuant to Federal Rule of Evidence 26 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure 27 of a communication or information covered by the attorney-client privilege or 28 work product protection, the parties may incorporate their agreement in the - 11 -

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1 stipulated protective order submitted to the court. 2 12. MISCELLANEOUS 3 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 4 person to seek its modification by the Court in the future. 5 12.2 Right to Assert Other Objections. By stipulating to the entry of this 6 Protective Order, no Party waives any right it otherwise would have to object to 7 disclosing or producing any information or item on any ground not addressed in 8 this Stipulated Protective Order. Similarly, no Party waives any right to object on 9 any ground to use in evidence of any of the material covered by this Protective 10 Order. 11 12.3 Filing Protected Material. A Party that seeks to file under seal any 12 Protected Material must comply with Local Civil Rule 79-5. Protected Material 13 may only be filed under seal pursuant to a court order authorizing the sealing of the 14 specific Protected Material at issue. If a Party’s request to file Protected Material 15 under seal is denied by the court, then the Receiving Party may file the information 16 in the public record unless otherwise instructed by the court. 17 13. FINAL DISPOSITION 18 After the final disposition of this Action, as defined in paragraph 4, within 19 60 days of a written request by the Designating Party, each Receiving Party must 20 return all Protected Material to the Producing Party or destroy such material. As 21 used in this subdivision, “all Protected Material” includes all copies, abstracts, 22 compilations, summaries, and any other format reproducing or capturing any of the 23 Protected Material. Whether the Protected Material is returned or destroyed, the 24 Receiving Party must submit a written certification to the Producing Party (and, if 25 not the same person or entity, to the Designating Party) by the 60 day deadline that 26 (1) identifies (by category, where appropriate) all the Protected Material that was 27 returned or destroyed and (2)affirms that the Receiving Party has not retained any 28 copies, abstracts, compilations, summaries or any other format reproducing or - 12 -

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1 || capturing any of the Protected Material. Notwithstanding this provision, Counsel 2 entitled to retain an archival copy of all pleadings, motion papers, trial, 3 || deposition, and hearing transcripts, legal memoranda, correspondence, deposition 4 |/and trial exhibits, expert reports, attorney work product, and consultant and expert 5 || work product, even if such materials contain Protected Material. Any such archival 6 || copies that contain or 28 constitute Protected Material remain subject to this 7 || Protective Order as set forth in Section 4 (DURATION). 8 14. Any violation of this Order may be punished by appropriate measures 9 ||including, without limitation, contempt proceedings and/or monetary sanctions. 10 11 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD. 12 13 || DATED: January 25, 2023 GUIZAR, HENDERSON & CARRAZCO, LLP 14 15 By: _/s/ KentHenderson | Humberto Guizar 16 Kent M. Henderson 17 Angel Carrazco 1g Attorneys for Plaintiff DATED: January 25,2023 =CARPENTER, ROTHANS & DUMONT 19 50 By:__/s/ Jill Wilhams Jill Williams 21 Kimberly Morosi 22 Attorneys for Defendants 23 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 24 Dated: February 27, 2023 25 6 43,2 26 HONORA@LE DOUGLAS F. MCCORMICK 27 UNITED OoTATTIC AAA GSTPATE TTTINGE 28 -13-

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1 EXHIBIT A

2

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3 I__________________________ [print or type full name] of 4 _______________________________________ [print or type full address and 5 telephone number declare under penalty of perjury that I have read in its entirety 6 and understand the Stipulated Protective Order that was issued by the United 7 States District Court for the Central District of California on ________________ 8 in the case of Marco Antonio Pescina v. City of Santa Ana, et al., 8:20-cv-01781- 9 CJC-DFM. I agree to comply with and to be bound by all the terms of this 10 Stipulated Protective Order and I understand and acknowledge that failure to so 11 comply could expose me to sanctions and punishment in the nature of contempt. I 12 solemnly promise that I will not disclose in any manner any information or item 13 that is subject to this Stipulated Protective Order to any person or entity except in 14 strict compliance with the provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District 16 Court for the Central District of California for the purpose of enforcing the terms 17 of this Stipulated Protective Order, even if such enforcement proceedings occur 18 after termination of this action. I hereby appoint __________________________ 19 [print or type full name] of _______________________________________ [print 20 or type full address and telephone number] as my California agent for service of 21 process in connection with this action or any proceedings related to enforcement of 22 this Stipulated Protective Order. 23

24 Date: ______________________________________ 25 City and State where sworn and signed: ________________________________ 26 Printed name: _______________________________ 27 Signature: __________________________________ 28 - 15 -

STIPULATED PROTECTIVE ORDER