Case 2:22-cv-05620-MCS-MAA Document 30 Filed 03/10/23 Page 1 of 17 Page ID #:263

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

9 10 11 ANGELINA ATABEKOVA- CASE NO. 2:22-cv-05620-MCS-MAAx 12 MICHAELIDIS, and VARDOUI [Assigned to Hon. Mark C. Scarsi, 1st Cthse, Ctrm. 7C; MICHAELIDOU; both individually Mag. Maria A. Audero, USDC-Roybal, Ctrm. 690] 13 and as successors in interest to 14 Decedent MELKON STIPULATED PROTECTIVE

MICHAELIDIS, ORDER

15 Plaintiff(s), 16 17 v. 18 CITY OF LOS ANGELES, BRYAN MORALES; and DOES 1-10, 19 inclusive, 20 Defendant(s). 21 22 1. PURPOSES AND LIMITATIONS 23 Discovery in this action is likely to involve production of confidential, 24 proprietary, or private information for which special protection from public 25 disclosure and from use for any purpose other than prosecuting this litigation may 26 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 27 enter the following Stipulated Protective Order. The parties acknowledge that this 28 Case 2:22-cv-05620-MCS-MAA Document 30 Filed 03/10/23 Page 2 of 17 Page ID #:264

1 Stipulated Protective Order does not confer blanket protections on all disclosures or 2 responses to discovery and that the protection it affords from public disclosure and 3 use extends only to the limited information or items that are entitled to confidential 4 treatment under the applicable legal principles. The parties further acknowledge, as 5 set forth in Section 13.3 below, that this Stipulated Protective Order does not entitle 6 them to file confidential information under seal; Local Rule 79-5 sets forth the 7 procedures that must be followed and the standards that will be applied when a 8 party seeks permission from the Court to file material under seal. Discovery in this 9 action is likely to involve production of confidential, proprietary, or private 10 information for which special protection from public disclosure and from use for 11 any purpose other than prosecuting this litigation may be warranted. 12 13 2. GOOD CAUSE STATEMENT 14 This action is likely to involve confidential, proprietary, or private 15 information for which special protection from public disclosure and from use for 16 any purpose other than prosecution of this action is warranted. Such confidential 17 and proprietary materials and information consist of, among other things, 18 confidential business or financial information, information regarding confidential 19 business practices, or other confidential information (including information 20 implicating privacy rights of third parties), information otherwise generally 21 unavailable to the public, or which may be privileged or otherwise protected from 22 disclosure under state or federal statutes, court rules, case decisions, or common 23 law. Accordingly, to expedite the flow of information, to facilitate the prompt 24 resolution of disputes over confidentiality of discovery materials, to adequately 25 protect information the parties are entitled to keep confidential, to ensure that the 26 parties are permitted reasonable necessary uses of such material in preparation for 27 and in the conduct of trial, to address their handling at the end of the litigation, and 28 to serve the ends of justice, a protective order for such information is justified in

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1 this matter. It is the intent of the parties that information will not be designated as 2 confidential for tactical reasons and that nothing be so designated without a good 3 faith belief that it has been maintained in a confidential, non-public manner, and 4 there is good cause why it should not be part of the public record of this case. 5 6 3. DEFINITIONS 7 3.1. Action: This pending federal lawsuit.. Angelina Atabekova- 8 Michaelidis, et al. v. City of Los Angeles, et al., Case No. 2:22-cv- 9 05620-MCS-MAAx. 10 3.2. Challenging Party: A Party or Nonparty that challenges the 11 designation of information or items under this Stipulated Protective 12 Order. 13 3.3. “CONFIDENTIAL” Information or Items: Information (regardless of 14 how it is generated, stored or maintained) or tangible things that 15 qualify for protection under Federal Rule of Civil Procedure 26(c), and 16 as specified above in the Good Cause Statement. 17 3.4. Counsel: Outside Counsel of Record and In-House Counsel (as well 18 as their support staff). 19 3.5. Designating Party: A Party or Nonparty that designates information or 20 items that it produces in disclosures or in responses to discovery as 21 “CONFIDENTIAL.” 22 3.6. Disclosure or Discovery Material: All items or information, regardless 23 of the medium or manner in which it is generated, stored, or 24 maintained (including, among other things, testimony, transcripts, and 25 tangible things), that is produced or generated in disclosures or 26 responses to discovery in this matter. 27 3.7. Expert: A person with specialized knowledge or experience in a 28 matter pertinent to the litigation who has been retained by a Party or its

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1 counsel to serve as an expert witness or as a consultant in this Action. 2 3.8. In-House Counsel: Attorneys who are employees of a party to this 3 Action. In-House Counsel does not include Outside Counsel of 4 Record or any other outside counsel. 5 3.9. Nonparty: Any natural person, partnership, corporation, association, 6 or other legal entity not named as a Party to this action. 7 3.10. Outside Counsel of Record: Attorneys who are not employees of a 8 party to this Action but are retained to represent or advise a party to 9 this Action and have appeared in this Action on behalf of that party or 10 are affiliated with a law firm which has appeared on behalf of that 11 party, and includes support staff. 12 3.11. Party: Any party to this Action, including all of its officers, directors, 13 employees, consultants, retained experts, In-House Counsel, and 14 Outside Counsel of Record (and their support staffs). 15 3.12. Producing Party: A Party or Nonparty that produces Disclosure or 16 Discovery Material in this Action. 17 3.13. Professional Vendors: Persons or entities that provide litigation 18 support services (e.g., photocopying, videotaping, translating, 19 preparing exhibits or demonstrations, and organizing, storing, or 20 retrieving data in any form or medium) and their employees and 21 subcontractors. 22 3.14. Protected Material: Any Disclosure or Discovery Material that is 23 designated as “CONFIDENTIAL.” 24 3.15. Receiving Party: A Party that receives Disclosure or Discovery 25 Material from a Producing Party. 26 3.16 Final Disposition: The conclusion of any appellate proceedings, or, if 27 no appeal is taken, when the time for filing of an appeal has run. 28 Except as set forth below, the terms of this protective order apply

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1 through FINAL DISPOSITION of the action. The parties may 2 stipulate that they will be contractually bound by the terms of this 3 agreement beyond FINAL DISPOSITION, but will have to file a 4 separate action for enforcement of the agreement once all proceedings 5 in this case are complete. 6 7 4. SCOPE 8 The protections conferred by this Stipulated Protective Order cover not only 9 Protected Material, but also (1) any information copied or extracted from Protected 10 Material; (2) all copies, excerpts, summaries, or compilations of Protected Material; 11 and (3) any testimony, conversations, or presentations by Parties or their Counsel 12 that might reveal Protected Material. 13 Any use of Protected Material at trial shall be governed by the orders of the 14 trial judge. This Stipulated Protective Order does not govern the use of Protected 15 Material at trial. 16 17 5. DURATION 18 Once a case proceeds to trial, all of the information that was designated as 19 confidential or maintained pursuant to this Stipulated Protective Order becomes 20 public and presumptively will be available to all members of the public, including 21 the press, unless compelling reasons supported by specific factual findings to 22 proceed otherwise are made to the trial judge in advance of the trial. See 23 Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) 24 (distinguishing “good cause” showing for sealing documents produced in discovery 25 from “compelling reasons” standard when merits-related documents are part of 26 court record). Accordingly, the terms of this Stipulated Protective Order do not 27 extend beyond the commencement of the trial. 28 Even after final disposition of this litigation, the confidentiality obligations

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1 imposed by this Stipulated Protective Order shall remain in effect until a 2 Designating Party agrees otherwise in writing or a court order otherwise directs. 3 Final disposition shall be deemed to be the later of (1) dismissal of all claims and 4 defenses in this Action, with or without prejudice; and (2) final judgment herein 5 after the completion and exhaustion of all appeals, rehearings, remands, trials, or 6 reviews of this Action, including the time limits for filing any motions or 7 applications for extension of time pursuant to applicable law. 8 9 6. DESIGNATING PROTECTED MATERIAL 10 6.1. Exercise of Restraint and Care in Designating Material for Protection. 11 Each Party or Nonparty that designates information or items for 12 protection under this Stipulated Protective Order must take care to 13 limit any such designation to specific material that qualifies under the 14 appropriate standards. The Designating Party must designate for 15 protection only those parts of material, documents, items, or oral or 16 written communications that qualify so that other portions of the 17 material, documents, items, or communications for which protection is 18 not warranted are not swept unjustifiably within the ambit of this 19 Stipulated Protective Order. 20 Mass, indiscriminate, or routinized designations are prohibited. 21 Designations that are shown to be clearly unjustified or that have been 22 made for an improper purpose (e.g., to unnecessarily encumber the 23 case development process or to impose unnecessary expenses and 24 burdens on other parties) may expose the Designating Party to 25 sanctions. 26 6.2. Manner and Timing of Designations. 27 Except as otherwise provided in this Stipulated Protective Order 28 (see, e.g., Section 6.2(a)), or as otherwise stipulated or ordered,

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1 Disclosure or Discovery Material that qualifies for protection under 2 this Stipulated Protective Order must be clearly so designated before 3 the material is disclosed or produced. 4 Designation in conformity with this Stipulated Protective Order 5 requires the following: 6 (a) For information in documentary form (e.g., paper or electronic 7 documents, but excluding transcripts of depositions or other 8 pretrial or trial proceedings), that the Producing Party affix at a 9 minimum, the legend “CONFIDENTIAL” to each page that 10 contains protected material. If only a portion or portions of the 11 material on a page qualifies for protection, the Producing Party 12 also must clearly identify the protected portion(s) (e.g., by 13 making appropriate markings in the margins). 14 A Party or Nonparty that makes original documents 15 available for inspection need not designate them for protection 16 until after the inspecting Party has indicated which documents it 17 would like copied and produced. During the inspection and 18 before the designation, all of the material made available for 19 inspection shall be deemed “CONFIDENTIAL.” After the 20 inspecting Party has identified the documents it wants copied 21 and produced, the Producing Party must determine which 22 documents, or portions thereof, qualify for protection under this 23 Stipulated Protective Order. Then, before producing the 24 specified documents, the Producing Party must affix the legend 25 “CONFIDENTIAL” to each page that contains Protected 26 Material. If only a portion or portions of the material on a page 27 qualifies for protection, the Producing Party also must clearly 28 identify the protected portion(s) (e.g., by making appropriate

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1 markings in the margins). 2 (b) For testimony given in depositions, that the Designating Party 3 identify the Disclosure or Discovery Material on the record, 4 before the close of the deposition, all protected testimony. 5 (c) For information produced in nondocumentary form, and for any 6 other tangible items, that the Producing Party affix in a 7 prominent place on the exterior of the container or containers in 8 which the information is stored the legend “CONFIDENTIAL.” 9 If only a portion or portions of the information warrants 10 protection, the Producing Party, to the extent practicable, shall 11 identify the protected portion(s). 12 6.3. Inadvertent Failure to Designate. 13 If timely corrected, an inadvertent failure to designate qualified 14 information or items does not, standing alone, waive the Designating 15 Party’s right to secure protection under this Stipulated Protective Order 16 for such material. Upon timely correction of a designation, the 17 Receiving Party must make reasonable efforts to assure that the 18 material is treated in accordance with the provisions of this Stipulated 19 Protective Order. 20 21 7. CHALLENGING CONFIDENTIALITY DESIGNATIONS 22 7.1. Timing of Challenges. 23 Any Party or Nonparty may challenge a designation of 24 confidentiality at any time that is consistent with the Court’s 25 Scheduling Order. 26 7.2. Meet and Confer. 27 The Challenging Party shall initiate the dispute resolution 28 process, which shall comply with Local Rule 37.1 et seq., and with

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1 Section 4 of Judge Audero’s Procedures (“Mandatory Telephonic 2 Conference for Discovery Disputes”).1 3 7.3. Burden of Persuasion. 4 The burden of persuasion in any such challenge proceeding shall 5 be on the Designating Party. Frivolous challenges, and those made for 6 an improper purpose (e.g., to harass or impose unnecessary expenses 7 and burdens on other parties) may expose the Challenging Party to 8 sanctions. Unless the Designating Party has waived or withdrawn the 9 confidentiality designation, all parties shall continue to afford the 10 material in question the level of protection to which it is entitled under 11 the Producing Party’s designation until the Court rules on the 12 challenge. 13 14 8. ACCESS TO AND USE OF PROTECTED MATERIALS 15 8.1. Basic Principles. 16 A Receiving Party may use Protected Material that is disclosed 17 or produced by another Party or by a Nonparty in connection with this 18 Action only for prosecuting, defending, or attempting to settle this 19 Action. Such Protected Material may be disclosed only to the 20 categories of persons and under the conditions described in this 21 Stipulated Protective Order. When the Action reaches a final 22 disposition, a Receiving Party must comply with the provisions of 23 Section 14 below. 24 Protected Material must be stored and maintained by a 25 Receiving Party at a location and in a secure manner that ensures that 26 27 1 Judge Audero’s Procedures are available at 28 https://www.cacd.uscourts.gov/honorable-maria-audero.

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1 access is limited to the persons authorized under this Stipulated 2 Protective Order. 3 8.2. Disclosure of “CONFIDENTIAL” Information or Items. 4 Unless otherwise ordered by the Court or permitted in writing 5 by the Designating Party, a Receiving Party may disclose any 6 information or item designated “CONFIDENTIAL” only to: 7 (a) The Receiving Party’s Outside Counsel of Record, as well as 8 employees of said Outside Counsel of Record to whom it is 9 reasonably necessary to disclose the information for this Action; 10 (b) The officers, directors, and employees (including In-House 11 Counsel) of the Receiving Party to whom disclosure is 12 reasonably necessary for this Action; 13 (c) Experts of the Receiving Party to whom disclosure is reasonably 14 necessary for this Action and who have signed the 15 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 16 (d) The Court and its personnel; 17 (e) Court reporters and their staff; 18 (f) Professional jury or trial consultants, mock jurors, and 19 Professional Vendors to whom disclosure is reasonably 20 necessary or this Action and who have signed the 21 “Acknowledgment and Agreement to be Bound” (Exhibit A); 22 (g) The author or recipient of a document containing the 23 information or a custodian or other person who otherwise 24 possessed or knew the information; 25 (h) During their depositions, witnesses, and attorneys for witnesses, 26 in the Action to whom disclosure is reasonably necessary 27 provided: (i) the deposing party requests that the witness sign 28 the “Acknowledgment and Agreement to Be Bound” (Exhibit

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

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1 the subpoena or court order shall not produce any information designated in this 2 action as “CONFIDENTIAL” before a determination by the Court from which the 3 subpoena or order issued, unless the Party has obtained the Designating Party’s 4 permission. The Designating Party shall bear the burden and expense of seeking 5 protection in that court of its confidential material and nothing in these provisions 6 should be construed as authorizing or encouraging a Receiving Party in this Action 7 to disobey a lawful directive from another court. 8 9 10. A NONPARTY’S PROTECTED MATERIAL SOUGHT TO BE 10 PRODUCED IN THIS LITIGATION 11 10.1. Application. 12 The terms of this Stipulated Protective Order are applicable to 13 information produced by a Nonparty in this Action and designated as 14 “CONFIDENTIAL.” Such information produced by Nonparties in 15 connection with this litigation is protected by the remedies and relief 16 provided by this Stipulated Protective Order. Nothing in these 17 provisions should be construed as prohibiting a Nonparty from seeking 18 additional protections. 19 10.2. Notification. 20 In the event that a Party is required, by a valid discovery 21 request, to produce a Nonparty’s confidential information in its 22 possession, and the Party is subject to an agreement with the Nonparty 23 not to produce the Nonparty’s confidential information, then the Party 24 shall: 25 (a) Promptly notify in writing the Requesting Party and the 26 Nonparty that some or all of the information requested is subject 27 to a confidentiality agreement with a Nonparty; 28 (b) Promptly provide the Nonparty with a copy of the Stipulated

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1 Protective Order in this Action, the relevant discovery 2 request(s), and a reasonably specific description of the 3 information requested; and 4 (c) Make the information requested available for inspection by the 5 Nonparty, if requested. 6 10.3. Conditions of Production. 7 If the Nonparty fails to seek a protective order from this Court 8 within fourteen (14) days after receiving the notice and accompanying 9 information, the Receiving Party may produce the Nonparty’s 10 confidential information responsive to the discovery request. If the 11 Nonparty timely seeks a protective order, the Receiving Party shall not 12 produce any information in its possession or control that is subject to 13 the confidentiality agreement with the Nonparty before a 14 determination by the Court. Absent a court order to the contrary, the 15 Nonparty shall bear the burden and expense of seeking protection in 16 this Court of its Protected Material. 17 18 11. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 19 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 20 Protected Material to any person or in any circumstance not authorized under this 21 Stipulated Protective Order, the Receiving Party immediately must (1) notify in 22 writing the Designating Party of the unauthorized disclosures, (2) use its best 23 efforts to retrieve all unauthorized copies of the Protected Material, (3) inform the 24 person or persons to whom unauthorized disclosures were made of all the terms of 25 this Stipulated Protective Order, and (4) request such person or persons to execute 26 the “Acknowledgment and Agreement to be Bound” (Exhibit A). 27 28 / / /

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1 12. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 2 PROTECTED MATERIAL 3 When a Producing Party gives notice to Receiving Parties that certain 4 inadvertently produced material is subject to a claim of privilege or other 5 protection, the obligations of the Receiving Parties are those set forth in Federal 6 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 7 whatever procedure may be established in an e-discovery order that provides for 8 production without prior privilege review. Pursuant to Federal Rule of Evidence 9 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure 10 of a communication or information covered by the attorney-client privilege or work 11 product protection, the parties may incorporate their agreement in the Stipulated 12 Protective Order submitted to the Court. 13 14 13. MISCELLANEOUS 15 13.1. Right to Further Relief. 16 Nothing in this Stipulated Protective Order abridges the right of 17 any person to seek its modification by the Court in the future. 18 13.2. Right to Assert Other Objections. 19 By stipulating to the entry of this Stipulated Protective Order, no 20 Party waives any right it otherwise would have to object to disclosing 21 or producing any information or item on any ground not addressed in 22 this Stipulated Protective Order. Similarly, no Party waives any right 23 to object on any ground to use in evidence of any of the material 24 covered by this Stipulated Protective Order. 25 13.3. Filing Protected Material. 26 A Party that seeks to file under seal any Protected Material must 27 comply with Local Rule 79-5. Protected Material may only be filed 28 under seal pursuant to a court order authorizing the sealing of the

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1 specific Protected Material at issue. If a Party's request to file 2 Protected Material under seal is denied by the Court, then the 3 Receiving Party may file the information in the public record unless 4 otherwise instructed by the Court. 5 6 14. FINAL DISPOSITION 7 After the final disposition of this Action pursuant to Section 3.16 above, 8 within sixty (60) days of a written request by the Designating Party, each Receiving 9 Party must return all Protected Material to the Producing Party or destroy such 10 material. As used in this subdivision, “all Protected Material” includes all copies, 11 abstracts, compilations, summaries, and any other format reproducing or capturing 12 any of the Protected Material. Whether the Protected Material is returned or 13 destroyed, the Receiving Party must submit a written certification to the Producing 14 Party (and, if not the same person or entity, to the Designating Party) by the 60-day 15 deadline that (1) identifies (by category, where appropriate) all the Protected 16 Material that was returned or destroyed and (2) affirms that the Receiving Party has 17 not retained any copies, abstracts, compilations, summaries or any other format 18 reproducing or capturing any of the Protected Material. Notwithstanding this 19 provision, Counsel is entitled to retain an archival copy of all pleadings; motion 20 papers; trial, deposition, and hearing transcripts; legal memoranda; correspondence; 21 deposition and trial exhibits; expert reports; attorney work product; and consultant 22 and expert work product, even if such materials contain Protected Material. Any 23 such archival copies that contain or constitute Protected Material remain subject to 24 this Stipulated Protective Order as set forth in Section 5. 25 26 15. VIOLATION 27 Any violation of this Stipulated Order may be punished by any and all 28 appropriate measures including, without limitation, contempt proceedings and/or

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1 monetary sanctions. 2 3 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 4 5 DATED: March 10, 2023 LAW OFFICES OF DALE K. GALIPO 6 MARDIROSIAN & MARDIROSIAN, APC 7 By: 8 Dale K. Galipo, Esq. Marcel F. Sincich, Esq. 9 Margarit K. Mardirosian, Esq. Attorney for Plaintiffs 10 ANGELINA ATABEKOVA- MICHAELIDIS, and VARDOUI 11 MICHAELIDOU 12 DATED: March 10, 2023 13 MICHAEL N. FEUER, City Attorney SCOTT MARCUS, Chief Assistant City Attorney 14 CORY M. BRENTE, Senior Assistant City Attorney 15 TY A. FORD, Deputy City Attorney 16 By: 17 Ty A. Ford, Deputy City Attorney 18 Attorneys for Defendant 19 CITY OF LOS ANGELES 20 DATED: March 10, 2023 MANNING & KASS 21 ELLROD, RAMIREZ, TRESTER LLP 22 By: 23 Eugene P. Ramirez, Esq. Attorneys for Defendant 24 BRYAN MORALES

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

25 26 March 10, 2023 Dated: 27 Maria A. Audero 28 United States Magistrate Judge 16 Case 2:22-cv-05620-MCS-MAA Document 30 Filed 03/10/23 Page 17 of 17 Page ID #:279

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, [full name], of 4 [address], declare under penalty of perjury that I have read in its 5 entirety and understand the Stipulated Protective Order that was issued by the 6 United States District Court for the Central District of California on 7 [date] in the case of Michaelidis, et al. v. City of Los Angeles, et al., Case No. 2:22- 8 cv-05620-MCS-MAAx. 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 10 so comply could expose me to sanctions and punishment in the nature of contempt. 11 I solemnly promise that I will not disclose in any manner any information or item 12 that is subject to this Stipulated Protective Order to any person or entity except in 13 strict compliance with the provisions of this Stipulated Protective Order. 14 I further agree to submit to the jurisdiction of the United States District Court 15 for the Central District of California for the purpose of enforcing the terms of this 16 Stipulated Protective Order, even if such enforcement proceedings occur after 17 termination of this action. I hereby appoint [full name] 18 of [address and telephone number] 19 as my California agent for service of process in connection with this action or any 20 proceedings related to enforcement of this Stipulated Protective Order. 21 22 Signature: 23 Printed Name: 24 Date: 25 City and State Where Sworn and Signed: 26 27 28

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