1 SEKI, NISHIMURA & WATASE, PLC

JOSEPH ESPOSITO (SBN 142785)

2 jesposito@snw-law.com 3 JANET L. KEUPER (SBN 128417) jkeuper@snw-law.com 4 600 Wilshire Boulevard, Suite 1250 NOTE: CHANGES MADE BY THE COURT 5 Los Angeles, California 90017 Tel.: (213) 481-2869 | Fax: (213) 481-2871 6

7 Attorneys for Defendants, COUNTY OF LOS ANGELES and DEPUTY JESSE CORONA 8

9 UNITED STATES DISTRICT COURT

10

CENTRAL DISTRICT OF CALIFORNIA

11

12 ENRIQUE GONZALEZ, Case No.: 2:23-cv-04335-GW (JPRx) 13 Plaintiff, (Hon. George H. Wu) 14 15 vs. STIPULATION RE: PROTECTIVE

ORDER

16 COUNTY OF LOS ANGELES, a 17 public entity; DEPUTY CORONA, a Action Filed: June 2, 2023 public employee; DOES 1-10, Trial Date: June 4, 2024 18 19 Defendants.

20

21 Plaintiff ENRIQUE CONZALEZ, and Defendants, COUNTY OF LOS 22 ANGELES, and DEPUTY JESSE CORONA, by and through their respective 23 counsel, hereby stipulate and agree as follows: 24 1. INTRODUCTION 25 1.1 PURPOSES AND LIMITATIONS 26 Discovery in this action is likely to involve production of confidential, 27 proprietary or private information for which special protection from public 28 1 disclosure and from use for any purpose other than prosecuting this litigation may 2 be warranted. 3 Accordingly, the parties hereby stipulate to and petition the Court to enter 4 the following Stipulated Protective Order. The parties acknowledge that this Order 5 does not confer blanket protections on all disclosures or responses to discovery and 6 that the protection it affords from public disclosure and use extends only to the 7 limited information or items that are entitled to confidential treatment under the 8 applicable legal principles. 9 The parties further acknowledge, as set forth in Section 12.3, below, that this 10 Stipulated Protective Order does not automatically entitle them to file confidential 11 information under seal and that Local Civil Rule 79-5 sets forth the procedures that 12 must be followed and the standards that will be applied when a party seeks 13 permission from the Court to file material under seal. The parties agree that this 14 protective order does not waive the parties’ rights to object to discovery demands 15 or requests for documents and/or information. 16 1.2 GOOD CAUSE STATEMENT 17 This civil action arises out of a traffic stop of plaintiff, Enrique Gonzalez 18 initiated by Los Angeles County Sheriff’s Department (“LASD”) Deputy Jesse 19 Corona. The Complaint alleges a date of incident of August 25, 2022 in the City 20 of Maywood, California. 21 This action is likely to involve confidential, proprietary, official, and/or 22 private law enforcement and police personnel information for which special 23 protection from public disclosure and from use for any purpose other than 24 prosecution of this action may be warranted. Such confidential and proprietary 25 materials and information may consist of, among other things, confidential 26 proprietary information/or private personnel police information, regarding 27 confidential contained in police personnel files, official law enforcement 28 investigative information, information otherwise generally unavailable to the 1 public, or which may be privileged or otherwise protected from disclosure under 2 state or federal statutes, court rules, case decisions, or common law. 3 Accordingly, to expedite the flow of information, to facilitate the prompt 4 resolution of disputes over confidentiality of discovery materials, to adequately 5 protect information the parties are entitled to keep confidential, to ensure that the 6 parties are permitted reasonable necessary uses of such material in preparation for 7 and in the conduct of trial, to address their handling at the end of the litigation, and 8 serve the ends of justice, a protective order for such information is justified in this 9 matter. It is the intent of the parties that information will not be designated as 10 confidential for tactical reasons and that nothing be so designated without a good

11 faith belief that it has been maintained in a confidential, 12 2. DEFINITIONS 13 2.1 Action: Enrique Gonzalez v. County of Los Angeles, et al., 2:23-cv- 14 04335-GW (JPRx). 15 2.2 Challenging Party: A Party or Non-Party that challenges the 16 designation of information or items under this Order. 17 2.3 “CONFIDENTIAL” Information or Items: Information (regardless 18 of how it is generated, stored or maintained) or tangible things that a Designating 19 Party believes is entitled to confidential treatment under Federal Rule of Civil 20 Procedure 26(c), and as specified above in the Purposes and Limitations Statement. 21 This also includes (1) any information copied or extracted from the Confidential 22 information; (2) all copies, excerpts, summaries, abstracts or compilations of 23 Confidential information; and (3) any testimony, conversations, or presentations 24 that might reveal Confidential information. 25 2.4 Counsel: Counsel of record for the parties to this civil litigation and 26 their support staff. 27 28 1 2.5 Designating Party: A Party or Non-Party that designates information 2 or 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, 5 regardless of the medium or manner in which it is generated, stored, or maintained 6 (including, among other things, testimony, transcripts, and tangible things), that are 7 produced or generated in disclosures or responses to discovery in this matter. 8 2.7 Expert: A person with specialized knowledge or experience in a 9 matter pertinent to the litigation who has been retained by a Party or its counsel to 10 serve as an expert witness or as a consultant in this Action. 11 2.8 Final Disposition: When this Action has been fully and completely 12 terminated by way of settlement, dismissal, trial and/or appeal. 13 2.9 House Counsel: Attorneys other than Counsel (as defined in 14 paragraph 2.4) and who are employees of a party to this Action. 15 2.10 Non-Party: Any natural person, partnership, corporation, association 16 or other legal entity not named as a Party to this action. 17 2.11 Outside Counsel of Record: Attorneys who are not employees of a 18 party to this Action but are retained to represent or advise a party to this Action 19 and have appeared in this Action on behalf of that party or are affiliated with a law 20 firm that has appeared on behalf of that party, and includes support staff. 21 2.12 Party: Any party to this Action, including all of its officers, directors, 22 boards, departments, divisions, employees, consultants, retained experts, and 23 Outside Counsel of Record (and their support staff). 24 2.13 Producing Party: A Party or Non-Party that produces Disclosure or 25 Discovery Material in this Action. 26 2.14 Professional Vendors: Persons or entities that provide litigation 27 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 28 1 demonstrations, and organizing, storing, or retrieving data in any form or medium) 2 and their employees and subcontractors. 3 2.15 Protected Material: Any Disclosure or Discovery Material that is 4 designated as “CONFIDENTIAL.” 5 2.16 Receiving Party: A Party that receives Disclosure or Discovery 6 Material from a Producing Party. 7 3. SCOPE 8 The protections conferred by this Stipulation and Order cover not only 9 Protected Material (as defined above), but also (1) any information copied or 10 extracted from Protected Material; (2) all copies, excerpts, abstracts, summaries, or 11 compilations of Protected Material; and (3) any deposition testimony, 12 conversations, or presentations by Parties or their Counsel that might reveal 13 Protected Material. 14 Any use of Protected Material at trial shall be governed by the orders of the 15 trial judge. This Order does not govern the use of Protected Material at trial. 16 4. DURATION 17 Once a trial commences in this Action, information that was designated as 18 CONFIDENTIAL or maintained pursuant to this protective order and that is 19 introduced or admitted as an exhibit at trial becomes public and will be 20 presumptively available to all members of the public, including the press, unless 21 compelling reasons supported by specific factual findings to proceed otherwise are 22 made to and found by the trial judge. See Kamakana v. City and County of 23 Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing “good cause” 24 showing for sealing documents produced in discovery from “compelling reasons” 25 standard when merits-related documents are part of court record). Accordingly, the 26 terms of this protective order do not extend beyond the commencement of the trial. 27 28 1 5. DESIGNATING PROTECTED MATERIAL 2 5.1 Exercise of Restraint and Care in Designating Material for 3 Protection. 4 Each Party or Non-Party that designates information or items for protection 5 under this Order must take care to limit any such designation to specific material 6 that qualifies under the appropriate standards. To the extent practicable, the 7 Designating Party must designate for protection only those parts of material, 8 documents, items or oral or written communications that qualify so that other 9 portions of the material, documents, items or communications for which protection 10 is not warranted are not swept unjustifiably within the ambit of this Order. 11 Indiscriminate or routinized designations are prohibited. Designations that 12 are shown to be clearly unjustified or that have been made for an improper purpose 13 (e.g., to unnecessarily encumber the case development process or to impose 14 unnecessary expenses and burdens on other parties) may expose the Designating 15 Party to sanctions. 16 If it comes to a Designating Party’s attention that information or items that it 17 designated for protection do not qualify for protection, that Designating Party 18 must promptly notify all other Parties that it is withdrawing the inapplicable 19 designation. 20 5.2 Manner and Timing of Designations. Except as otherwise 21 provided in this Order (see, e.g., second paragraph of section 5.2(a) below), or as 22 otherwise stipulated or ordered, Disclosure or Discovery Material that qualifies for 23 protection under this Order must be clearly so designated before the material is 24 disclosed or produced. 25 Designation in conformity with this Order requires: 26 (a) for information in documentary form (e.g., paper or electronic 27 documents, but excluding transcripts of depositions or other pretrial or trial 28 proceedings), that the Producing Party affix at a minimum, the legend 1 “CONFIDENTIAL” or words of a similar effect, and that includes the case name 2 and case number (hereinafter “CONFIDENTIAL legend”), to each page that 3 contains protected material. To the extent practicable, if only a portion of the 4 material on a page qualifies for protection, the Producing Party also must clearly 5 identify the protected portion(s) (e.g., by making appropriate markings in the 6 margins). 7 A Party or Non-Party that makes original documents available for inspection 8 need not designate them for protection until after the inspecting Party has indicated 9 which documents it would like copied and produced. During the inspection and 10 before the designation, all of the material made available for inspection shall be 11 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 12 documents it wants copied and produced, the Producing Party must determine 13 which documents, or portions thereof, qualify for protection under this Order. 14 Then, before producing the specified documents, the Producing Party must affix 15 the “CONFIDENTIAL legend” to each page that contains Protected Material. To 16 the extent practicable, if only a portion of the material on a page qualifies for 17 protection, the Producing Party also must clearly identify the protected portion(s) 18 (e.g., by making appropriate markings in the margins): 19 (b) for testimony given in depositions that the Designating Party 20 identifies the Disclosure or Discovery Material on the record, before the close of 21 the deposition all protected testimony. 22 (c) for information produced in some form other than documentary and 23 for any other tangible items, that the Producing Party affix in a prominent place on 24 the exterior of the container or containers in which the information is stored the 25 legend “CONFIDENTIAL.” If only a portion or portions of the information 26 warrants protection, the Producing Party, to the extent practicable, shall identify 27 the protected portion(s). 28 1 5.3 Inadvertent Failures to Designate. If timely corrected, an 2 inadvertent failure to designate qualified information or items does not, standing 3 alone, waive the Designating Party’s right to secure protection under this Order for 4 such material. Upon timely correction of an inadvertent failure to designate, the 5 Receiving Party must make reasonable efforts to assure that the material is treated 6 in accordance with the 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 10 Scheduling Order. 11 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 12 resolution process under Local Rule 37.1 et seq. 13 6.3 The burden of persuasion in any such challenge proceeding shall be 14 on the Designating Party. Frivolous challenges, and those made for an improper 15 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 16 parties) may expose the Challenging Party to sanctions. Unless the Designating 17 Party has waived or withdrawn the confidentiality designation, all parties shall 18 continue to afford the material in question the level of protection to which it is 19 entitled under the Producing Party’s designation until the Court rules on the 20 challenge. 21 7. ACCESS TO AND USE OF PROTECTED MATERIAL 22 7.1 Basic Principles. A Receiving Party may use Protected Material that 23 is disclosed or produced by another Party or by a Non-Party in connection with 24 this Action only for prosecuting, defending or attempting to settle this Action. 25 Such Protected Material may be disclosed only to the categories of persons and 26 under the conditions described in this Order. When the Action has been 27 terminated, a Receiving Party must comply with the provisions of section 13 below 28 (FINAL DISPOSITION). 1 Protected Material must be stored and maintained by a Receiving Party at a 2 location and in a secure manner that ensures that access is limited to the persons 3 authorized under this Order. 4 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 5 otherwise ordered by the court or permitted in writing by the Designating Party, a 6 Receiving Party may disclose any information or item designated 7 “CONFIDENTIAL” only to: 8 (a) the Receiving Party’s Counsel of Record in this Action, as well as 9 employees of said Counsel of Record to whom it is reasonably necessary to 10 disclose the information for this Action; 11 (b) experts (as defined in this Order) of the Receiving Party to whom 12 disclosure is reasonably necessary for this Action and who have signed the 13 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 14 (c) the court and its personnel; 15 (d) court reporters and their staff; 16 (e) professional jury or trial consultants, mock jurors, and Professional 17 Vendors to whom disclosure is reasonably necessary for this Action and who have 18 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 19 (f) the author or recipient of a document containing the information or a 20 custodian or other person who otherwise possessed or knew the information; 21 (g) during their depositions, witnesses, and attorneys for witnesses, in the 22 Action to whom disclosure is reasonably necessary provided: (1) the deposing 23 party requests that the witness sign the form attached as Exhibit “A” hereto; and 24 (2) they will not be permitted to keep any confidential information unless they sign 25 the “Acknowledgment and Agreement to Be Bound” (Exhibit “A”), unless 26 otherwise agreed by the Designating Party or ordered by the court. Pages of 27 transcribed deposition testimony or exhibits to depositions that reveal Protected 28 1 Material may be separately bound by the court reporter and may not be disclosed 2 to anyone except as permitted under this Stipulated Protective Order; 3 (h) any mediator or settlement officer, and their supporting personnel, 4 mutually agreed upon by any of the parties engaged in settlement discussions and 5 who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A) 6 or appointed by the court; and 7 (i) the officers, directors, and employees (including House Counsel) of

8 the Receiving Party to whom disclosure is reasonably necessary for this Action. 9 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 10 PRODUCED IN OTHER LITIGATION 11 If a Party is served with a subpoena or a court order issued in other litigation 12 that compels disclosure of any information or items designated in this Action as 13 “CONFIDENTIAL,” that Party must: 14 (a) promptly notify in writing the Designating Party. Such notification 15 shall include a copy of the subpoena or court order unless prohibited by law; 16 (b) promptly notify in writing the party who caused the subpoena or order 17 to issue in the other litigation that some or all of the material covered by the 18 subpoena or order is subject to this Protective Order. Such notification shall 19 include a copy of this Stipulated Protective Order; and 20 (c) cooperate with respect to all reasonable procedures sought to be 21 pursued by the Designating Party whose Protected Material may be affected. 22 If the Designating Party timely seeks a protective order in the action in 23 which the subpoena or order was issued, the Party served with the subpoena or 24 court order shall not produce any information designated in this action as 25 “CONFIDENTIAL” before a determination by the court from which the subpoena 26 or order issued, unless the Party has obtained the Designating Party’s permission. 27 The Designating Party shall bear the burden and expense of seeking protection in 28 that court of its confidential material – and nothing in these provisions should be 1 construed as authorizing or encouraging a Receiving Party in this action to disobey 2 a lawful directive from another court. 3 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 4 PRODUCED IN THIS LITIGATION 5 (a) The terms of this Order are applicable to information produced by a 6 Non- Party in this Action and designated as “CONFIDENTIAL.” Such information 7 produced by Non-Parties in connection with this litigation is protected by the 8 remedies and relief provided by this Order. Nothing in these provisions should be 9 construed as prohibiting a Non-Party from seeking additional protections. 10 (b) In the event that a Party is required, by a valid discovery request, to 11 produce a Non-Party’s confidential information in its possession, and the Party is 12 subject to an agreement with the Non-Party not to produce the Non-Party’s 13 confidential information, then the Party shall: 14 (1) promptly notify in writing the Requesting Party and the Non- 15 Party that some or all of the information requested is subject to a 16 confidentiality agreement with a Non-Party; 17 (2) promptly provide the Non-Party with a copy of the Stipulated 18 Protective Order in this Action, the relevant discovery request(s), and 19 a reasonably specific description of the information requested; and 20 (3) make the information requested available for inspection by the 21 Non-Party, if requested. 22 (c) If the Non-Party fails to seek a protective order from this court within 23 21 days of receiving the notice and accompanying information, the Receiving 24 Party may produce the Non-Party’s confidential information responsive to the 25 discovery request. 26 If the Non-Party timely seeks a protective order, the Receiving Party shall 27 not produce any information in its possession or control that is subject to the 28 confidentiality agreement with the Non-Party before a determination by the court. 1 Absent a court order to the contrary, the Non-Party shall bear the burden and 2 expense of seeking protection in this court of its Protected Material. 3 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 4 If a Receiving Party learns that, by inadvertence or otherwise, it has 5 disclosed Protected Material to any person or in any circumstance not authorized 6 under this Stipulated Protective Order, the Receiving Party must immediately (a) 7 notify in writing the Designating Party of the unauthorized disclosures, (b) use its 8 best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform 9 the person or persons to whom unauthorized disclosures were made of all the terms 10 of this Order, and (d) request such person or persons to execute the 11 “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit 12 A. 13 11. INADVERTENT PRODUCTION OF PRIVILEGED OR 14 OTHERWISE PROTECTED MATERIAL 15 When a Producing Party gives notice to Receiving Parties that certain 16 inadvertently produced material is subject to a claim of privilege or other 17 protection, the obligations of the Receiving Parties are those set forth in Federal 18 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 19 whatever procedure may be established in an e-discovery order that provides for 20 production without prior privilege review. Pursuant to Federal Rule of Evidence 21 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure 22 of a communication or information covered by the attorney-client privilege or 23 work product protection, the parties may incorporate their agreement in the 24 stipulated protective order submitted to the court if the Court so allows. 25 12. MISCELLANEOUS 26 12.1 Right to Further Relief. Nothing in this Order abridges the right of 27 any person to seek its modification by the Court in the future. 28 1 12.2 Right to Assert Other Objections. By stipulating to the entry of this 2 Protective Order, no Party waives any right it otherwise would have to object to 3 disclosing or producing any information or item on any ground not addressed in 4 this Stipulated Protective Order. Similarly, no Party waives any right to object on 5 any ground to use in evidence of any of the material covered by this Protective 6 Order. 7 12.3 Filing Protected Material. A Party that seeks to file under seal any 8 Protected Material must comply with Local Civil Rule 79-5. Protected Material 9 may only be filed under seal pursuant to a court order authorizing the sealing of the 10 specific Protected Material at issue. If a Party’s request to file Protected Material 11 under seal is denied by the court, then the Receiving Party may file the information 12 in the public record unless otherwise instructed by the court. 13 13. FINAL DISPOSITION 14 After the final disposition of this Action, as defined in paragraphs 2.8 and 4, 15 within 60 days of a written request by the Designating Party, each Receiving Party 16 must return all Protected Material to the Producing Party or destroy such material. 17 As used in this subdivision, “all Protected Material” includes all copies, abstracts, 18 compilations, summaries, and any other format reproducing or capturing any of the 19 Protected Material. Whether the Protected Material is returned or destroyed, the 20 Receiving Party must submit a written certification to the Producing Party (and, if 21 not the same person or entity, to the Designating Party) by the 60 day deadline that 22 (1) identifies (by category, where appropriate) all the Protected Material that was 23 returned or destroyed and (2) affirms that the Receiving Party has not retained any 24 copies, abstracts, compilations, summaries or any other format reproducing or 25 capturing any of the Protected Material. Notwithstanding this provision, Counsel 26 are entitled to retain an archival copy of all pleadings, motion papers, trial, 27 deposition, and hearing transcripts, legal memoranda, correspondence, deposition 28 and trial exhibits, expert reports, attorney work product, and consultant and expert 1 work product, even if such materials contain Protected Material. Any such archival 2 copies that contain or constitute Protected Material remain subject to this 3 Protective Order as set forth in Section 4 (DURATION). 4 14. VIOLATION 5 Any willful violation of this Order may be punished by appropriate 6 measures including, without limitation, contempt proceedings and/or monetary 7 sanctions. 8 9 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 10 11 DATED: May 2, 2024 LAW OFFICES OF GREG W. GARROTTO 12 13 By: /s/ Greg W. Garrotto 14 Greg W. Garrotto, Esq. Attorneys for Plaintiff 15

ENRIQUE GONZALEZ

16 DATED: May 2, 2024 SEKI, NISHIMURA & WATASE, PLC 17

18

19 By: /s JANET L. KEUPER 20 Janet L. Keuper, Esq. Joseph Esposito, Esq. 21 Attorneys for Defendants 22 COUNTY OF LOS ANGELES and

DEPUTY JESSE CORONA

23 24 25

26 27 28

ATTESTATION REGARDING SIGNATURES

3 I, Janet L. Keuper, attest that all signatories listed, and on whose behalf the filing is submitted, concur in the filing’s content and have authorized the filing.

6 By: /s/ JANET L. KEUPER 7 Janet L. Keuper 9 10 Il 1S SO ORDERED. 12 f bf, 7 13 || Dated: 5/2/2024 By: fe 14 HON. JEAN P. ROSENBLUTH 15 UNITED STATES MAGISTRATE JUDGE

16 17 18 19 20 21 22 23 24 25 26 27 28 45

1 EXHIBIT A 2 3 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 4 5 I, ______________________________________[print or type full name], of _________________________________ [print or type full address], declare 6 under penalty of perjury that I have read in its entirety and understand the 7 Stipulated Protective Order that was issued by the United States District Court for 8 the Central District of California on _____________ in the case of Enrique 9 Gonzalez v. County of Los Angeles, et al., United States District Court Case No. 10 2:23-cv-04335-GW (JPRx). I agree to comply with and to be bound by all the 11 terms of this Stipulated Protective Order and I understand and acknowledge that 12 failure to so comply could expose me to sanctions and punishment in the nature of 13 contempt. I solemnly promise that I will not disclose in any manner any 14 information or item that is subject to this Stipulated Protective Order to any person 15 or entity except in strict compliance with the provisions of this Order. 16 I further agree to submit to the jurisdiction of the United States District 17 Court for the Central District of California for the purpose of enforcing the terms 18 of this Stipulated Protective Order, even if such enforcement proceedings occur 19 after termination of this action. 20

21 Date: ______________________________________ 22 City and State where sworn and signed: _________________________________ 23 Printed name: _______________________________ 24 Signature: ________________________________ 25 26 27 28