1 DBraina nS tOolrnmeeyr,, EEssqq.. [[SS..BB.. ##2 19081098697] ] 2 HADSELL STORMER RENICK & DAI LLP 128 N. Fair Oaks Avenue 3 Pasadena, California 91103 Telephone: (626) 585-9600 4 Facsimile: (626) 577-7079 Emails: dstormer@hadsellstormer.com 5 bolney@hadsellstormer.com

6 Attorneys for Plaintiffs 7 [Additional Counsel continued on next page] 8

9

10

UNITED STATES DISTRICT COURT

11 CENTRAL DISTRICT OF CALIFORNIA

12 KARLA GARCIA ARANDA, an Case No.: 19-cv-01770-RGK (RAO) individual; ALFREDO ARANDA, an 13 individual; and Minor Plaintiff B.A., by [Assigned to the Honorable R. Gary and through his Guardian ad Litem, Karla Klausner– Courtroom 850] 14 Garcia Aranda,

15 Plaintiffs, STIPULATED PROTECTIVE ORDER

BETWEEN PLAINTIFFS AND NON-

16 v. PARTY BELL POLICE

DEPARTMENT

17 COUNTY OF LOS ANGELES, a public entity, LOS ANGELES DEPARTMENT 18 OF CHILDREN AND FAMILY Complaint filed: August 15, 2018 SERVICES, a subdivision of the County Discovery Cut-Off: January 2, 2020 19 of Los Angeles; RUBEN JIMENEZ, an Motion Cut-Off: January 16, 2020 individual; MELISSA RAMIREZ, an Trial Date: March 31, 2020 20 individual; LYDIA BUENO, an individual; ALEXANDRA RONCES, an 21 individual; GLADYS ESCOBEDO, an individual; EVITA SALAS, an 22 individual, ANTONIA LOPEZ, an individual; RACHEL SIMONS, an 23 individual; GLORIA MEJIA, an individual; STEPHANIE MORALES, an 24 individual; LAURA LUNA, an individual; SANDRA JIMENEZ, an 25 individual; OFFICER PACHECO, an individual; OFFICER ESPINOZA, an 26 individual, and DOES 1- 10,

27 Defendants.

28 1 [Additional Counsel continued from previous page] 2 Olu K. Orange, Esq. (SBN 213653) 3 o.orange@orangelawoffices.com

ORANGE LAW OFFICES, P.C.

4 3435 Wilshire Boulevard, Suite 2910 Los Angeles, California 90010 5 TEL: (213) 736-9900

FAX: (213) 417-8800

6

7 Rachel Steinback (SBN 310700)

LAW OFFICE OF RACHEL STEINBACK

8 P.O. Box 291253 Los Angeles, CA 90029 9 Telephone: (213) 537-5370 Facsimile: (213) 232-4003 10 Email: steinbacklaw@gmail.com

11 Attorneys for Plaintiffs 12

13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 1. A. PURPOSES AND LIMITATIONS 2 Discovery in this action is likely to involve production of confidential, proprietary 3 or private information for which special protection from public disclosure and from use 4 for any purpose other than prosecuting this litigation may be warranted. Accordingly, the 5 Plaintiffs and non-Party Bell Police Department hereby stipulate to and petition the 6 Court to enter the following Stipulated Protective Order. Plaintiffs and non-Party Bell 7 Police Department acknowledge that this Order does not confer blanket protections on 8 all disclosures or responses to discovery and that the protection it affords from public 9 disclosure and use extends only to the limited information or items that are entitled to 10 confidential treatment under the applicable legal principles. 11 B. GOOD CAUSE STATEMENT 12 This action is likely to involve police reports pertaining to third party witnesses, 13 and SCAR reports (Suspected Child Abuse Reports) filled out by the Bell Police 14 Department to the County of Los Angeles responding to certain of those police reports, 15 for which special protection from public disclosure and from use for any purpose other 16 than prosecution of this action is warranted. Such confidential and proprietary materials 17 and information consist of, among other things, police reports and SCAR reports 18 containing the identity of witnesses and suspected victims, including minors, 19 information implicating privacy rights of third parties and otherwise generally 20 unavailable to the public, or which may be privileged or otherwise protected from 21 disclosure under state or federal statutes, court rules, case decisions, or common law. 22 Accordingly, to expedite the flow of information, to facilitate the prompt resolution of 23 disputes over confidentiality of discovery materials, to adequately protect information 24 the parties are entitled to keep confidential, to ensure that the parties are permitted 25 reasonable necessary uses of such material in preparation for and in the conduct of trial, 26 to address their handling at the end of the litigation, and serve the ends of justice, a 27 protective order for such information is justified in this matter. It is the intent of the 28 Plaintiffs and non-Party Bell Police Department that information will not be designated 1 as confidential for tactical reasons and that nothing be so designated without a good faith 2 belief that it has been maintained in a confidential, non-public manner, and there is good 3 cause why it should not be part of the public record of this case. 4 Plaintiffs are currently meeting and conferring with Defendants regarding a 5 protective order for this case. In the meantime, non-Party Bell Police Department 6 requires a protective order to produce the sensitive information set forth above in 7 response to Plaintiffs' subpoena duces tecum dated August 21, 2019. Production of these 8 documents is necessary for the deposition of a non-party witness scheduled for 9 September 5, 2019. 10 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 11 The parties further acknowledge, as set forth in Section 12.3, below, that this 12 Stipulated Protective Order does not entitle them to file confidential information under 13 seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the 14 standards that will be applied when a party seeks permission from the court to file 15 material under seal. 16 There is a strong presumption that the public has a right of access to judicial 17 proceedings and records in civil cases. In connection with non-dispositive motions, good 18 cause must be shown to support a filing under seal. See Kamakana v. City and County of 19 Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors Corp., 307 F.3d 20 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc., 187 F.R.D. 576, 21 577 (E.D. Wis. 1999) (even stipulated protective orders require good cause showing), 22 and a specific showing of good cause or compelling reasons with proper evidentiary 23 support and legal justification, must be made with respect to Protected Material that a 24 party seeks to file under seal. The parties’ mere designation of Disclosure or Discovery 25 Material as CONFIDENTIAL does not— without the submission of competent evidence 26 by declaration, establishing that the material sought to be filed under seal qualifies as 27 confidential, privileged, or otherwise protectable—constitute good cause. 28 Further, if a party requests sealing related to a dispositive motion or trial, then 1 compelling reasons, not only good cause, for the sealing must be shown, and the relief 2 sought shall be narrowly tailored to serve the specific interest to be protected. See Pintos 3 v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For each item or type 4 of information, document, or thing sought to be filed or introduced under seal in 5 connection with a dispositive motion or trial, the party seeking protection must articulate 6 compelling reasons, supported by specific facts and legal justification, for the requested 7 sealing order. Again, competent evidence supporting the application to file documents 8 under seal must be provided by declaration. 9 Any document that is not confidential, privileged, or otherwise protectable in 10 its entirety will not be filed under seal if the confidential portions can be redacted. 11 If documents can be redacted, then a redacted version for public viewing, omitting 12 only the confidential, privileged, or otherwise protectable portions of the document, 13 shall be filed. Any application that seeks to file documents under seal in their 14 entirety should include an explanation of why redaction is not feasible. 15 2. DEFINITIONS 16 2.1 Action: Karla Garcia Aranda et al. v. County of Los Angeles et al., 19-cv- 17 01770-RGK (RAO) 18 2.2 Challenging Party: a Party or Non-Party that challenges the designation of 19 information or items under this Order. 20 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how it is 21 generated, stored or maintained) or tangible things that qualify for protection under 22 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 23 Statement. 24 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 25 support staff). 26 2.5 Designating Party: a Party or Non-Party that designates information or items 27 that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 28 2.6 Disclosure or Discovery Material: all items or information, regardless of the 1 medium or manner in which it is generated, stored, or maintained (including, among 2 other things, testimony, transcripts, and tangible things), that are produced or generated 3 in disclosures or responses to discovery in this matter. 4 2.7 Expert: a person with specialized knowledge or experience in a matter 5 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 6 expert witness or as a consultant in this Action. 7 2.8 House Counsel: attorneys who are employees of a party to this Action. House 8 Counsel does not include Outside Counsel of Record or any other outside counsel. 9 2.9 Non-Party: any natural person, partnership, corporation, association or other 10 legal entity not named as a Party to this action. 11 2.10 Outside Counsel of Record: attorneys who are not employees of a party to 12 this Action but are retained to represent or advise a party to this Action and have 13 appeared in this Action on behalf of that party or are affiliated with a law firm that has 14 appeared on behalf of that party, and includes support staff. 15 2.11 Party: any party to this Action, including all of its officers, directors, 16 employees, consultants, retained experts, and Outside Counsel of Record (and their 17 support staffs). 18 2.12 Producing Party: a Party or Non-Party that produces Disclosure or Discovery 19 Material in this Action. 20 2.13 Professional Vendors: persons or entities that provide litigation support 21 services (e.g., photocopying, videotaping, translating, preparing exhibits or 22 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 23 their employees and subcontractors. 24 2.14 Protected Material: any Disclosure or Discovery Material that is designated 25 as “CONFIDENTIAL.” 26 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material from 27 a Producing Party. 28 / / / 1 3. SCOPE 2 The protections conferred by this Stipulation and Order cover not only Protected 3 Material (as defined above), but also (1) any information copied or extracted from 4 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 5 Material; and (3) any testimony, conversations, or presentations by Parties or their 6 Counsel that might reveal Protected Material. 7 Any use of Protected Material at trial shall be governed by the orders of the trial 8 judge. This Order does not govern the use of Protected Material at trial. 9 4. DURATION 10 Once a case proceeds to trial, information that was designated as 11 CONFIDENTIAL or maintained pursuant to this protective order used or introduced as 12 an exhibit at trial becomes public and will be presumptively available to all members of 13 the public, including the press, unless compelling reasons supported by specific factual 14 findings to proceed otherwise are made to the trial judge in advance of the trial. See 15 Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” showing for sealing 16 documents produced in discovery from “compelling reasons” standard when merits- 17 related documents are part of court record). Accordingly, the terms of this protective 18 order do not extend beyond the commencement of the trial. 19 5. DESIGNATING PROTECTED MATERIAL 20 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each 21 Party or Non-Party that designates information or items for protection under this Order 22 must take care to limit any such designation to specific material that qualifies under the 23 appropriate standards. The Designating Party must designate for protection only those 24 parts of material, documents, items or oral or written communications that qualify so that 25 other portions of the material, documents, items or communications for which protection 26 is not warranted are not swept unjustifiably within the ambit of this Order. 27 Mass, indiscriminate or routinized designations are prohibited. Designations that 28 are shown to be clearly unjustified or that have been made for an improper purpose (e.g., 1 to unnecessarily encumber the case development process or to impose unnecessary 2 expenses and burdens on other parties) may expose the Designating Party to sanctions. 3 If it comes to a Designating Party’s attention that information or items that it 4 designated for protection do not qualify for protection, that Designating Party must 5 promptly notify all other Parties that it is withdrawing the inapplicable designation. 6 5.2 Manner and Timing of Designations. Except as otherwise provided in this 7 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or 8 ordered, Disclosure or Discovery Material that qualifies for protection under this Order 9 must be clearly so designated before the material is disclosed or produced. 10 Designation in conformity with this Order requires: 11 (a) for information in documentary form (e.g., paper or electronic 12 documents, but excluding transcripts of depositions or other pretrial or trial 13 proceedings), that the Producing Party affix at a minimum, the legend 14 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that contains 15 protected material. If only a portion of the material on a page qualifies for protection, the 16 Producing Party also must clearly identify the protected portion(s) (e.g., by making 17 appropriate markings in the margins). 18 A Party or Non-Party that makes original documents available for inspection need 19 not designate them for protection until after the inspecting Party has indicated which 20 documents it would like copied and produced. During the inspection and before the 21 designation, all of the material made available for inspection shall be deemed 22 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 23 copied and produced, the Producing Party must determine which documents, or portions 24 thereof, qualify for protection under this Order. Then, before producing the specified 25 documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page 26 that contains Protected Material. If only a portion of the material on a page qualifies for 27 protection, the Producing Party also must clearly identify the protected portion(s) (e.g., 28 by making appropriate markings in the margins). 1 (b) for testimony given in depositions that the Designating Party identifies 2 the Disclosure or Discovery Material on the record, before the close of the deposition all 3 protected testimony. 4 (c) for information produced in some form other than documentary and for 5 any other tangible items, that the Producing Party affix in a prominent place on the 6 exterior of the container or containers in which the information is stored the legend 7 “CONFIDENTIAL.” If only a portion or portions of the information warrants protection, 8 the Producing Party, to the extent practicable, shall identify the protected portion(s). 9 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure 10 to designate qualified information or items does not, standing alone, waive the 11 Designating Party’s right to secure protection under this Order for such material. Upon 12 timely correction of a designation, the Receiving Party must make reasonable efforts to 13 assure that the material is treated in accordance with the provisions of this Order. 14 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 15 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation of 16 confidentiality at any time that is consistent with the Court’s Scheduling Order. 17 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution 18 process under Local Rule 37.1 et seq. 19 6.3 The burden of persuasion in any such challenge proceeding shall be on the 20 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., 21 to harass or impose unnecessary expenses and burdens on other parties) may expose the 22 Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn 23 the confidentiality designation, all parties shall continue to afford the material in 24 question the level of protection to which it is entitled under the Producing Party’s 25 designation until the Court rules on the challenge. 26 7. ACCESS TO AND USE OF PROTECTED MATERIAL 27 7.1 Basic Principles. A Receiving Party may use Protected Material that is 28 disclosed or produced by another Party or by a Non-Party in connection with this Action 1 only for prosecuting, defending or attempting to settle this Action. Such Protected 2 Material may be disclosed only to the categories of persons and under the conditions 3 described in this Order. When the Action has been terminated, a Receiving Party must 4 comply with the provisions of section 13 below (FINAL DISPOSITION). 5 Protected Material must be stored and maintained by a Receiving Party at a 6 location and in a secure manner that ensures that access is limited to the persons 7 authorized under this Order. 8 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise 9 ordered by the court or permitted in writing by the Designating Party, a Receiving Party 10 may disclose any information or item designated “CONFIDENTIAL” only to: 11 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 12 as employees of said Outside Counsel of Record to whom it is reasonably necessary to 13 disclose the information for this Action; 14 (b) the Receiving party, including its officers, directors, and employees 15 (including House Counsel) to whom disclosure is reasonably necessary for this Action; 16 (c) Experts (as defined in this Order) of the Receiving Party to whom 17 disclosure is reasonably necessary for this Action and who have signed the 18 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 19 (d) the court and its personnel; 20 (e) court reporters and their staff; 21 (f) professional jury or trial consultants, mock jurors, and Professional 22 Vendors to whom disclosure is reasonably necessary for this Action and who have 23 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 24 (g) the author or recipient of a document containing the information or a 25 custodian or other person who otherwise possessed or knew the information; 26 (h) during their depositions, witnesses, and attorneys for witnesses, in the 27 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 28 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will not 1 be permitted to keep any confidential information unless they sign the 2 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed 3 by the Designating Party or ordered by the court. Pages of transcribed deposition 4 testimony or exhibits to depositions that reveal Protected Material may be separately 5 bound by the court reporter and may not be disclosed to anyone except as permitted 6 under this Stipulated Protective Order; and 7 (i) any mediator or settlement officer, and their supporting personnel, 8 mutually agreed upon by any of the parties engaged in settlement discussions. 9 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 10 IN OTHER LITIGATION 11 If a Party is served with a subpoena or a court order issued in other litigation that 12 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 shall 15 include a copy of the subpoena or court order; 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 include 19 a copy of this Stipulated Protective Order; and 20 (c) cooperate with respect to all reasonable procedures sought to be pursued 21 by the Designating Party whose Protected Material may be affected. If the Designating 22 Party timely seeks a protective order, the Party served with the subpoena or court order 23 shall not produce any information designated in this action as “CONFIDENTIAL” 24 before a determination by the court from which the subpoena or order issued, unless the 25 Party has obtained the Designating Party’s permission. The Designating Party shall bear 26 the burden and expense of seeking protection in that court of its confidential material 27 and nothing in these provisions should be construed as authorizing or encouraging a 28 Receiving Party in this Action to disobey a lawful directive from another court. 1 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED 2 IN THIS LITIGATION 3 (a) The terms of this Order are applicable to information produced by a 4 Non-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 subject 10 to an agreement with the Non-Party not to produce the Non-Party’s confidential 11 information, then the Party shall: 12 (1) promptly notify in writing the Requesting Party and the Non- 13 Party that some or all of the information requested is subject to a confidentiality 14 agreement 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. If 23 the Non-Party timely seeks a protective order, the Receiving Party shall not produce any 24 information in its possession or control that is subject to the confidentiality agreement 25 with the Non-Party before a determination by the court. Absent a court order to the 26 contrary, the Non-Party shall bear the burden and expense of seeking protection in this 27 court of its Protected Material. 28 / / / 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 writing 5 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 6 all unauthorized copies of the Protected Material, (c) inform the person or persons to 7 whom unauthorized disclosures were made of all the terms of this Order, and (d) request 8 such person or persons to execute the “Acknowledgment and Agreement to Be Bound” 9 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, the 14 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 information 19 covered by the attorney-client privilege or work product protection, the parties may 20 incorporate their agreement in the stipulated protective order submitted to the court. 21 12. MISCELLANEOUS 22 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 23 person to seek its modification by the Court in the future. 24 12.2 Right to Assert Other Objections. By stipulating to the entry of this 25 Protective Order, no Party waives any right it otherwise would have to object to 26 disclosing or producing any information or item on any ground not addressed in this 27 Stipulated Protective Order. Similarly, no Party waives any right to object on any ground 28 to use in evidence of any of the material covered by this Protective Order. 1 12.3 Filing Protected Material. A Party that seeks to file under seal any Protected 2 Material must comply with Local Civil Rule 79-5. Protected Material may only be filed 3 under seal pursuant to a court order authorizing the sealing of the specific Protected 4 Material at issue. If a Party’s request to file Protected Material under seal is denied by 5 the court, then the Receiving Party may file the information in the public record unless 6 otherwise instructed by the court. 7 13. FINAL DISPOSITION 8 After the final disposition of this Action, as defined in paragraph 4, within 60 days 9 of a written request by the Designating Party, each Receiving Party must return all 10 Protected Material to the Producing Party or destroy such material. As used in this 11 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 12 summaries, and any other format reproducing or capturing any of the Protected Material. 13 Whether the Protected Material is returned or destroyed, the Receiving Party must 14 submit a written certification to the Producing Party (and, if not the same person or 15 entity, to the Designating Party) by the 60 day deadline that (1) identifies (by category, 16 where appropriate) all the Protected Material that was returned or destroyed and (2) 17 affirms that the Receiving Party has not retained any copies, abstracts, compilations, 18 summaries or any other format reproducing or capturing any of the Protected Material. 19 Notwithstanding this provision, Counsel are entitled to retain an archival copy of all 20 pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda, 21 correspondence, deposition and trial exhibits, expert reports, attorney work product, and 22 consultant and expert work product, even if such materials contain Protected Material. 23 Any such archival copies that contain or constitute Protected Material remain subject to 24 this Protective Order as set forth in Section 4 (DURATION). 25 14. VIOLATION 26 Any violation of this Order may be punished by appropriate measures including, 27 without limitation, contempt proceedings and/or monetary sanctions. 28 / / / Ly /// 2] /// 3 | ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD. 4 | DATED _ 09/03/2019 6 7 /s/ Brian Olney Attorneys for Plaintiff 8 9 9 |DATED: 4/2/19 ) 1] . 12 VA WY. f fofneys for Non-Party BellPolice Department, by and through 13 | its City Attorneys, Aleshire & Wynder, LLP 14 15 16 | FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 17 18 | DATED: September 5, 2019 19 Q O 7 20 t On. 21 | HON. ROZELLA A. OLIVER United States Magistrate Judge 23 24 25 26 27 28

STIPUT ATED PROTECTIVE ORDER -]3-

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, _____________________________ [print or type full name], of 4 _________________ [print or type full address], declare under penalty of perjury 5 that I have read in its entirety and understand the Stipulated Protective Order that 6 was issued by the United States District Court for the Central District of California 7 on [date] in the case of Karla Garcia Aranda et al. v. County of Los Angeles et al., 8 19-cv-01770-RGK (RAO). I agree to comply with and to be bound by all the terms 9 of 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 Order. 14 I further agree to submit to the jurisdiction of the United States District Court for the 15 Central District of California for enforcing the terms of this Stipulated Protective 16 Order, even if such enforcement proceedings occur after termination of this action. 17 I hereby appoint __________________________ [print or type full name] of 18 _______________________________________ [print or type full address and 19 telephone number] as my California agent for service of process in connection with 20 this action or any proceedings related to enforcement of this Stipulated Protective 21 Order. 22 23 Date: ______________________________________ 24 City and State where sworn and signed: _________________________________ 25 26 Printed name: _______________________________ 27 28 Signature: __________________________________