1 Thomas C. Hurrell, State Bar No. 119876 E-Mail: thurrell@hurrellcantrall.com 2 Charles Phan, State Bar No. 254371 E-Mail: cphan@hurrellcantrall.com 3 HURRELL CANTRALL LLP 300 South Grand Avenue, Suite 1300 4 Los Angeles, California 90071 Telephone: (213) 426-2000 5 Facsimile: (213) 426-2020

6 Attorneys for Defendants COUNTY OF RIVERSIDE (sued correctly as County of Riverside and also sued incorrectly and served as Riverside County Sheriff’s 7 Department), DEPUTY GORDON MITCHELL, DEPUTY SETH MANNIE, and

DEPUTY JUSTIN TIBBETTS

8

UNITED STATES DISTRICT COURT

9

CENTRAL DISTRICT OF CALIFORNIA, EASTERN DIVISION

10

11 DEMAJAY WILLIAMS, an individual; LEAD CASE NO.: 5:19-cv-00397- 12 D.W., a minor by and through her JGB-SHKx guardian ad litem Desiree Renee 13 Wilson; J.W., a minor by and through Consolidated With Case Nos.: her guardian ad litem Danielle Banks; 5:19-cv-00405-JGB-SHKx 14 and TAMMY JOHNSON WILLIAMS, 5:19−cv-00864-JGB-SHKx an individual, 15 Plaintiffs, Assigned to Hon. Jesus G. Bernal, 16 Courtroom “1” v. 17 Discovery Magistrate: Hon. Shashi H. KOHL’S DEPARTMENT STORES, Kewalramani, Courtroom “3” or “4” 18 INC., a Delaware corporation; KOHL’S ILLINOIS, INC., a Nevada corporation; DISCOVERY MATTER 19 COUNTY OF RIVERSIDE, a California municipal entity; STIPULATED PROTECTIVE 20 RIVERSIDE COUNTY SHERIFF’S ORDER DEPARTMENT, a California 21 municipal entity; DEPUTY GORDON MITCHELL, an individual; DEPUTY Trial Date: 6/02/20 22 JUSTIN TIBBETTS, an individual; and DOES 1-30, inclusive, 23 NOTE: CHANGES MADE BY Defendants. COURT 24 LARISA WASHINGTON; individually 25 and as Successor-in-Interest to THE

ESTATE OF RODERICK D.

26 WILLIAMS, JR.,

27 Plaintiffs, 1

KOHL’S DEPARTMENT STORES,

2 INC.; COUNTY OF RIVERSIDE AND DOES 1-50, inclusive, 3 Defendants. 4

5 AND CONSOLIDATED CASES

6

7 8 1. A. PURPOSES AND LIMITATIONS 9 Discovery in this action is likely to involve production of confidential, 10 proprietary, or private information for which special protection from public 11 disclosure and from use for any purpose other than prosecuting this litigation maybe 12 warranted. Accordingly, the parties hereby stipulate to and petition the Court to 13 enter the following Stipulated Protective Order. The parties acknowledge that this 14 Order does not confer blanket protections on all disclosures or responses to 15 discovery and that the protection it affords from public disclosure and use extends 16 only to the limited information or items that are entitled to confidential treatment 17 under the applicable legal principles. The parties further acknowledge, as set forth in 18 Section 12.3, below, that this Stipulated Protective Order does not entitle them to 19 file confidential information under seal; Civil Local Rule 79-5 sets forth the 20 procedures that must be followed and the standards that will be applied when a party 21 seeks permission from the court to file material under seal 22 B. GOOD CAUSE STATEMENT 23 Plaintiff and defendants may produce certain documents or provide testimony 24 in this case that contain personal medical, employment or financial information. 25 Such information may implicate the privacy interests of the parties and are properly 26 protected through a Fed. R. Civ. P. 26(c) protective order. Seattle Times Co. v. 27 Rhinehart, 467 U.S. 20, 35 n.21 (1984) (“Rule 26(c) includes among its express 1 oppression or undue burden or expense.’ Although the Rule contains no specific 2 reference to privacy or to other rights or interests that may be implicated, such 3 matters are implicit in the broad purpose and language of the Rule.”); Soto v. City of 4 Concord, 162 F.R.D. 603, 617 (N.D. Cal. 1995) (a party’s privacy rights are to be 5 protected through a “carefully crafted protective order.”) 6 This action is also likely to involve the disclosure of documents 7 relating to law enforcement activities and training, which are 8 confidential and proprietary information for which special protection from 9 public disclosure and from use for any purpose other than prosecution of this action 10 is warranted. The materials and information subject to this stipulated protective 11 order are generally unavailable to the public, or which maybe privileged or 12 otherwise protected from disclosure under state or federal statutes, court rules, 13 case decisions, or common law. Accordingly, to expedite the flow of information, 14 to facilitate the prompt resolution of disputes over confidentiality of discovery 15 materials, to adequately protect information the parties are entitled to keep 16 confidential, to ensure that the parties are permitted reasonable necessary uses of 17 such material in preparation for and in the conduct of trial, to address their handling 18 at the end of the litigation, and serve the ends of justice, a protective order for such 19 information is justified in this matter. It is the intent of the parties that information 20 will not be designated as confidential for tactical reasons and that nothing be so 21 designated without a good faith belief that it has been maintained in a confidential, 22 non-public manner, and there is good cause why it should not be part of the public 23 record of this case. 24 2. DEFINITIONS 25 2.1 Action: This pending consolidated federal action. 26 2.2 Challenging Party: a Party or Non-Party that challenges the 27 designation of information or items under this Order. 1 how it is generated, stored or maintained) or tangible things that qualify for 2 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 3 the Good Cause Statement. 4 2.4 Counsel: Outside Counsel of Record and House Counsel (as well 5 as their support staff). 6 2.5 Designating Party: a Party or Non-Party that designates information or 7 items that it produces in disclosures or in responses to discovery as 8 “CONFIDENTIAL.” 9 2.6 Disclosure or Discovery Material: all items or information, regardless 10 of the medium or manner in which it is generated, stored, or maintained (including, 11 among other things, testimony, transcripts, and tangible things), that are produced or 12 generated in disclosures or responses to discovery in this matter. 13 2.7 Expert: a person with specialized knowledge or experience in a matter 14 pertinent to the litigation who has been retained by a Party or its counsel to serve as 15 an expert witness or as a consultant in this Action. 16 2.8 House Counsel: attorneys who are employees of a party to this Action. 17 House Counsel does not include Outside Counsel of Record or any other outside 18 counsel. 19 2.9 Non-Party: any natural person, partnership, corporation, association, or 20 other legal entity not named as a Party to this action. 21 2.10 Outside Counsel of Record: attorneys who are not employees of a 22 party to this Action but are retained to represent or advise a party to this Action and 23 have appeared in this Action on behalf of that party or are affiliated with a law firm 24 which has appeared on behalf of that party, and includes support staff. 25 2.11 Party: any party to this Action, including all of its officers, directors, 26 employees, consultants, retained experts, and Outside Counsel of Record (and their 27 support staffs). 1 Discovery Material in this Action. 2 2.13 Professional Vendors: persons or entities that provide litigation 3 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 4 demonstrations, and organizing, storing, or retrieving data in any form or medium) 5 and their employees and subcontractors. 6 2.14 Protected Material: any Disclosure or Discovery Material that is 7 designated as “CONFIDENTIAL.” 8 2.15 Receiving Party: a Party that receives Disclosure or Discovery 9 Material from a Producing Party. 10 3. SCOPE 11 The protections conferred by this Stipulation and Order cover not only 12 Protected Material (as defined above), but also (1) any information copied or 13 extracted from Protected Material; (2) all copies, excerpts, summaries, or 14 compilations of Protected Material; and (3) any testimony, conversations, or 15 presentations by Parties or their Counsel that might reveal Protected Material. 16 Any use of Protected Material at trial shall be governed by the orders of the 17 trial judge. This Order does not govern the use of Protected Material at trial. 18 4. DURATION 19 20 Once a case proceeds to trial, information that was designated as 21 CONFIDENTIAL or maintained pursuant to this Order used or introduced as an 22 exhibit at trial becomes public and will be presumptively available to all members of 23 the public, including the press, unless compelling reasons supported by specific 24 factual findings to proceed otherwise are made to the trial judge in advance of the 25 trial. See Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1180-81 (9th 26 Cir. 2006) (distinguishing “good cause” showing for sealing documents produced in 27 discovery from “compelling reasons” standard when merits-related documents are 1 commencement of the trial as to the Protected Material used or introduced as an 2 exhibit at trial. 3 Even after final disposition of this litigation, the confidentiality obligations 4 imposed by this Order shall remain in effect until a Designating Party agrees 5 otherwise in writing or a court order otherwise directs. Final disposition shall be 6 deemed to be the later of (1) dismissal of all claims and defenses in this Action, with 7 or without prejudice; and (2) final judgment herein after the completion and 8 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 9 including the time limits for filing any motions or applications for extension of time 10 pursuant to applicable law. 11 5. DESIGNATING PROTECTED MATERIAL 12 5.1 Exercise of Restraint and Care in Designating Material for Protection. 13 Each Party or Non-Party that designates information or items for protection 14 under this Order must take care to limit any such designation to specific material 15 that qualifies under the appropriate standards. The Designating Party must designate 16 for protection only those parts of material, documents, items, testimony or oral 17 or written communications that qualify so that other portions of the material, 18 documents, items, or communications for which protection is not warranted are not 19 swept unjustifiably within the ambit of this Order. 20 Mass, indiscriminate, or routinized designations are prohibited. Designations 21 that are shown to be clearly unjustified or that have been made for an improper 22 purpose (e.g., to unnecessarily encumber the case development process or to impose 23 unnecessary expenses and burdens on other parties) may expose the Designating 24 Party to sanctions. 25 If it comes to a Designating Party’s attention that information or items that it 26 designated for protection do not qualify for protection, that Designating Party must 27 promptly notify all other Parties that it is withdrawing the inapplicable designation. 1 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 2 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 3 under this Order must be clearly so designated before the material is disclosed or 4 produced. 5 Designation in conformity with this Order requires: 6 (a) for information in documentary form (e.g., paper or electronic 7 documents, but excluding transcripts of depositions or other pretrial or trial 8 proceedings), that the Producing Party affix at a minimum, the legend 9 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 10 contains protected material. If only a portion or portions of the material on a page 11 qualifies for protection, the Producing Party also must clearly identify the protected 12 portion(s) (e.g., by making appropriate markings in the margins). 13 A Party or Non-Party that makes original documents available for inspection 14 need not designate them for protection until after the inspecting Party has indicated 15 which documents it would like copied and produced. During the inspection and 16 before the designation, all of the material made available for inspection shall be 17 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 18 documents it wants copied and produced, the Producing Party must determine which 19 documents, or portions thereof, qualify for protection under this Order. Then, before 20 producing the specified documents, the Producing Party must affix the 21 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 22 portion or portions of the material on a page qualifies for protection, the Producing 23 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 24 markings in the margins). 25 (b) for testimony given in depositions that the Designating Party identify the 26 Disclosure or Discovery Material on the record, before the close of the deposition all 27 protected testimony. 1 any other tangible items, that the Producing Party affix in a prominent place on the 2 exterior of the container or containers in which the information is stored the legend 3 “CONFIDENTIAL.” If only a portion or portions of the information warrants 4 protection, the Producing Party, to the extent practicable, shall identify the protected 5 portion(s). 6 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 7 failure to designate qualified information or items does not, standing alone, waive 8 the Designating Party’s right to secure protection under this Order for such material. 9 Upon timely correction of a designation, the Receiving Party must make reasonable 10 efforts to assure that the material is treated in accordance with the provisions of this 11 Order. 12 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 13 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 14 designation of confidentiality at any time that is consistent with the Court’s 15 Scheduling Order. 16 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 17 resolution process under Local Rule 37.1 et seq. 18 6.3 The burden of persuasion in any such challenge proceeding shall be on 19 the Designating Party. Frivolous challenges, and those made for an improper 20 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 21 parties) may expose the Challenging Party to sanctions. Unless the Designating 22 Party has waived or withdrawn the confidentiality designation, all parties shall 23 continue to afford the material in question the level of protection to which it is 24 entitled under the Producing Party’s designation until the Court rules on the 25 challenge. 26 7. ACCESS TO AND USE OF PROTECTED MATERIAL 27 7.1 Basic Principles. A Receiving Party may use Protected Material that is 1 Action only for prosecuting, defending, or attempting to settle this Action. Such 2 Protected Material may be disclosed only to the categories of persons and under the 3 conditions described in this Order. When the Action has been terminated, a 4 Receiving Party must comply with the provisions of section 13 below (FINAL 5 DISPOSITION). 6 Protected Material must be stored and maintained by a Receiving Party at a 7 location and in a secure manner that ensures that access is limited to the persons 8 authorized under this Order. 9 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 10 otherwise ordered by the court or permitted in writing by the Designating Party, a 11 Receiving Party may disclose any information or item designated 12 “CONFIDENTIAL” only to: 13 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 14 as employees of said Outside Counsel of Record to whom it is reasonably necessary 15 to disclose the information for this Action; 16 (b) the officers, directors, and employees (including House Counsel) of 17 the Receiving Party to whom disclosure is reasonably necessary for this Action; 18 (c) Experts (as defined in this Order) of the Receiving Party to whom 19 disclosure is reasonably necessary for this Action and who have signed the 20 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 21 (d) the court and its personnel; 22 (e) court reporters and their staff; 23 (f) professional jury or trial consultants, mock jurors, and Professional 24 Vendors to whom disclosure is reasonably necessary for this Action and who have 25 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 26 (g) the author or recipient of a document containing the information or a 27 custodian or other person who otherwise possessed or knew the information; 1 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 2 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will 3 not be permitted to keep any confidential information unless they sign the 4 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 5 agreed by the Designating Party or ordered by the court. Pages of transcribed 6 deposition testimony or exhibits to depositions that reveal Protected Material maybe 7 separately bound by the court reporter and may not be disclosed to anyone except as 8 permitted under this Stipulated Protective Order; and 9 (i) any mediator or settlement officer, and their supporting personnel, 10 mutually agreed upon by any of the parties engaged in settlement discussions. 11 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 12 IN OTHER LITIGATION 13 If a Party is served with a subpoena or a court order issued in other litigation 14 that compels disclosure of any information or items designated in this Action as 15 “CONFIDENTIAL,” that Party must: 16 (a) promptly notify in writing the Designating Party. Such notification 17 shall include a copy of the subpoena or court order; 18 (b) promptly notify in writing the party who caused the subpoena or order to 19 issue in the other litigation that some or all of the material covered by the subpoena 20 or order is subject to this Protective Order. Such notification shall include a copy of 21 this Stipulated Protective Order; and 22 (c) cooperate with respect to all reasonable procedures sought to be 23 pursued by the Designating Party whose Protected Material may be affected. 24 If the Designating Party timely seeks a protective order, the Party served with 25 the subpoena or court order shall not produce any information designated in this 26 action as “CONFIDENTIAL” before a determination by the court from which the 27 subpoena or order issued, unless the Party has obtained the Designating Party’s 1 protection in that court of its confidential material and nothing in these provisions 2 should be construed as authorizing or encouraging a Receiving Party in this Action 3 to disobey a lawful directive from another court. 4 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 5 PRODUCED IN THIS LITIGATION 6 (a) The terms of this Order are applicable to information produced by a 7 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 8 produced by Non-Parties in connection with this litigation is protected by the 9 remedies and relief provided by this Order. Nothing in these provisions should be 10 construed as prohibiting a Non-Party from seeking additional protections. 11 (b) In the event that a Party is required, by a valid discovery request, to 12 produce a Non-Party’s confidential information in its possession, and the Party is 13 subject to an agreement with the Non-Party not to produce the Non-Party’s 14 confidential information, then the Party shall: 15 (1) promptly notify in writing the Requesting Party and the Non-Party that 16 some or all of the information requested is subject to a confidentiality agreement 17 with a Non-Party; 18 (2) promptly provide the Non-Party with a copy of the Stipulated 19 Protective Order in this Action, the relevant discovery request(s), and a reasonably 20 specific description of the information requested; and 21 (3) make the information requested available for inspection by the Non- 22 Party, if requested. 23 (c) If the Non-Party fails to seek a protective order from this court within 14 24 days of receiving the notice and accompanying information, the Receiving Party 25 may produce the Non-Party’s confidential information responsive to the discovery 26 request. 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 1 Absent a court order to the contrary, the Non-Party shall bear the 2 burden and 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 disclosed 5 Protected Material to any person or in any circumstance not authorized under this 6 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 7 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 8 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 9 persons to whom unauthorized disclosures were made of all the terms of this Order, 10 and (d) request such person or persons to execute the “Acknowledgment and 11 Agreement to Be Bound” that is attached hereto as Exhibit A. 12 11. INADVERTENT PRODUCTION OF PRIVILEGED OR 13 OTHERWISE PROTECTED MATERIAL 14 Pursuant to Fed. R. Civ. P. 26(b)(5)(B) and Fed. R. Evid. 502, the inadvertent 15 production of privileged documents and data pursuant to this Order shall not result 16 in the waiver of any applicable privileges as to those documents and data. Also, the 17 inadvertent production of privileged documents or data under this Order shall not 18 result in the waiver of any applicable privileges as to those documents and data in 19 any other Federal or State proceeding. Any privileged material inadvertently 20 disclosed shall be and remain the property of the Producing Party. 21 (a) If a Producing Party determines that it has produced a document or data 22 to which it wishes to assert a claim of privilege, it shall notify the Receiving Party 23 promptly of its claim. As part of the notification, the Producing Party shall identify, 24 by Bates number(s) if possible, the document(s) or data as to which the Disclosing is 25 asserting a claim of privilege. 26 (b) A Receiving Party shall notify the Producing Party upon identification 27 of any document(s) or data that reasonably appears to be potentially privileged. 1 privilege made by the Producing Party as to the identified document(s) or data. As 2 part of the notification, the Receiving Party shall identify, by Bates Number(s) if 3 possible, the document(s) or data at issue. The Receiving Party shall segregate the 4 specified document(s) or data, as well as any copies thereof, from any other 5 materials, and the Receiving Party shall not use the information in the potentially 6 privileged document(s) or data, except as provided by Fed. R. Civ. P. 26(b)(5)(B), 7 for a period of 14 days after the date on which the Receiving Party notifies the 8 Producing Party. Within that 14-day period, or any other period of time agreed to by 9 the parties, the Producing Party shall determine whether it will assert a claim of 10 privilege as to the identified document(s) or data, and it shall notify the Receiving 11 Party counsel of its determination. 12 (c) Upon receiving notice of a claim of privilege by the Producing Party 13 regarding a produced document or data, the Receiving Party shall segregate, in 14 accordance with Fed. R. Civ. P. 26(b)(5)(B), the specified document or data, as well 15 as any copies thereof, and shall not use the information in the specified document or 16 data, except as provided by Fed. R. Civ. P. 26(b)(5)(B), until after the claim is 17 resolved. If a court upholds — or if the Receiving Party does not challenge — the 18 Producing Party's claim of privilege as to a produced document or data, the 19 Receiving Party shall return or dispose of the specified document or data, as well as 20 any hard or electronic copies thereof. Within five business days of taking such 21 measures, the Receiving Party shall certify that it has complied with the 22 requirements of this paragraph 23 24 This provision is not intended to modify whatever procedure may be 25 established in an e-discovery order that provides for production without prior 26 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 27 parties reach an agreement on the effect of disclosure of a communication or 1 parties may incorporate their agreement in the stipulated protective order submitted 2 to the court. 3 12. MISCELLANEOUS 4 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 5 person to seek its modification by the Court in the future. 6 12.2 Right to Assert Other Objections. By stipulating to the entry of this 7 Protective Order no Party waives any right it otherwise would have to object to 8 disclosing or producing any information or item on any ground not addressed in this 9 Stipulated Protective Order. Similarly, no Party waives any right to object on any 10 ground to use in evidence of any of the material covered by this Protective Order. 11 12.3 Filing Protected Material. A Party that seeks to file under seal any 12 Protected Material must comply with Civil Local 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, the 19 Designating Party will provide notice via written request to the Receiving Party to 20 return all Protected Material to the Producing Party or destroy such material. Within 21 60 days of the written request by the Designating Party, each Receiving Party must 22 return all Protected Material to the Producing Party or destroy such material. As 23 used in this subdivision, “all Protected Material” includes all copies, abstracts, 24 compilations, summaries, and any other format reproducing or capturing any of 25 the Protected Material. Whether the Protected Material is returned or destroyed, the 26 Receiving Party must submit a written certification to the Producing Party (and, if 27 not the same person or entity, to the Designating Party) by the 60 day deadline that 1 returned or destroyed and (2) affirms that the Receiving Party has not retained 2 any copies, abstracts, compilations, summaries or any other format reproducing or 3 capturing any of the Protected Material. Notwithstanding this provision, Counsel 4 are entitled to retain an archival copy of all pleadings, motion papers, trial, 5 deposition, and hearing transcripts, legal memoranda, correspondence, deposition 6 and trial exhibits, expert reports, attorney work product, and consultant and expert 7 work product, even if such materials contain Protected Material. Any such 8 archival copies that contain or constitute Protected Material remain subject to this 9 Protective Order as set forth in Section 4 (DURATION). 10 14. Any violation of this Order may be punished by any and all appropriate 11 measures including, without limitation, contempt proceedings and/or monetary 12 sanctions. 13 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 14 15 DATED: October 23, 2019 HURRELL CANTRALL LLP

16

17 By: /s/ Charles Phan 18

THOMAS C. HURRELL

19 CHARLES PHAN Attorneys for Defendants COUNTY OF 20 RIVERSIDE (sued correctly as County of 21 Riverside and also sued incorrectly and served as Riverside County Sheriff’s 22 Department), DEPUTY GORDON 23 MITCHELL, DEPUTY SETH MANNIE, and DEPUTY JUSTIN TIBBETTS 24

25 26 27 1 DATED: October 23, 2019 MCMURRAY HENRICKS LLP

2

3 By: /s/ Yana G. Henriks 4

YANA G. HENRIKS

5 Attorneys for Plaintiffs DEMAJAY WILLIAMS, DESTINY WILLIAMS, a 6 minor by and through her guardian ad 7 litem Desiree Renee Wilson, JODI WILLIAMS, , a minor by and through her 8 guardian ad litem Danielle Banks, and 9 TAMMY JOHNSON

10 DATED: October 23, 2019 SAMUEL O. OGBOGU INC. A.P.L.C. 11

12

13 By: /s/ Samuel O. Ogbogu 14 SAMUEL O. OGBOGU, ESQ Attorney for Plaintiff, 15 LARISSA WASHINGTON, et al. 16

17 DATED: October 23, 2019 LAW OFFICE OF JILLISA L. O’BRIEN PC 18

19 20 By: /s/ Conor McElroy

JILLISA O’BRIEN

21 CONOR MCELROY 22 Attorneys for Defendant ERICK

VENTURA-IRAHETA

23

24 25 26 27 1||DATED: October 23, 2019 NORTON AND MELNIK 2 3 4 By: _/s/ Geoffrey P. Norton

GEOFFREY P. NORTON

5 Attorney for Defendant JOHN 6 BLAKEMAN 7 g || DATED: October 23, 2019 CHAPMAN, GLUCKSMAN, DEAN, ROEB 9 & BARGER

10 /s/ Arthur Chapman By: 12 ARTHUR CHAPMAN

B DAVID A. WEINBERGER

Attorneys for Defendant KOHL’S 252 14 DEPARTMENT STORES, INC. 15 || FOR GOOD CAUSE SHOWN IT IS ORDERED. 16 DATED: October 25, 2019 18 19 A ps 20 || Honorable Shashi H. Kewalramani 21 || United States Magistrate Judge 22 23 24 25 26 27 28

1 EXHIBIT A: ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 2 I, _____________________________ [print or type full name], of 3 _________________________________ [print or type full address], declare under 4 penalty of perjury that I have read in its entirety and understand the Stipulated 5 Protective Order that was issued by the United States District Court for the Central 6 District of California on __________ [date] in the consolidated cases of Williams, et 7 al. v Kohl’s Department Stores, Inc., Case No. 5:19-cv-00397-JGB-SHKx; Williams, 8 et al. v Kohl’s Department Stores, Inc., Case No. 5:19-cv-00405-JGB-SHKx; and 9 Washington v. Kohl’s Department Stores, Inc., Case No. 5:19−cv-00864-JGB-SHKx. 10 I agree to comply with and to be bound by all the terms of this Stipulated Protective 11 Order and I understand and acknowledge that failure to so comply could expose me 12 to sanctions and punishment in the nature of contempt. I solemnly promise that I will 13 not disclose in any manner any information or item that is subject to this Stipulated 14 Protective Order to any person or entity except in strict compliance with the 15 provisions of this Stipulated Protective Order. I further agree to submit to the 16 jurisdiction of the United States District Court for the Central District of California 17 for enforcing the terms of this Stipulated Protective Order, even if such enforcement 18 proceedings occur after termination of this action. I hereby appoint 19 __________________________ [print or type full name] of 20 __________________________________________ [print or type full address and 21 telephone number] as my California agent for service of process in connection with 22 this action or any proceedings related to enforcement of this Stipulated Protective 23 Order. 24 Date: ______________________________________ 25 City and State where sworn and signed: _________________________________ 26 Printed name: _______________________________ 27 Signature: __________________________________