Pedram Esfandiary, Esq. (SBN: 312569) 1 pesfandiary@baumhedlundlaw.com 2 Monique A. Alarcon, Esq. (SBN: 311650) malarcon@baumhedlundlaw.com 3 Timothy A. Loranger, Esq. (SBN: 225422) 4 tloranger@baumhedlundlaw.com 5 Ronald M. Goldman, Esq. (SBN: 33422) rgoldman@baumhedlundlaw.com 6

BAUM HEDLUND ARISTEI & GOLDMAN, P.C.

7 10940 Wilshire Blvd., 17th Floor Los Angeles, CA 90024 8 Telephone: (310) 207-3233 9 Attorneys for Plaintiff 10 11 Geoffrey Plowden geoffrey.plowden@lacity.org 12 Deputy City Attorney 13 200 North Main Street 6th Floor, City Hall East 14 Los Angeles, California 90012 15 Attorneys for City of Los Angeles Defendants

16 17 UNITED STATES DISTRICT COURT 18 CENTRAL DISTRICT OF CALIFORNIA 19 CJ MONTANO, Case No. 2:20-cv-07241-CBM-AS 20

Plaintiff 21 Hon. Consuelo B. Marshall 22 v. CITY OF LOS ANGELES; COUNTY OF Hon. Alka Sagar 23 LOS ANGELES; CHIEF MICHEL 24 MOORE; SHERIFF ALEXANDER STIPULATED PROTECTIVE

VILLANUEVA; MICHAEL ORDER

25 RIMKUNAS; and DOES 1-10 inclusive, 26 Defendants 27 28 1 PURPOSES AND LIMITATIONS 2 Discovery in this action is likely to involve production of confidential, 3 proprietary, or private information for which special protection from public disclosure 4 and from use for any purpose other than prosecuting this litigation may be warranted. 5 Accordingly, the parties hereby stipulate to and petition the Court to enter the 6 following Stipulated Protective Order. The parties acknowledge that this Order does 7 not confer blanket protections on all disclosures or responses to discovery and that the 8 protection it affords from public disclosure and use extends only to the limited 9 information or items that are entitled to confidential treatment under the applicable 10 legal principles. The parties further acknowledge, as set forth in Section 12.3, below, 11 that this Stipulated Protective Order does not entitle them to file confidential 12 information under seal; Civil Local Rule 79-5 sets forth the procedures that must be 13 followed and the standards that will be applied when a party seeks permission from the 14 court to file material under seal. 15 GOOD CAUSE STATEMENT 16 This action is likely to involve the exchange of protected health information 17 (“PHI”), Police Officer Personnel information and Open Investigations Consisting of 18 Official Information for which special protection from public disclosure and from use 19 for any purpose other than prosecution of this action is warranted. Such confidential 20 materials and information consist of, among other things, medical records containing 21 PHI, Police Officer Personnel information and Open Investigations Consisting of 22 Official Information. Accordingly, to expedite the flow of information, to facilitate the 23 prompt resolution of disputes over confidentiality of discovery materials, to adequately 24 protect information the parties are entitled to keep confidential, to ensure that the 25 parties are permitted reasonable necessary uses of such material in preparation for and 26 in the conduct of trial, to address their handling at the end of the litigation, and serve 27 the ends of justice, a protective order for such information is justified in this matter. It 28 is the intent of the parties that information will not be designated as confidential for 1 tactical reasons and that nothing be so designated without a good faith belief that it has 2 been maintained in a confidential, non-public manner, and there is good cause why it 3 should not be part of the public record of this case. 4 I. Definitions 5 A. Action: this pending lawsuit 6 B. Challenging Party: a Party or Non-Party that challenges the designation of 7 information or items under this Order. 8 C. “CONFIDENTIAL” Information or Items: information (regardless of how 9 it is generated, stored or maintained) or tangible things that qualify for 10 protection under Federal Rule of Civil Procedure 26(c), and as specified 11 above in the Good Cause Statement. 12 D. Counsel: Outside Counsel of Record and House Counsel (as well as their 13 support staff). 14 E. Designating Party: a Party or Non-Party that designates information or items 15 that it produces in disclosures or in responses to discovery as 16 “CONFIDENTIAL.” 17 F. Disclosure or Discovery Material: all items or information, regardless of 18 the medium or manner in which it is generated, stored, or maintained 19 (including, among other things, testimony, transcripts, and tangible things), 20 that are produced or generated in disclosures or responses to discovery in this 21 matter. 22 G. Expert: a person with specialized knowledge or experience in a matter 23 pertinent to the litigation who has been retained by a Party or its counsel to 24 serve as an expert witness or as a consultant in this Action. 25 H. House Counsel: attorneys who are employees of a party to this Action. 26 House Counsel does not include Outside Counsel of Record or any other 27 outside counsel. 28 I. Non-Party: any natural person, partnership, corporation, association, or other 1 legal entity not named as a Party to this action. 2 J. Outside Counsel of Record: attorneys who are not employees of a party to 3 this Action but are retained to represent or advise a party to this Action and 4 have appeared in this Action on behalf of that party or are affiliated with a 5 law firm which has appeared on behalf of that party, and includes support 6 staff. 7 K. Party: any party to this Action, including all of its officers, directors, 8 employees, consultants, retained experts, and Outside Counsel of Record 9 (and their support staffs). 10 L. Producing Party: a Party or Non-Party that produces Disclosure or 11 Discovery Material in this Action. 12 M. Professional Vendors: persons or entities that provide litigation support 13 services (e.g., photocopying, videotaping, translating, preparing exhibits or 14 demonstrations, and organizing, storing, or retrieving data in any form or 15 medium) and their employees and subcontractors. 16 N. Protected Material: any Disclosure or Discovery Material that is designated 17 as “CONFIDENTIAL.” 18 O. Receiving Party: a Party that receives Disclosure or Discovery Material 19 from a Producing Party. 20 I. Scope 21 The protections conferred by this Stipulation and Order cover not only Protected 22 Material (as defined above), but also (1) any information copied or extracted from 23 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 24 Material; and (3) any testimony, conversations, or presentations by Parties or their 25 Counsel that might reveal Protected Material. 26 Any use of Protected Material at trial shall be governed by the orders of the trial 27 judge. This Order does not govern the use of Protected Material at trial. 28 1 II. Duration 2 Once a case proceeds to trial, all of the information that was designated as 3 confidential or maintained pursuant to this protective order becomes public and will be 4 presumptively available to all members of the public, including the press, unless 5 compelling reasons supported by specific factual findings to proceed otherwise are 6 made to the trial judge in advance of the trial. See Kamakana v. City and County of 7 Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing “good cause” 8 showing for sealing documents produced in discovery from “compelling reasons” 9 standard when merits-related documents are part of court record). Accordingly, the 10 terms of this protective order do not extend beyond the commencement of the trial. 11 III. Designating Protected Materials 12 A. Exercise of Restraint and Care in Designating Material for Protection. 13 Each Party or Non-Party that designates information or items for protection under this 14 Order must take care to limit any such designation to specific material that qualifies 15 under the appropriate standards. The Designating Party must designate for protection 16 only those parts of material, documents, items, or oral or written communications that 17 qualify so that other portions of the material, documents, items, or communications for 18 which protection is not warranted are not swept unjustifiably within the ambit of this 19 Order. Mass, indiscriminate, or routinized designations are prohibited. Designations 20 that are shown to be clearly unjustified or that have been made for an improper 21 purpose (e.g., to unnecessarily encumber the case development process or to impose 22 unnecessary expenses and burdens on other parties) may expose the Designating Party 23 to sanctions. If it comes to a Designating Party’s attention that information or items 24 that it designated for protection do not qualify for protection, that Designating Party 25 must promptly notify all other Parties that it is withdrawing the inapplicable 26 designation. 27 B. Manner and Timing of Designations. Except as otherwise provided in this 28 Order, or as otherwise stipulated or ordered, Disclosure or Discovery Material that 1 qualifies for protection under this Order must be clearly so designated before the 2 material is disclosed or produced. 3 Designation in conformity with this Order requires: 4 (a) for information in documentary form (e.g., paper or electronic documents, 5 but excluding transcripts of depositions or other pretrial or trial proceedings), 6 that the Producing Party affix at a minimum, the legend “CONFIDENTIAL” 7 (hereinafter “CONFIDENTIAL legend”), to each page that contains 8 protected material. If only a portion or portions of the material on a page 9 qualifies for protection, the Producing Party also must clearly identify the 10 protected portion(s) (e.g., by making appropriate markings in the margins). A 11 Party or Non-Party that makes original documents available for inspection 12 need not designate them for protection until after the inspecting Party has 13 indicated which documents it would like copied and produced. During the 14 inspection and before the designation, all of the material made available for 15 inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party 16 has identified the documents it wants copied and produced, the Producing 17 Party must determine which documents, or portions thereof, qualify for 18 protection under this Order. Then, before producing the specified documents, 19 the Producing Party must affix the “CONFIDENTIAL legend” to each page 20 that contains Protected Material. If only a portion or portions of the material 21 on a page qualifies for protection, the Producing Party also must clearly 22 identify the protected portion(s) (e.g., by making appropriate markings in the 23 margins). 24 (b) for testimony given in depositions that the Designating Party identify the 25 Disclosure or Discovery Material on the record, before the close of the 26 deposition all protected testimony. 27 (c) for information produced in some form other than documentary and for any 28 other tangible items, that the Producing Party affix in a prominent place on 1 the exterior of the container or containers in which the information is stored 2 the legend “CONFIDENTIAL.” If only a portion or portions of the 3 information warrants protection, the Producing Party, to the extent 4 practicable, shall identify the protected portion(s). 5 C. Inadvertent Failures to Designate. If timely corrected, an inadvertent failure 6 to designate qualified information or items does not, standing alone, waive 7 the Designating Party’s right to secure protection under this Order for such 8 material. Upon timely correction of a designation, the Receiving Party must 9 make reasonable efforts to assure that the material is treated in accordance 10 with the provisions of this Order. 11 IV. Challenging Confidentiality Designations 12 A. Timing of Challenges. Any Party or Non-Party may challenge a 13 designation of confidentiality at any time that is consistent with the Court’s Scheduling 14 Order. 15 B. Meet and Confer. The Challenging Party shall initiate the dispute 16 resolution process by providing written notice of each designation it is challenging and 17 describing the basis for each challenge. To avoid ambiguity as to whether a challenge 18 has been made, the written notice must recite that the challenge to confidentiality is 19 being made in accordance with Paragraph IV of this Order. The Parties shall attempt to 20 resolve each challenge in good faith and must begin the process by conferring directly 21 (in voice to voice dialogue) within 10 days of the date of service of notice. In conferring, 22 the Challenging Party must explain the basis for its belief that the confidentiality 23 designation was not proper and must give the Designating Party an opportunity to review 24 the designated material, to reconsider the circumstances, and, if no change in designation 25 is offered, to explain the basis for the chosen designation. During the meet and confer 26 process, the Designating Party must state the bases for its objections to each challenge 27 on a document by document basis. A Challenging Party may proceed to the next stage 28 of the challenge process only if it has engaged in this meet and confer process first or 1 establishes that the Designating Party is unwilling to participate in the meet and confer 2 process in a timely manner. 3 C. Judicial Intervention. If the Parties cannot resolve a challenge without 4 court intervention, the Challenging Party shall file a “Notice of Improper Confidential 5 Designation” with the Court (“Notice”). The Notice shall list the challenged documents 6 by Bates label (or other identifying label if no Bates label). The Designating Patty shall 7 file a “Motion to Maintain Confidentiality” within fourteen (14) calendar days of the 8 Notice, explaining why the documents should or should not be de-designated. Failure 9 by the Designating Party to make such a Motion within 14 days of the Notice shall 10 automatically waive the confidentiality designation for each challenged designation. The 11 Challenging Party will then have fourteen (14) calendar days to file a Response. There 12 shall be no Reply absent leave of Court. Either party may lodge but not file the 13 challenged documents with the Court during this stage of the challenge process. The 14 burden of persuasion as to whether information is confidential shall be on the 15 Designating Party. 16 V. Privilege 17 A. Asserting Privilege or Protection. A Party who withholds or redacts documents 18 or information contained within a document on the grounds of attorney-client 19 privilege and/or work product protection, or any other asserted privilege, shall 20 provide: 21 (1) A listing of such documents in electronic spreadsheet format providing the 22 following objective metadata fields (“objective metadata” does not include 23 substantive content from, or a subjective description of, the document being 24 withheld or redacted) where available: 25 (a) the Bates number of the document (or unique document identifier); 26 (b) the nature of the privilege asserted (“attorney-client privilege” or 27 “attorney work product”); 28 1 (c) the name(s) of the author(s) of the document (if known or knowable) (for 2 email chains, because metadata only captures the author(s) of the most 3 recent email in the chain, all emails in the same chain will be listed 4 together in the log and the emails within the chain to which privilege is 5 asserted will state “attorney-client privilege” or “attorney work 6 product”); 7 (d) the name(s) of the recipient(s) of the document, including anyone who 8 was sent the document as a “CC” or a “BCC” (if known or knowable) (for 9 email chains, because metadata only captures the recipients of the most 10 recent email in the chain, all emails in the same chain will be listed 11 together in the log and the emails within the chain to which privilege is 12 asserted will state "attorney-client privilege" or "attorney work product"); 13 (e) the document type, including, for example, whether the document is an 14 email, paper file, a spreadsheet, or other descriptive identifier of the 15 document type; and 16 (f) the date the document was created (if known or knowable), sent (if 17 applicable), and last modified (if applicable). 18 (2) The names of the individuals who are identified prior to providing the privilege 19 log as being attorneys will be highlighted on the log; if it is discovered that 20 names of other attorneys on the log were not highlighted, the Receiving Party 21 will be notified with an offer to provide a replacement log. In addition to the 22 preceding paragraph, the Producing party will also include the following 23 information in its privilege log entries (provided the party remains willing to 24 meet and confer further on specific documents after production of this privilege 25 log): 26 27 28 1 Document Type From and to Whom Content 2 Email From attorney to client Conveying legal advice 3 Email Attach. from client to attorney requesting legal advice 4 Memorandum between attorneys discussing legal advice 5 Letter between clients discussing litigation 6 Other Document between client and prepared in anticipation 7 attorney of/for litigation 8 9 (3) As an alternative to the categories in the preceding paragraph, or where 10 they do not apply, the Producing Party may provide alternate individualized 11 descriptions for such documents. 12 B. Challenging Asserted Privilege and Protection. After receipt of such a 13 privilege log, any Party may dispute a claim of privilege or protection. However, prior 14 to any submission to the Court for an in camera review, the Party disputing a claim of 15 privilege or protection shall provide in writing the identification of the documents for 16 which it questions the claim of privilege or protection and the reasons (including legal 17 support) for its assertion that the documents are not privileged or protected. Within 18 fourteen calendar (14) days, the Party seeking to support the claim of privilege or 19 protection shall provide a written response supporting the claim of privilege or 20 protection (including legal support). The Parties will then meet and confer in good 21 faith as to the claims of privilege or protection. If agreement cannot be met after 22 fourteen (14) calendar days, any party may thereafter submit the material under seal to 23 the Court for a determination as to privilege or protection. If a party believes the 24 circumstances require different timing or procedure, they shall meet and confer on 25 alternatives to resolving any disputes and if unable to agree may present the issue to 26 the Court. 27 28 1 C. Time for Providing Privilege Log. The Producing Party shall provide the 2 information required by paragraph “A” to the receiving party within 30 days of 3 withholding or redacting the related documents. 4 VI. Access to and Use of Protected Materials 5 A. Basic Principles. A Receiving Party may use Protected Material that is 6 disclosed or produced by another Party or by a Non-Party in connection with this 7 Action only for prosecuting, defending, or attempting to settle this Action. Such 8 Protected Material may be disclosed only to the categories of persons and under the 9 conditions described in this Order. When the Action has been terminated, a Receiving 10 Party must comply with the provisions of section XII below (FINAL DISPOSITION). 11 Protected Material must be stored and maintained by a Receiving Party at a location 12 and in a secure manner that ensures that access is limited to the persons authorized 13 under this Order. 14 B. Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise 15 ordered by the court or permitted in writing by the Designating Party, a Receiving 16 Party may disclose any information or item designated “CONFIDENTIAL” only to: 17 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as 18 employees of said Outside Counsel of Record to whom it is reasonably 19 necessary to disclose the information for this Action; 20 (b) the officers, directors, and employees (including House Counsel) of the 21 Receiving Party to whom disclosure is reasonably necessary for this Action; 22 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure 23 is reasonably necessary for this Action and who have signed the 24 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 25 (d) the court and its personnel; 26 (e) court reporters and their staff; 27 28 1 (f) professional jury or trial consultants, mock jurors, and Professional Vendors 2 to whom disclosure is reasonably necessary for this Action and who have 3 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 4 (g) the author or recipient of a document containing the information or a 5 custodian or other person who otherwise possessed or knew the information; 6 (h) during their depositions, witnesses, and attorneys for witnesses, in the Action 7 to whom disclosure is reasonably necessary provided: (1) the deposing party 8 requests that the witness sign the form attached as Exhibit A hereto; and (2) 9 they will not be permitted to keep any confidential information unless they 10 sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless 11 otherwise agreed by the Designating Party or ordered by the court. Pages of 12 transcribed deposition testimony or exhibits to depositions that reveal 13 Protected Material may be separately bound by the court reporter and may 14 not be disclosed to anyone except as permitted under this Stipulated 15 Protective Order; and 16 (i) any mediator or settlement officer, and their supporting personnel, mutually 17 agreed upon by any of the parties engaged in settlement discussions. 18 VII. Protected Material Subpoenaed or Ordered Produced in Other 19 Litigation 20 If a Party is served with a subpoena or a court order issued in other litigation that 21 compels disclosure of any information or items designated in this Action as 22 “CONFIDENTIAL,” that Party must: 23 (a) promptly notify in writing the Designating Party. Such notification shall include 24 a copy of the subpoena or court order; 25 (b) promptly notify in writing the party who caused the subpoena or order to issue in 26 the other litigation that some or all of the material covered by the subpoena or 27 order is subject to this Protective Order. Such notification shall include a copy of 28 this Stipulated Protective Order; and 1 (c) cooperate with respect to all reasonable procedures sought to be pursued by the 2 Designating Party whose Protected Material may be affected. If the Designating 3 Party timely seeks a protective order, the Party served with the subpoena or 4 court order shall not produce any information designated in this action as 5 “CONFIDENTIAL” before a determination by the court from which the 6 subpoena or order issued, unless the Party has obtained the Designating Party’s 7 permission. The Designating Party shall bear the burden and expense of seeking 8 protection in that court of its confidential material and nothing in these 9 provisions should be construed as authorizing or encouraging a Receiving Party 10 in this Action to disobey a lawful directive from another court. 11 VIII. A Non-Party’s Protected Material Sought To Be Produced in This 12 Litigation 13 (a) The terms of this Order are applicable to information produced by a Non-Party 14 in this Action and designated as “CONFIDENTIAL.” Such information 15 produced by Non-Parties in connection with this litigation is protected by the 16 remedies and relief provided by this Order. Nothing in these provisions should 17 be construed as prohibiting a Non-Party from seeking additional protections. 18 (b) In the event that a Party is required, by a valid discovery request, to produce a 19 Non-Party’s confidential information in its possession, and the Party is subject 20 to an agreement with the Non-Party not to produce the Non-Party’s confidential 21 information, then the Party shall: 22 (1) promptly notify in writing the Requesting Party and the Non-Party that 23 some or all of the information requested is subject to a confidentiality 24 agreement with a Non-Party; 25 (2) promptly provide the Non-Party with a copy of the Stipulated Protective 26 Order in this Action, the relevant discovery request(s), and a reasonably 27 specific description of the information requested; and 28 1 (3) make the information requested available for inspection by the Non-Party, 2 if requested. 3 (c) If the Non-Party fails to seek a protective order from this court within 14 days of 4 receiving the notice and accompanying information, the Receiving Party may 5 produce the Non-Party’s confidential information responsive to the discovery 6 request. If the Non-Party timely seeks a protective order, the Receiving Party 7 shall not produce any information in its possession or control that is subject to 8 the confidentiality agreement with the Non-Party before a determination by the 9 court. Absent a court order to the contrary, the Non-Party shall bear the burden 10 and expense of seeking protection in this court of its Protected Material. 11 IX. Unauthorized Disclosure of Protected Material 12 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 13 Protected Material to any person or in any circumstance not authorized under this 14 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 15 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 16 all unauthorized copies of the Protected Material, (c) inform the person or persons to 17 whom unauthorized disclosures were made of all the terms of this Order, and (d) 18 request such person or persons to execute the “Acknowledgment and Agreement to Be 19 Bound” that is attached hereto as Exhibit A. 20 X. Inadvertent Production of Privileged or Otherwise Protected Material 21 When a Producing Party gives notice to Receiving Parties that certain 22 inadvertently produced material is subject to a claim of privilege or other protection, 23 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 24 Procedure 26(b)(5)(B). In the event of disagreement, until such time as the 25 disagreement is resolved, the Receiving Party will return the document and will not 26 review or use the document or its contents. If the substance of the protected document 27 is discussed in a deposition prior to the time of discovery or notification of the 28 inadvertent disclosure, the Parties agree that such testimony may not be used for any 1 purpose until the dispute is resolved by agreement of the Parties or by Court order. The 2 Party to whom any produced document was returned shall retain the returned 3 materials until the end of the case, including any appeals. Within fifteen (15) calendar 4 days after notice of the disclosure, the producing Party shall provide a log that 5 describes the basis for the claim that the material is privileged or otherwise protected 6 from disclosure. After receipt of such a privilege log, any Party may dispute a claim of 7 privilege or protection, by providing in writing the identification of the documents for 8 which it questions the claim of privilege or protection and the reasons (including legal 9 support) for its assertion that the documents are not privileged or protected. Within 10 fifteen (15) calendar days, the Party seeking to support the claim of privilege or 11 protection shall provide a written response supporting the claim of privilege or 12 protection (including legal support). The Parties will then meet and confer in good 13 faith as to the claims of privilege or protection. 14 XI. Miscellaneous 15 A. Right to Further Relief. Nothing in this Order abridges the right of any 16 person to seek its modification by the Court in the future. 17 B. Right to Assert Other Objections. By stipulating to the entry of this 18 Protective Order no Party waives any right it otherwise would have to object to 19 disclosing or producing any information or item on any ground not addressed in this 20 Stipulated Protective Order. Similarly, no Party waives any right to object on any 21 ground to use in evidence of any of the material covered by this Protective Order. 22 C. Filing Protected Material. A Party that seeks to file under seal any 23 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 24 only be filed under seal pursuant to a court order authorizing the sealing of the specific 25 Protected Material at issue. If a Party’s request to file Protected Material under seal is 26 denied by the court, then the Receiving Party may file the information in the public 27 record unless otherwise instructed by the court. 28 1 XII. Final Disposition 2 After the final disposition of this Action, as defined in paragraph 4, within 60 3 days of a written request by the Designating Party, each Receiving Party must return 4 all Protected Material to the Producing Party or destroy such material. As used in this 5 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 6 summaries, and any other format reproducing or capturing any of the Protected 7 Material. Whether the Protected Material is returned or destroyed, the Receiving Party 8 must submit a written certification to the Producing Party (and, if not the same person 9 or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by 10 category, where appropriate) all the Protected Material that was returned or destroyed 11 and (2) affirms that the Receiving Party has not retained any copies, abstracts, 12 compilations, summaries or any other format reproducing or capturing any of the 13 Protected Material. Notwithstanding this provision, Counsel are entitled to retain an 14 archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, 15 legal memoranda, correspondence, deposition and trial exhibits, expert reports, 16 attorney work product, and consultant and expert work product, even if such materials 17 contain Protected Material. Any such archival copies that contain or constitute 18 Protected Material remain subject to this Protective Order as set forth in Section II 19 (DURATION) 20 // 21 // 22 // 23 // 24 // 25 // 26 // 27 // 28 1 Any violation of this Order may be punished by any and all appropriate 2 measures including, without limitation, contempt proceedings and/or monetary 3 sanctions. 4 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 5 Dated: October 30, 2020 By: /s/ Pedram Esfandiary Pedram Esfandiary, Esq. 6 pesfandiary@baumhedlundlaw.com 7 Monique A. Alarcon, Esq. 8 malarcon@baumhedlundlaw.com Timothy A. Loranger, Esq. 9 tloranger@baumhedlundlaw.com 10 Ronald M. Goldman, Esq. rgoldman@baumhedlundlaw.com 11

BAUM HEDLUND ARISTEI GOLDMAN, P.C.

12 10940 Wilshire Boulevard, 17th Floor Los Angeles, CA 90024 13 Telephone: (310) 207-3233 14 Attorneys for Plaintiff CJ Montano 15 16 By: /s/ Geoffrey Plowden Geoffrey Plowden 17 geoffrey.plowden@lacity.org 18 Deputy City Attorney 200 North Main Street 19 6th Floor, City Hall East 20 Los Angeles, California 90012 21 Attorneys for City of Los Angeles Defendants 22 23 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 24 DATED: __N__o_v_em__b_e_r_ 2_,_ 2_0_2_0________ 25 /s/ Alka Sagar 26 _____________________________________ Honorable Alka Sagar 27 United States Magistrate Judge 28

CERTIFICATE OF SERVICE

1

2 The foregoing document was filed on October 30, 2020, using the court’s CM/ECF electronic system which will electronically serve a copy to all counsel of record. 3

4 /s/ Pedram Esfandiary 5 Pedram Esfandiary 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28