1 || Andrew E. Smyth, Esq. SBN 60030 Stephen S. Smyth, Esq. SBN 248433 2 || William J. Smyth, Esq. SBN 265374 3 SW SMYTH LLP 4929 Wilshire Boulevard, Suite 690 41 Los Angeles, California 90010 5 || Telephone: (323) 933-8401 Facsimile: (323) 933-6089 6 office@smythlo.com 7 || Attorneys for Plaintiffs

EUGENE DARRELL FENIX

8 | KIRKIELLA CARRINGTON 9 MICHAEL N. FEUER, City Attorney - SBN 111529 10 | KATHLEEN A. KENEALY, Chief Deputy City Attorney — SBN 212289 11 || SCOTT MARCUS, Senior Assistant City Attorney - SBN 184980 CORY M. BRENTE, Senior Assistant City Attorney — SBN 115453 12 | NICHOLAS LAUBER, Deputy City Attorney — SBN 288499 13 || 200 North Main Street, 6th Floor, City Hall East Los Angeles, CA 90012 141 Phone No.: (213) 978-7025 15 | Fax No.: (213) 978-8785 Email: Nicholas.Lauber@lacity.org 16 Attorneys for Defendant, CITY OF LOS ANGELES 17 18 UNITED STATES DISTRICT COURT 19 CENTRAL DISTRICT OF CALIFORNIA 20 21 | BUGENE DARRELL FENIX, Case No. 2-20-CV-09740 7 || an individual, and KIRKIELLA CARRINGTON, 73 |) an individual STIPULATED PROTECTIVE Plaintiffs, ORDER 24 V. 25 96 || THE CITY OF LOS ANGELES., and DOES 1-20 Inclusive 27 Defendants. 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 4 || disclosure and from use for any purpose other than prosecuting this litigation may 5 || be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 6 | enter the following Stipulated Protective Order. The parties acknowledge that this 7 | Stipulated Protective Order does not confer blanket protections on all disclosures or 8 || responses to discovery and that the protection it affords from public disclosure and 9 || use extends only to the limited information or items that are entitled to confidential 10 || treatment under the applicable legal principles. The parties further acknowledge, as 11 | set forth in Section 13.3 below, that this Stipulated Protective Order does not entitle 12 || them to file confidential information under seal; Local Rule 79-5 sets forth the 13 || procedures that must be followed and the standards that will be applied when a 14 || party seeks permission from the Court to file material under seal. Discovery in this [5 | action is likely to involve production of confidential, proprietary, or private 16 | information for which special protection from public disclosure and from use for || any purpose other than prosecuting this litigation may be warranted. 18 19 | 2. GOOD CAUSE STATEMENT 20) This action involves the City of Los Angeles and Los Angeles Police 21 |) Department officers. Plaintiff is seeking materials and information that Defendants 22 || the City of Los Angeles (“the City”) and Los Angeles Police Department officers 23 || (collectively “Defendants”) maintain as confidential, specifically the police body 24 | worn video from the incident date, which the City maintains as strictly confidential 25 || and which Defendants believe need special protection from public disclosure and 26 || from use for any purpose other than prosecuting this litigation. ai Defendants assert that the confidentiality of the materials and information 28 || sought by Plaintiff is recognized by California and federal law, as evidenced inter

1 | alia by California Penal Code section 832.7 and Kerr v. United States Dist. Ct. for 2 | N.D. Cal., 511 F.2d 192, 198 (9th Cir. 1975), aff'd, 426 U.S. 394 (1976). The City 3 | has not publicly released the materials and information referenced above except 4 | under protective order or pursuant to a court order, if at all. These materials and 5 | information are of the type that has been used to initiate disciplinary action against 6 | Los Angeles Police Department officers, and has been used as evidence in 7 | disciplinary proceedings, where the officers’ conduct was considered to be contrary 8 || to LAPD policy. 9 The City contends that absent a protective order delineating the responsibilities 10 | of nondisclosure on the part of the parties hereto, there is a specific risk of 11 | unnecessary and undue disclosure by one or more of the many attorneys, secretaries, 12 || law clerks, paralegals and expert witnesses involved in this case, as well as the 13 || corollary risk of embarrassment, harassment and professional and legal harm on the 14 || part of the LAPD officers referenced in the materials and information. 15 The City also contends that the unfettered disclosure of the materials and 16 | information, absent a protective order, would allow the media to share this 17 | information with potential jurors in the area, impacting the rights of the City herein 18 || to receive a fair trial. 19 Accordingly, to expedite the flow of information, to facilitate the prompt 20 || resolution of disputes over confidentiality of discovery materials, to adequately 21 || protect information the parties are entitled to keep confidential, to ensure that the 22 || parties are permitted reasonable necessary uses of such material in preparation for 23 || and in the conduct of trial, to address their handling at the end of the litigation, and 24 || serve the ends of justice, a protective order for such information is justified in this 25 || matter. It is the intent of the partics that information will not be designated as 26 || confidential for tactical reasons and that nothing be so designated without a good 27 || faith belief that it has been maintained in a confidential, non-public manner, and there 28 || is good cause why it should not be part of the public record of this case.

|3. DEFINITIONS 2 3.1. Action: Eugene Darrell Fenix et al v. The City of Los Angeles et al, 3 2:20-cv-09740-PA-MAA 4 3.2. Challenging Party: A Party or Nonparty that challenges the 5 designation of information or items under this Stipulated Protective 6 Order. 7 3.3. “CONFIDENTIAL” Information or Items: Information (regardless of 8 how it is generated, stored or maintained) or tangible things that 9 qualify for protection under Federal Rule of Civil Procedure 26(c), and 10 as specified above in the Good Cause Statement. Il 3.4, Counsel: Outside Counsel of Record and In-House Counsel (as well 12 as their support staff). 13 3.5. Designating Party: A Party or Nonparty that designates information or 14 items that it produces in disclosures or in responses to discovery as 15 “CONFIDENTIAL.” 16 3.6. Disclosure or Discovery Material: All items or information, regardless 17] of the medium or manner in which it is generated, stored, or 18 maintained (including, among other things, testimony, transcripts, and 19 tangible things), that is produced or generated in disclosures or 20 responses to discovery in this matter. 21 3.7. Expert: A person with specialized knowledge or experience in a 22 matter pertinent to the litigation who has been retained by a Party or its 23 counsel to serve as an expert witness or as a consultant in this Action. 24 3.8. In-House Counsel: Attorneys who are employees of a party to this 25 Action. In-House Counsel does not include Outside Counsel of 26 Record or any other outside counsel. 27 3.9. Nonparty: Any natural person, partnership, corporation, association, 28 or other legal entity not named as a Party to this action.

1 3.10. Outside Counsel of Record: Attorneys who are not employees of a 2 party to this Action but are retained to represent or advise a party to 3 this Action and have appeared in this Action on behalf of that party or 4 are affiliated with a law firm which has appeared on behalf of that 5 party, and includes support staff 6 3.11. Party: Any party to this Action, including all of its officers, directors, employces, consultants, retained experts, In-House Counsel, and 8 Outside Counsel of Record (and their support staffs). 9 3.12. Producing Party: A Party or Nonparty that produces Disclosure or 10 Discovery Material in this Action, I] 3.13. Professional Vendors: Persons or entities that provide litigation 12 support services (e.g., photocopying, videotaping, translating, 13 preparing exhibits or demonstrations, and organizing, storing, or 14 retrieving data in any form or medium) and their employees and I5 subcontractors. 16 3.14. Protected Material: Any Disclosure or Discovery Material that is 7 designated as “CONFIDENTIAL.” 18 3.15. Receiving Party: A Party that reccives Disclosure or Discovery 19 Material from a Producing Party. 20 || 4, SCOPE 21 The protections conferred by this Stipulated Protective Order cover not only 22 || Protected Material, but also (1) any information copied or extracted from Protected 23 || Material; (2) all copies, excerpts, summaries, or compilations of Protected Material; 24 || and (3) any testimony, conversations, or presentations by Parties or their Counsel 25 || that might reveal Protected Material. 26 Any use of Protected Material at trial shall be governed by the orders of the 27 | trial judge. This Stipulated Protective Order does not govern the use of Protected 28 || Material at trial.

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

| 6.2. Manner and Timing of Designations. 2 Except as otherwise provided in this Stipulated Protective Order 3 (see, e.g, Section 6.2(a)), or as otherwise stipulated or ordered, 4 Disclosure or Discovery Material that qualifies for protection under 5 this Stipulated Protective Order must be clearly so designated before 6 the material is disclosed or produced. 7 Designation in conformity with this Stipulated Protective Order 8 requires the following: 9 (a) For information in documentary form (e.g., paper or electronic 10 documents, but excluding transcripts of depositions or other Il pretrial or trial proceedings), that the Producing Party affix at a 12 minimum, the legend “CONFIDENTIAL” to cach page that 13 contains protected material. [f only a portion or portions of the 14 material on a page qualifies for protection, the Producing Party IS also must clearly identify the protected portion(s) (e.g., by 16 making appropriate markings in the margins). 17 A Party or Nonparty that makes original documents 18 available for inspection need not designate them for protection 19 until afier the inspecting Party has indicated which documents it 20) would like copied and produced. During the inspection and 21 before the designation, all of the material made available for 22 inspection shall be deemed “CONFIDENTIAL.” After the 23 inspecting Party has identified the documents it wants copied 24 and produced, the Producing Party must determine which 25 documents, or portions thereof, qualify for protection under this 26 Stipulated Protective Order. Then, before producing the 27 specified documents, the Producing Party must affix the legend 28 “CONFIDENTIAL” to each page that contains Protected

| Material. If only a portion or portions of the material on a page 2 qualifies for protection, the Producing Party also must clearly 3 identify the protected portion(s) (e.g., by making appropriate 4 markings in the margins). 5 (b) For testimony given in depositions, that the Designating Party 6 identify the Disclosure or Discovery Material on the record, 7 before the close of the deposition, all protected testimony. 8 (c) For information produced in nondocumentary form, and for any 9 other tangible items, that the Producing Party affix ina 10 prominent place on the exterior of the container or containers in 1] which the information is stored the legend “CONFIDENTIAL.” 12 If only a portion or portions of the information warrants 13 protection, the Producing Party, to the extent practicable, shall 14 identify the protected portion(s). 15 6.3. Inadvertent Failure to Designate. 16 If timely corrected, an inadvertent failure to designate qualified 17 information or items does not, standing alone, waive the Designating 18 Pariy’s right to secure protection under this Stipulated Protective Order 19 for such material. Upon timely correction of a designation, the 20) Receiving Party must make reasonable efforts to assure that the material is treated in accordance with the provisions of this Stipulated 22 Protective Order. 2317. CHALLENGING CONFIDENTIALITY DESIGNATIONS 24 7.1. Timing of Challenges. 25 Any Party or Nonparty may challenge a designation of 26 confidentiality at any time thal is consistent with the Court’s 27 Scheduling Order. 28 | ff

| 7.2. Meet and Confer. 2 The Challenging Party shall initiate the dispute resolution 3 process, which shall comply with Local Rule 37.1 et seq., and with 4 Section 4 of Judge Audero’s Procedures (“Mandatory Telephonic 5 Conference for Discovery Disputes”).! 6 7.3. Burden of Persuasion. The burden of persuasion in any such challenge proceeding shall 8 be on the Designating Party. Frivolous challenges, and those made for 9 an improper purpose (e.¢., to harass or impose unnecessary expenses 10 and burdens on other parties) may expose the Challenging Party to 11 sanctions, Unless the Designating Party has waived or withdrawn the 12 confidentiality designation, all partics shall continue to afford the 13 material in question the level of protection to which it is entitled under I4 the Producing Party’s designation until the Court rules on the 15 challenge. 16 17 || 8 ACCESS TO AND USE OF PROTECTED MATERIALS 18 8.1. Basic Principles. 19 A Receiving Party may use Protected Material that is disclosed 20 or produced by another Party or by a Nonparty in connection with this 21 Action only for prosecuting, defending, or attempting to settle this 22 Action. Such Protected Material may be disclosed only to the 23 categories of persons and under the conditions described in this 24 Stipulated Protective Order. When the Action reaches a final 25 disposition, a Receiving Party must comply with the provisions of 26 a0... 2 32 & eo = ' Judge Audero’s Procedures are available at 28 | https://www.cacd.uscourts.gov/honorable-maria-audero.

| Section 14 below. 2 Protected Matcrial must be stored and maintained by a 3 Receiving Party at a location and in a secure manner that ensures that 4 access is limited to the persons authorized under this Stipulated 5 Protective Order. 6 8.2. Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise ordered by the Court or permitted in writing 8 by the Designating Party, a Receiving Party may disclose any 9 information or item designated “CONFIDENTIAL.” only to: 10 (a) The Receiving Party’s Outside Counsel of Record, as well as 1] employees of said Outside Counsel of Record to whom it is 12 reasonably necessary to disclose the information for this Action; 13 (b) The officers, directors, and employees (including In-House l4 Counsel) of the Receiving Party to whom disclosure is 15 reasonably necessary for this Action; 16 (c) Experts of the Receiving Party to whom disclosure is reasonably 17 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; 2] (f) Professional jury or trial consultants, mock jurors, and 22 Professional Vendors to whom disclosure is reasonably 23 necessary or this Action and who have signed the 24 “Acknowledgment and Agreement to be Bound” (Exhibit A); 25 (g) The author or recipient of a document containing the 26 information or a custodian or other person who otherwise 27 possessed or knew the information; 28 (h) During their depositions, witnesses, and attorneys for witnesses, 10

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

| pursued by the Designating Party whose Protected Material may be 2 affected. 3 If the Designating Party timely secks a protective order, the Party served with 4 | the subpoena or court order shall not produce any information designated in this || action as “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 secking 8 | protection in that court of its confidential material and nothing in these provisions 9 | should be construed as authorizing or encouraging a Receiving Party in this Action 10 || to disobey a lawful directive from another court. 11 10. ANONPARTY’S PROTECTED MATERIAL SOUGHT TO BE 13 PRODUCED IN THIS LITIGATION 14 10.1. Application. 15 The terms of this Stipulated Protective Order are applicable to 16 information produced by a Nonparty in this Action and designated as “CONFIDENTIAL.” Such information produced by Nonparties in 18 connection with this litigation is protected by the remedies and relief 19 provided by this Stipulated Protective Order. Nothing in these 20 provisions should be construed as prohibiting a Nonparty from seeking 21 additional protections. 22 10.2. Notification. 23 In the event that a Party is required, by a valid discovery 24 request, to produce a Nonparty’s confidential information in its 25 possession, and the Party is subject to an agreement with the Nonparty 26 not to produce the Nonparty’s confidential information, then the Party 27 shall: 28 (a) Promptly notify in writing the Requesting Party and the 12

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

1 || the “Acknowledgment and Agreement to be Bound” (Exhibit A). 312. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 4 PROTECTED MATERIAL 5 When a Producing Partly gives notice to Receiving Parties that certain 6 || inadvertently produced material is subject to a claim of privilege or other 7 | protection, the obligations of the Recciving Partics are those set forth in Federal 8 || Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 9 | whatever procedure may be established in an e-discovery order that provides for 10 || production without prior privilege review. Pursuant to Federal Rule of Evidence 11 || 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure 12 || of communication or information covered by the attorney-client privilege or work 13 | product protection, the parties may incorporate their agreement in the Stipulated 14 | Protective Order submitted to the Court. 1S 16 | 13. MISCELLANEOUS 17 13.1. Right to Further Relief. 18 Nothing in this Stipulated Protective Order abridges the right of 19 any person to seek its modification by the Court in the future. 20 13.2. Right to Assert Other Objections. 21 By stipulating to the entry of this Stipulated Protective Order, no 22 Party waives any right it otherwise would have to object to disclosing 23 or producing any information or item on any ground not addressed in 24 this Stipulated Protective Order. Similarly, no Party waives any right 25 to object on any ground to use in evidence of any of the material 26 covered by this Stipulated Protective Order. 27 13.3. Filing Protected Material. 28 A Party that secks to file under seal any Protected Material must 14

I comply with Local Rule 79-5. Protected Material may only be filed 2 under seal pursuant to a court order authorizing the sealing of the 3 specific Protected Material at issue. If a Party's request to file 4 Protected Material under seal is denied by the Court, then the 5 Receiving Party may file the information in the public record unless 6 otherwise instructed by the Court. 8] 14. FINAL DISPOSITION ? Afier the final disposition of this Action, within sixty (60) days of a written 10 || request by the Designating Party, each Receiving Party must return all Protected || Material to the Producing Party or destroy such material. As used in this 12 || subdivision, “all Protected Material” includes all copies, abstracts, compilations, 13 || summaries, and any other format reproducing or capturing any of the Protected 14 | Material. Whether the Protected Material is returned or destroyed, the Receiving 15 | Party must submit a written certification to the Producing Party (and, if not the 16 | same person or entity, to the Designating Party) by the 60-day deadline that 17 | (1) identifies (by category, where appropriate) all the Protected Material that was 18 || returned or destroyed and (2) affirms that the Receiving Party has not retained any 19 | copies, abstracts, compilations, summaries or any other format reproducing or 20 | capturing any of the Protected Material. Notwithstanding this provision, Counsel is 21 || entitled to retain an archival copy of all pleadings; motion papers; trial, deposition, 22 || and hearing transcripts; legal memoranda; correspondence; deposition and trial 23 || exhibits; expert reports; attorney work product; and consultant and expert work 24 || product, even if such materials contain Protected Material. Any such archival 25 || copies that contain or constitute Protected Material remain subject to this Stipulated 26 | Protective Order as set forth in Section 5. 27 | ff 28 || MV 15

15. VIOLATION 2 Any violation of this Stipulated Order may be punished by any and all 3 || appropriate measures including, without limitation, contempt proceedings and/or 4 || monetary sanctions. 6 | ITISSO STIPULATED, THROUGH COUNSEL OF RECORD. | ome g | Dated: bb □□□ we ER, Attorney(s) for Plaintifi(s) ’

Dated: 2/10/21 eS I] Attorney(s) for Defendant(s) 12 ‘| 13 | FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. | □□□ 14 —_— 15 || Dated: 02/25/2021 || 16 Maria A! ero United States Magistrate Judge 18 19 20 21

23 24 25 26

28 16

EXHIBIT A

2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, andrew E. Smyth __—_[ full name], of 4929 Wilshire Blvd □□□□ tg Ck S0010 [address], declare under penalty of perjury that I have read in its 5 || entirety and understand the Stipulated Protective Order that was issued by the 6 | United States District Court for the Central District of California on _rebruary 2021 7 || [date] in the case of _Fenix Vs. City of Los Angeles, CV20-09740—PA~ (MAA) 8 || [case name and number]. I agree to comply with and to be bound by all the terms 9 | of this Stipulated Protective Order, and | understand and acknowledge that failure 10 || to so comply could expose me to sanctions and punishment in the nature of I! || contempt. I solemnly promise that I will not disclose in any manner any 12 || information or item that is subject to this Stipulated Protective Order to any person 13 || or entity except in strict compliance with the provisions of this Stipulated Protective 14 | Order. 15 I further agree to submit to the jurisdiction of the United States District Court 16 || for the Ceniral District of California for the purpose of enforcing the terms of this 17 || Stipulated Protective Order, even if such enforcement proceedings occur after 18 | termination of this action. | hereby appoint Michelle Yi [full name] 19 || of 4929 Wilshire Blvd #690 Los Angeles, CA 9001faddress and telephone number] 20 || as my California agent for service of process in connection with this action or any 21 || proceedings related to enforcement of this Stipulated Protective Order, 22 ‘ 23 || Signature: { ire 24 || Printed Name: Renta 25 || Date: February 19, 2021 26 || City and State Where Sworn and Signed: Los Angeles, California 27 28 17