Alejandro Campos Jr. v. City of Fullerton

• Court: District Court, C.D. California
• Decided: February 7, 2025
• Docket: 8:24-cv-01892
• Status: Unknown

Opinion

1 Angela M. Powell, SBN 191876 amp@jones-mayer.com 2 Denise L. Rocawich, SBN 232792 dlr@jones-mayer.com 3 Helen O. Kim, SBN 254560 hok@jones-mayer.com 4 JONES MAYER 3777 North Harbor Boulevard 5 Fullerton, CA 92835 Telephone: (714) 446-1400 6 Facsimile: (714) 446-1448 Attorneys for Defendant, City of Fullerton 7 Luis A. Carrillo, SBN 70398 8 lc@carrillofirm.com Michael S. Carrillo, SBN 258878 9 mc@carrillofirm.com J. Miguel Flores, SBN 240535 10 mf@carrillofirm.com CARRILLO LAW FIRM, LLP 11 1499 Huntington Drive, Suite 402 South Pasadena, CA 91030 12 Telephone: (626) 799-9375 Facsimile: (626) 799-9380 13 Attorneys for Plaintiff, Alejandro Campos, Jr.

14 Arnoldo Casillas, SBN 158519 Acasillas@casillaslegal.com 15 CASILLAS & ASSOCIATES 2801 E. Spring Street, Suite 200 16 Long Beach, CA 90806 Telephone: (562) 203-3030 17 Facsimile: (323) 725-0350 Attorneys for Plaintiffs, Jose Campos Herrera and Elvira Campos Rios 18

19 UNITED STATES DISTRICT COURT

20 CENTRAL DISTRICT OF CALIFORNIA 21 ALEJANDRO CAMPOS, JR., JOSE 22 CAMPOS HERRERA, and ELVIRA Case No. 8:24-cv-01892 DOC-ADS CAMPOS RIOS 23 Plaintiffs, STIPULATED PROTECTIVE ORDER 24 vs. 25 CITY OF FULLERTON, and DOES 1-10, 26 inclusive

27 Defendants.

28 1 I. PURPOSES AND LIMITATIONS 2 A. 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 6 to enter the following Stipulated Protective Order. The parties acknowledge that 7 this Order does not confer blanket protections on all disclosures or responses to 8 discovery and that the protection it affords from public disclosure and use extends 9 only to the limited information or items that are entitled to confidential treatment 10 under the applicable legal principles. The parties further acknowledge, as set 11 forth in Section XIII(C), below, that this Stipulated Protective Order does not 12 entitle them to file confidential information under seal; Civil Local Rule 79-5 sets 13 forth the procedures that must be followed and the standards that will be applied 14 when a party seeks permission from the Court to file material under seal. 15 II. GOOD CAUSE STATEMENT 16 A. This action is likely to involve discovery that is confidential and 17 privileged for which special protection from public disclosure and from use for 18 any purpose other than prosecution of this action may be warranted. Such 19 confidential and proprietary materials and information consist of, among other 20 things, information pertaining to Fullerton Police Department (FPD) and Orange 21 County District Attorney’s Office (OCDA) investigation of the underlying criminal 22 activities, as well as peace officer personnel file information and/or documents 23 which the Parties agree include (1) Personal data, including marital status, family 24 members, educational and employment history, home addresses, or similar 25 information; (2) Medical history; (3) Election of employee benefits; (4) Employee 26 advancement, appraisal or discipline; and (5) Complaints, or investigations of 27 complaints, if any, concerning an event or transaction in which a peace officer 28 participated, or which a peace officer perceived, and pertaining to the manner in 1 which the peace officer performed his or her duties. 2 Such confidential materials and information consist of, among other things, 3 materials that may be entitled to privileges and/or protections under the 4 following: United States Constitution, First Amendment; the California 5 Constitution, Article I, Section 1; California Penal Code §§ 832.5, 832.7 and 832.8; 6 California Evidence Code §§ 1040 and 1043 et. seq; the Privacy Act of 1974, 5 7 U.S.C. § 552; Health Insurance Portability and Accountability Act of 1996 8 (HIPPA); the right to privacy; decisional law relating to such provisions; and 9 information otherwise generally unavailable to the public, or which may be 10 privileged or otherwise protected from disclosure under state or federal statutes, 11 court rules, case decisions, or common law. 12 Defendants also contend that such confidential materials and information 13 is entitled to the Official Information Privilege. Sanchez v. City of Santa Ana, 936 14 F.2d 1027, 1033 (9th Cir. Cal.1990); see also Kerr v. United States Dist. Ct. for 15 N.D. Cal., 511 F.2d 192, 198 (9th Cir. Cal. 1975). Aff’d, 426 U.S. 394, 96 S. Ct. 16 3229, 48 L.Ed.2d 725 (1976). The information otherwise may be generally 17 unavailable to the public, or may be privileged or otherwise protected from 18 disclosure under state or federal statutes, court rules, case decisions, or common 19 law. 20 Further, discovery may require depositions, written discovery and/or the 21 production of certain OCDA Policies and Procedures, and peace officer training 22 information the public disclosure of which could comprise officer safety, and/or 23 raise security issues. Additionally, public disclosure of such information poses a 24 substantial risk of embarrassment, oppression, and/or physical harm to peace 25 officers whose confidential information is disclosed. The risk of harm to peace 26 officers is greater than with other government employees due to the nature of 27 their profession. The benefit of public disclosure of confidential information is 28 minimal while the potential disadvantages are great. 1 Accordingly, to expedite the flow of information, to facilitate the prompt 2 resolution of disputes over confidentiality of discovery materials, to adequately 3 protect information the parties are entitled to keep confidential, to ensure that the 4 parties are permitted reasonable necessary uses of such material in preparation 5 for and in the conduct of trial, to address their handling at the end of the 6 litigation, and serve the ends of justice, a protective order for such information is 7 justified in this matter. It is the intent of the parties that information will not be 8 designated as confidential for tactical reasons and that nothing be so designated 9 without a good faith belief that it has been maintained in a confidential, non- 10 public manner, and there is good cause why it should not be part of the public 11 record of this case. 12 III. DEFINITIONS 13 A. Action: Alejandro Campos, Jr., Jose Campos Herrera, and Elvira 14 Campos Rios v City of Fullerton, and does 1-10, inclusive. 15 B. Challenging Party: A Party or Non-Party that challenges the 16 designation of information or items under this Order. 17 C. “CONFIDENTIAL” Information or Items: Information (regardless of 18 how it is generated, stored or maintained) or tangible things that qualify for 19 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 20 the Good Cause Statement. 21 D. Counsel: Outside Counsel of Record and House Counsel (as well as 22 their support staff). 23 E. Designating Party: A Party or Non-Party that designates information 24 or items that it produces in disclosures or in responses to discovery as 25 “CONFIDENTIAL.” 26 F. Disclosure or Discovery Material: All items or information, 27 regardless of the medium or manner in which it is generated, stored, or 28 maintained (including, among other things, testimony, transcripts, and tangible 1 things), that are produced or generated in disclosures or responses to discovery in 2 this matter. 3 G. Expert: A person with specialized knowledge or experience in a 4 matter pertinent to the litigation who has been retained by a Party or its counsel 5 to serve as an expert witness or as a consultant in this Action. 6 H. House Counsel: Attorneys who are employees of a party to this 7 Action. House Counsel does not include Outside Counsel of Record or any other 8 outside counsel. 9 I. Non-Party: Any natural person, partnership, corporation, 10 association, or other legal entity not named as a Party to this action. 11 J. Outside Counsel of Record: Attorneys who are not employees of a 12 party to this Action but are retained to represent or advise a party to this Action 13 and have appeared in this Action on behalf of that party or are affiliated with a law 14 firm which has appeared on behalf of that party, and includes support staff. 15 K. Party: Any party to this Action, including all of its officers, directors, 16 employees, consultants, retained experts, and Outside Counsel of Record (and 17 their support staffs). 18 L. Producing Party: A Party or Non-Party that produces Disclosure or 19 Discovery Material in this Action. 20 M. Professional Vendors: Persons or entities that provide litigation 21 support services (e.g., photocopying, videotaping, translating, preparing exhibits 22 or demonstrations, and organizing, storing, or retrieving data in any form or 23 medium) and their employees and subcontractors. 24 N. Protected Material: Any Disclosure or Discovery Material that is 25 designated as “CONFIDENTIAL.” 26 O. Receiving Party: A Party that receives Disclosure or Discovery 27 Material from a Producing Party. 28 // 1 IV. SCOPE 2 A. The protections conferred by this Stipulation and Order cover not 3 only Protected Material (as defined above), but also (1) any information copied or 4 extracted from Protected Material; (2) all copies, excerpts, summaries, or 5 compilations of Protected Material; and (3) any testimony, conversations, or 6 presentations by Parties or their Counsel that might reveal Protected Material. 7 B. Any use of Protected Material at trial shall be governed by the orders 8 of the trial judge. This Order does not govern the use of Protected Material at 9 trial. 10 V. DURATION 11 A. Even after final disposition of this litigation, the confidentiality 12 obligations imposed by this Order shall remain in effect until a Designating Party 13 agrees otherwise in writing or a court order otherwise directs. Final disposition 14 shall be deemed to be the later of (1) dismissal of all claims and defenses in this 15 Action, with or without prejudice; and (2) final judgment herein after the 16 completion and exhaustion of all appeals, rehearings, remands, trials, or reviews 17 of this Action, including the time limits for filing any motions or applications for 18 extension of time pursuant to applicable law. 19 VI. DESIGNATING PROTECTED MATERIAL 20 A. Exercise of Restraint and Care in Designating Material for Protection 21 1. Each Party or Non-Party that designates information or items 22 for protection under this Order must take care to limit any such 23 designation to specific material that qualifies under the appropriate 24 standards. The Designating Party must designate for protection only 25 those parts of material, documents, items, or oral or written 26 communications that qualify so that other portions of the material, 27 documents, items, or communications for which protection is not 28 warranted are not swept unjustifiably within the ambit of this Order. 1 2. Mass, indiscriminate, or routinized designations are 2 prohibited. Designations that are shown to be clearly unjustified or 3 that have been made for an improper purpose (e.g., to unnecessarily 4 encumber the case development process or to impose unnecessary 5 expenses and burdens on other parties) may expose the Designating 6 Party to sanctions. 7 3. If it comes to a Designating Party’s attention that information 8 or items that it designated for protection do not qualify for 9 protection, that Designating Party must promptly notify all other 10 Parties that it is withdrawing the inapplicable designation. 11 B. Manner and Timing of Designations 12 1. Except as otherwise provided in this Order (see, e.g., Section 13 B(2)(b) below), or as otherwise stipulated or ordered, Disclosure or 14 Discovery Material that qualifies for protection under this Order 15 must be clearly so designated before the material is disclosed or 16 produced. 17 2. Designation in conformity with this Order requires the 18 following: 19 a. For information in documentary form (e.g., paper or 20 electronic documents, but excluding transcripts of depositions 21 or other pretrial or trial proceedings), that the Producing Party 22 affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 23 “CONFIDENTIAL legend”), to each page that contains 24 protected material. If only a portion or portions of the material 25 on a page qualifies for protection, the Producing Party also 26 must clearly identify the protected portion(s) (e.g., by making 27 appropriate markings in the margins). 28 b. A Party or Non-Party that makes original documents 1 available for inspection need not designate them for protection 2 until after the inspecting Party has indicated which documents 3 it would like copied and produced. During the inspection and 4 before the designation, all of the material made available for 5 inspection shall be deemed “CONFIDENTIAL.” After the 6 inspecting Party has identified the documents it wants copied 7 and produced, the Producing Party must determine which 8 documents, or portions thereof, qualify for protection under 9 this Order. Then, before producing the specified documents, 10 the Producing Party must affix the “CONFIDENTIAL legend” 11 to each page that contains Protected Material. If only a portion 12 or portions of the material on a page qualifies for protection, 13 the Producing Party also must clearly identify the protected 14 portion(s) (e.g., by making appropriate markings in the 15 margins). 16 c. For testimony given in depositions, that the Designating 17 Party identify the Disclosure or Discovery Material on the 18 record, before the close of the deposition all protected 19 testimony. 20 d. For information produced in form other than document 21 and for any other tangible items, that the Producing Party affix 22 in a prominent place on the exterior of the container or 23 containers in which the information is stored the legend 24 “CONFIDENTIAL.” If only a portion or portions of the 25 information warrants protection, the Producing Party, to the 26 extent practicable, shall identify the protected portion(s). 27 e. Any CONFIDENTIAL legend that is affixed to information in 28 documentary form shall not conceal, obscure, cover otherwise 1 block any information or contents of such document. Any 2 CONFIDENTIAL legends that are affixed on documentary 3 information shall not be in the form of a watermark which 4 covers any portion of the documentary information, but shall 5 be in a conspicuous, clear and prominent form in the margins 6 of such document or affixed on the document such that no 7 information is covered by the CONFIDENTIAL legend. 8 f. Documents or information that are labeled CONFIDENTIAL 9 shall have the CONFIDENTIAL legend removed before such 10 document is used as an exhibit at trial. The parties to this 11 Protective Order agree to produce copies of any protected 12 material that is to be used as an exhibit by another party at trial 13 without the CONFIDENTIAL legend. Such production will 14 take place 30 days before trial exhibits are exchanged. Each 15 party will provide a list of such exhibits to the party that has 16 custody of said protected material 45 days before trial exhibits 17 are to be exchanged asking the custodial party to produce a 18 version of the protected material without the CONFIDENTIAL 19 legend. 20 g. Any video footage that is designated as CONFIDENTIAL 21 shall be produced without any CONFIDENTIAL legend 22 obscuring any portion of the video footage. The parties are 23 hereby ordered to produce an original or native form copy of 24 any video footage that is labeled CONFIDENTIAL for use by 25 any party’s experts within 30 days of receiving a request for 26 such video footage in such form. 27 C. Inadvertent Failure to Designate 28 1. If timely corrected, an inadvertent failure to designate qualified 1 information or items does not, standing alone, waive the Designating 2 Party’s right to secure protection under this Order for such material. 3 Upon timely correction of a designation, the Receiving Party must 4 make reasonable efforts to assure that the material is treated in 5 accordance with the provisions of this Order. 6 VII. CHALLENGING CONFIDENTIALITY DESIGNATIONS 7 A. Timing of Challenges 8 1. Any party or Non-Party may challenge a designation of 9 confidentiality at any time that is consistent with the Court’s 10 Scheduling Order. 11 B. Meet and Confer 12 1. The Challenging Party shall initiate the dispute resolution 13 process under Local Rule 37.1 et seq. 14 C. The burden of persuasion in any such challenge proceeding shall be 15 on the Designating Party. Frivolous challenges, and those made for an improper 16 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 17 parties) may expose the Challenging Party to sanctions. Unless the Designating 18 Party has waived or withdrawn the confidentiality designation, all parties shall 19 continue to afford the material in question the level of protection to which it is 20 entitled under the Producing Party’s designation until the Court rules on the 21 challenge. 22 VIII. ACCESS TO AND USE OF PROTECTED MATERIAL 23 A. Basic Principles 24 1. A Receiving Party may use Protected Material that is disclosed 25 or produced by another Party or by a Non-Party in connection with 26 this Action only for prosecuting, defending, or attempting to settle 27 this Action. Such Protected Material may be disclosed only to the 28 categories of persons and under the conditions described in this 1 Order. When the Action has been terminated, a Receiving Party must 2 comply with the provisions of Section XIV below. 3 2. Protected Material must be stored and maintained by a 4 Receiving Party at a location and in a secure manner that ensures 5 that access is limited to the persons authorized under this Order. 6 B. Disclosure of “CONFIDENTIAL” Information or Items 7 1. 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 in this 11 Action, as well as employees of said Outside Counsel of Record 12 to whom it is reasonably necessary to disclose the information 13 for this Action; 14 b. The officers, directors, and employees (including House 15 Counsel) of the Receiving Party to whom disclosure is 16 reasonably necessary for this Action; 17 c. Experts (as defined in this Order) of the Receiving Party 18 to whom disclosure is reasonably necessary for this Action and 19 who have signed the “Acknowledgment and Agreement to Be 20 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 24 Professional Vendors to whom disclosure is reasonably 25 necessary for this Action and who have signed the 26 “Acknowledgment and Agreement to be Bound” attached as 27 Exhibit A hereto; 28 g. The author or recipient of a document containing the 1 information or a custodian or other person who otherwise 2 possessed or knew the information; 3 h. During their depositions, witnesses, and attorneys for 4 witnesses, in the Action to whom disclosure is reasonably 5 necessary provided: (i) the deposing party requests that the 6 witness sign the “Acknowledgment and Agreement to Be 7 Bound;” and (ii) they will not be permitted to keep any 8 confidential information unless they sign the 9 “Acknowledgment and Agreement to Be Bound,” unless 10 otherwise agreed by the Designating Party or ordered by the 11 Court. Pages of transcribed deposition testimony or exhibits to 12 depositions that reveal Protected Material may be separately 13 bound by the court reporter and may not be disclosed to 14 anyone except as permitted under this Stipulated Protective 15 Order; and 16 i. Any mediator or settlement officer, and their supporting 17 personnel, mutually agreed upon by any of the parties engaged 18 in settlement discussions. 19 IX. PROTECTED MATERIAL SUBPOENAED OR ORDERED 20 PRODUCED IN OTHER LITIGATION 21 A. If a Party is served with a subpoena or a court order issued in other 22 litigation that compels disclosure of any information or items designated in this 23 Action as “CONFIDENTIAL,” that Party must: 24 1. Promptly notify in writing the Designating Party. Such 25 notification shall include a copy of the subpoena or court order; 26 2. Promptly notify in writing the party who caused the subpoena 27 or order to issue in the other litigation that some or all of the material 28 covered by the subpoena or order is subject to this Protective Order. 1 Such notification shall include a copy of this Stipulated Protective 2 Order; and 3 3. Cooperate with respect to all reasonable procedures sought to 4 be pursued by the Designating Party whose Protected Material may 5 be affected. 6 B. If the Designating Party timely seeks a protective order, the Party 7 served with the subpoena or court order shall not produce any information 8 designated in this action as “CONFIDENTIAL” before a determination by the 9 Court from which the subpoena or order issued, unless the Party has obtained the 10 Designating Party’s permission. The Designating Party shall bear the burden and 11 expense of seeking protection in that court of its confidential material and nothing 12 in these provisions should be construed as authorizing or encouraging a Receiving 13 Party in this Action to disobey a lawful directive from another court. 14 X. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 15 PRODUCED IN THIS LITIGATION 16 A. The terms of this Order are applicable to information produced by a 17 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 18 produced by Non-Parties in connection with this litigation is protected by the 19 remedies and relief provided by this Order. Nothing in these provisions should be 20 construed as prohibiting a Non-Party from seeking additional protections. 21 B. In the event that a Party is required, by a valid discovery request, to 22 produce a Non-Party’s confidential information in its possession, and the Party is 23 subject to an agreement with the Non-Party not to produce the Non-Party’s 24 confidential information, then the Party shall: 25 1. Promptly notify in writing the Requesting Party and the Non- 26 Party that some or all of the information requested is subject to a 27 confidentiality agreement with a Non-Party; 28 2. Promptly provide the Non-Party with a copy of the Stipulated 1 Protective Order in this Action, the relevant discovery request(s), and 2 a reasonably specific description of the information requested; and 3 3. Make the information requested available for inspection by the 4 Non-Party, if requested. 5 C. If the Non-Party fails to seek a protective order from this court within 6 14 days of receiving the notice and accompanying information, the Receiving 7 Party may produce the Non-Party’s confidential information responsive to the 8 discovery request. If the Non-Party timely seeks a protective order, the Receiving 9 Party shall not produce any information in its possession or control that is subject 10 to the confidentiality agreement with the Non-Party before a determination by the 11 court. Absent a court order to the contrary, the Non-Party shall bear the burden 12 and expense of seeking protection in this court of its Protected Material. 13 XI. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 14 A. If a Receiving Party learns that, by inadvertence or otherwise, it has 15 disclosed Protected Material to any person or in any circumstance not authorized 16 under this Stipulated Protective Order, the Receiving Party must immediately (1) 17 notify in writing the Designating Party of the unauthorized disclosures, (2) use its 18 best efforts to retrieve all unauthorized copies of the Protected Material, (3) inform 19 the person or persons to whom unauthorized disclosures were made of all the 20 terms of this Order, and (4) request such person or persons to execute the 21 “Acknowledgment and Agreement to be Bound” that is attached hereto as Exhibit 22 A. 23 XII. INADVERTENT PRODUCTION OF PRIVILEGED OR 24 OTHERWISE PROTECTED MATERIAL 25 A. When a Producing Party gives notice to Receiving Parties that certain 26 inadvertently produced material is subject to a claim of privilege or other 27 protection, the obligations of the Receiving Parties are those set forth in Federal 28 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 1 whatever procedure may be established in an e-discovery order that provides for 2 production without prior privilege review. Pursuant to Federal Rule of Evidence 3 502(d) and (e), insofar as the parties reach an agreement on the effect of 4 disclosure of a communication or information covered by the attorney-client 5 privilege or work product protection, the parties may incorporate their agreement 6 in the Stipulated Protective Order submitted to the Court. 7 XIII. MISCELLANEOUS 8 A. Right to Further Relief 9 1. Nothing in this Order abridges the right of any person to seek 10 its modification by the Court in the future. 11 B. Right to Assert Other Objections 12 1. By stipulating to the entry of this Protective Order, no Party 13 waives any right it otherwise would have to object to disclosing or 14 producing any information or item on any ground not addressed in 15 this Stipulated Protective Order. Similarly, no Party waives any right 16 to object on any ground to use in evidence of any of the material 17 covered by this Protective Order. 18 C. Filing Protected Material 19 1. A Party that seeks to file under seal any Protected Material 20 must comply with Civil Local Rule 79-5. Protected Material may only 21 be filed under seal pursuant to a court order authorizing the sealing 22 of the specific Protected Material at issue. If a Party's request to file 23 Protected Material under seal is denied by the Court, then the 24 Receiving Party may file the information in the public record unless 25 otherwise instructed by the Court. 26 D. Use of Protected Material at Trial 27 Protected material may be used at trial and presented to a jury or 28 court during trial for any reason permitted by the Federal Rules of Evidence, 1 absent any order of this court barring such use. In the event protected material is 2 presented to a jury during trial, any CONFIDENTIAL standing of such material 3 will lose its protection under this order. 4 XIV. FINAL DISPOSITION 5 A. After the final disposition of this Action, as defined in Section V, 6 within sixty (60) days of a written request by the Designating Party, each 7 Receiving Party must return all Protected Material to the Producing Party or 8 destroy such material. As used in this subdivision, “all Protected Material” 9 includes all copies, abstracts, compilations, summaries, and any other format 10 reproducing or capturing any of the Protected Material. Whether the Protected 11 Material is returned or destroyed, the Receiving Party must submit a written 12 certification to the Producing Party (and, if not the same person or entity, to the 13 Designating Party) by the 60 day deadline that (1) identifies (by category, where 14 appropriate) all the Protected Material that was returned or destroyed and (2) 15 affirms that the Receiving Party has not retained any copies, abstracts, 16 compilations, summaries or any other format reproducing or capturing any of the 17 Protected Material. Notwithstanding this provision, Counsel are entitled to retain 18 an archival copy of all pleadings, motion papers, trial, deposition, and hearing 19 transcripts, legal memoranda, correspondence, deposition and trial exhibits, 20 expert reports, attorney work product, and consultant and expert work product, 21 even if such materials contain Protected Material. Any such archival copies that 22 contain or constitute Protected Material remain subject to this Protective Order as 23 set forth in Section V. 24 // 25 // 26 // 27 // 28 // 1 B. Any violation of this Order may be punished by any and all 2 appropriate measures including, without limitation, contempt proceedings and/or 3 monetary sanctions. 4 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

5 Respectfully submitted, 6 Dated: February 4, 2025 JONES MAYER 7 8 By: /s/ Helen O. Kim 9 ANGELA M. POWELL DENISE L. ROCAWICH 10 HELEN O. KIM 11 Attorneys for Defendant City of Fullerton 12

13 Dated: February 4, 2025 CARRILLO LAW FIRM, LLP 14

15 By: /s/Luis A. Carillo 16 LUIS A. CARRILLO MICHAEL S. CARRILLO 17 J. MIGUEL FLORES Attorneys for Plaintiff 18 Alejandro Campos, Jr. 19

27 [ADDITIONAL SIGNATURES ON FOLLOWING PAGE] 28 1 Dated: February 4, 2025 CASILLAS & ASSOCIATES 2 3 By: /s/ Arnoldo Casillas 4 ARNOLDO CASILLAS 5 Attorneys for Plaintiffs Jose Campos Herrera, and Elvira Campos Rios 6 Pursuant to Local Rule 5-4.3.4, as the filer of this document, I attest that all other 7 signatories listed, and on whose behalf the filing is submitted, concur in the 8 filing’s content and have authorized the filing. 9 10 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 11 12 13 Dated: 02/07/2025 /s/ Autumn D. Spaeth 14 HONORABLE AUTUMN D. SPAETH United States Magistrate Judge 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 5 I, [print or type full name], of 6 [print or type full address], declare under penalty of perjury that I 7 have read in its entirety and understand the Stipulated Protective Order that was 8 issue by the United States District Court for the Central District of California on 9 [DATE] in the case of [insert formal name of the case 10 and the number and initials assigned to it by the Court]. I agree to comply with 11 and to be bound by all the terms of this Stipulated Protective Order and I 12 understand and acknowledge that failure to so comply could expose me to 13 sanctions and punishment in the nature of contempt. I solemnly promise that I 14 will not disclose in any manner any information or item that is subject to this 15 Stipulated Protective Order to any person or entity except in strict compliance 16 with the provisions of this Order. 17 I further agree to submit to the jurisdiction of the United States District 18 Court for the Central District of California for the purpose of enforcing the terms 19 of this Stipulated Protective Order, even if such enforcement proceedings occur 20 after termination of this action. I hereby appoint [print 21 or type full name] of [print or type full address and 22 telephone number] as my California agent for service of process in connection 23 with this action or any proceedings related to enforcement of this Stipulated 24 Protective Order. 25 Date: 26 City and State where sworn and signed: 27 Printed Name: 28 Signature: