Dezarae Munoz v. Chad Bianco

Opinion

1 Eugene P. Ramirez (State Bar No. 134865) cugeneramir menninglip.com 2 Eugene P. Hanrahan (State Bar No. 185826) eugene. □□□□□□□□□□□□□□□□□□□□□□□ 3 Kayleigh A. Andersen (State Bar No. 306442) Rapicigh □□□□□□□□□□□□□□□□□□□□□□□ 4 MANNING & KAS ELLROD, RAMIREZ, TRESTER LLP 5 /801 S. Figueroa St, 15th Floor, Los Angeles, California 90017-3012 6 Telephone: GB) 624-6900 Facsimile: (213) 624-6999 7 Attorneys for Defendants SHERIFF 8 CHAD BIANCO; Sergeant TODD JOHNSON; Correctional Deputy ABDUL 9 FAR; MORGAN MCCANDLESS; Correctional Corporal BENJAMIN 10 SEAGRAVES-GLADNEY; Deputy KEVIN JONES; Correctional Deputy 2 11 || PHILLIP DIEFENDERFER; Correctional Deputy THOMAS KOLB; Correctional — 412 Deputy MIGUE TRIANA; and Corporal KAT GALLARDO z 13 > UNITED STATES DISTRICT COURT 14 = CENTRAL DISTRICT OF CALIFORNIA = 15 16 oe DEZARAE MUNOZ, individually and | Case No. 5:23-cv-02063-JGB-DTB 17 as successor-in-interest to Estate of ULYSSES MUNOZ AYALA, 18 STIPULATED PROTECTIVE Plaintiffs, ORDER RE CONFIDENTIAL V. 20 SHERIFF CHAD BIANCO, an Action Filed: October 10, 2023 21 Individual; Sergeant TODD FAC Filed: November 8, 2024 JOHNSON, an individual, Correctional 22 peput ABDUL FAR, an individual, M IRGAN MCCANDLESS, an 23 Individual, Correctional Corporal BENJAMIN SEAGRAVES- 24 GLADNEY, an Individual, Correctional Deputy KEVIN JONES, an Individual; 25 Correctional Deputy PHILLIP DIEFENDERFER, an Individual, 26 Correctional Deputy THOMAS KOLB, an Individual, Correctional Deputy 27 MIGUE TRIANA, an Individual, Corporal KAI GALLARDO, an 28 individual: RIVERSIDE COUNTY

BOERS RERARE MENT: Defendants. 3 4 5 }1. A.PURPOSES AND LIMITATIONS 6 Discovery in this action is likely to involve production of confidential, 7 proprietary, or private information for which special protection from public disclosure 8 and from use for any purpose other than prosecuting this litigation may be warranted. 9 Accordingly, the parties hereby stipulate to and petition the Court to enter the 10 following Stipulated Protective Order. The parties acknowledge that this Order does 2 11 ||not confer blanket protections on all disclosures or responses to discovery and that x 12 ||the protection it affords from public disclosure and use extends only to the limited 13 information or items that are entitled to confidential treatment under the applicable 14 legal principles. The parties further acknowledge, as set forth in Section 12.3, below, 15 that this Stipulated Protective Order does not entitle them to file confidential 16 information under seal; Civil Local Rule 79-5 sets forth the procedures that must be 17 followed and the standards that will be applied when a party seeks permission from 18 the court to file material under seal. 20 This action is likely to involve medical records, documents containing private 21 information from third parties, police investigation procedures and tactics, and other 22 confidential and private information for which special protection from public 23 disclosure and from use for any purpose other than prosecution of this action is 24 warranted. Such confidential and proprietary materials and information consist of, 25 among other things, confidential personal information of non-parties, private medical 26 and mental health records, including Plaintiff's and plaintiffs’ decedent’s HIPAA 27 protected medical and mental health care records, internal police reviews and 28 procedures, and other confidential and sensitive information otherwise generally

1 unavailable to the public, or which may be privileged or otherwise protected from 2 disclosure under state or federal statutes, court rules, case decisions, or common law. 3 Defendants contend that there is good cause for a protective order to maintain the 4 confidentiality of peace officer personnel records. They emphasize that releasing 5 these records, which include internal analyses and legal communications, could 6 hinder law enforcement investigations. 7 Accordingly, to expedite the flow of information, to facilitate the prompt 8 resolution of disputes over confidentiality of discovery materials, to adequately 9 protect information the parties are entitled to keep confidential, to ensure that the 10 parties are permitted reasonable necessary uses of such material in preparation for and 2 11 in the conduct of trial, to address their handling at the end of the litigation, and serve x 12 || the ends of justice, a protective order for such information is justified in this matter. 13 It is the intent of the parties that information will not be designated as confidential for S$ 14 || tactical reasons and that nothing be so designated without a good faith belief that it 15 been maintained in a confidential, non-public manner, and there is good cause 16 why it should not be part of the public record of this case. 17 2.. DEFINITIONS 18 2.1 Action: this pending federal lawsuit in Munoz v. County of Riverside, et al. 19 (Case No: 5:23-cv-02063-JGB-DTB). 20 2.2 Challenging Party: a Party or Non-Party that challenges the designation of 21 information or items under this Order. 22 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how 23 it is generated, stored or maintained) or tangible things that qualify for protection 24 }under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 25 Cause Statement. 26 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 27 support staff). 28 2.5 Designating Party: a Party or Non-Party that designates information or

1 j/items that it produces in disclosures or in responses to discovery as 2 “CONFIDENTIAL.” 3 2.6 Disclosure or Discovery Material: all items or information, regardless of 4 the medium or manner in which it is generated, stored, or maintained (including, 5 among other things, testimony, transcripts, and tangible things), that are produced or 6 generated in disclosures or responses to discovery in this matter. 7 2.7 Expert: a person with specialized knowledge or experience in a matter 8 pertinent to the litigation who has been retained by a Party or its counsel to serve as 9 an expert witness or as a consultant in this Action. 10 2.8 House Counsel: attorneys who are employees of a party to this Action. 2 11 || House Counsel does not include Outside Counsel of Record or any other outside 12 Ilcounsel. 13 2.9 Non-Party: any natural person, partnership, corporation, association, or S$ 14 || other legal entity not named as a Party to this action. 15 2.10 Outside Counsel of Record: attorneys who are not employees of a party to 16 this Action but are retained to represent or advise a party to this Action and have 17 appeared in this Action on behalf of that party or are affiliated with a law firm which 18 has appeared on behalf of that party, and includes support staff. 19 2.11 Party: any party to this Action, including all of its officers, directors, 20 employees, consultants, retained experts, and Outside Counsel of Record (and their 21 support staffs). 22 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 23 Discovery Material in this Action. 24 2.13 Professional Vendors: persons or entities that provide litigation support 25 services (e.g., photocopying, videotaping, translating, preparing exhibits or 26 demonstrations, and organizing, storing, or retrieving data in any form or medium) 27 and their employees and subcontractors. 28 2.14 Protected Material: any Disclosure or Discovery Material that 1s

1 designated as “CONFIDENTIAL.” 2 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 3 from a Producing Party. 4 /3. SCOPE 5 The protections conferred by this Stipulation and its associated Order cover not 6 only Protected Material/Confidential Documents (as defined above), but also (1) any 7 information copied or extracted from Protected Material; (2) all copies, excerpts, 8 summaries, or compilations of Protected Material; and (3) any testimony, 9 conversations, or presentations by Parties or their Counsel that might reveal Protected 10 Material. However, the protections conferred by this Stipulation and its associated 2 11 || Order do not cover the following information: (a) any information that is in the public x 12 || domain at the time of disclosure to a Receiving Party or becomes part of the public 13 domain after its disclosure to a Receiving Party as a result of publication not involving 14 a violation of this Order, including becoming part of the public record through trial or 15 otherwise; and (b) any information known to the Receiving Party prior to the 16 disclosure or obtained by the Receiving Party after the disclosure from a source who 17 obtained the information lawfully and under no obligation of confidentiality to the 18 Designating Party. 19 Any use of Protected Material at trial shall be governed by the orders of the 20 trial judge. This Order does not govern the use of Protected Material at trial. 21 }4. DURATION 22 “Once a case proceeds to trial, all information designated as confidential and 23 introduced at trial shall be presumptively public, subject only to sealing by order of 24 the trial judge upon a showing of compelling reasons supported by specific factual 25 findings (Kamakana v. City & County of Honolulu, 447 F.3d 1172). This Order shall 26 not be construed to create any preemptive right to seal trial exhibits.” Accordingly, 27 the terms of this protective order do not extend beyond the commencement of the trial 28 except as designated above.

1/5. DESIGNATION OF PROTECTED MATERIAL 2 5.1. Exercise of Restraint and Care in Designating Material for Protection. 3 Each Party or non-party that designates information or items for protection 4 /under this Stipulation and its associated Order must take care to limit any such 5 designation to specific material that qualifies under the appropriate standards. A 6 Designating Party must take care to designate for protection only those parts of 7 material, documents, items, or oral or written communications that qualify — so that 8 other portions of the material, documents, items or communications for which 9 protection is not warranted are not swept unjustifiably within the ambit of this Order. 10 “Mass, indiscriminate, or routine designations are prohibited, and designations 2 11 ||shall be made only where good cause exists under FRCP 26(c) or applicable x 12 || California law, with a specific factual basis supporting confidentiality. Information 13 may not be designated confidential for tactical reasons or to impede case preparation.” 14 Designations that are shown to be clearly unjustified, or that have been made for an 15 improper purpose (e.g., to unnecessarily encumber or retard the case development 16 process, or to impose unnecessary expenses and burdens on other parties), expose the 17 Designating Party to sanctions. 18 If it comes to a Designating Party’s attention that information or items that it 19 designated for protection do not qualify for protection, that Designating Party must 20 promptly notify all other Parties that it is withdrawing the inapplicable designation. 21 5.2. Manner and Timing of Designations. Except as otherwise provided in 22 this Order, or as otherwise stipulated or ordered, material that qualifies for protection 23 }under this Order must be clearly so designated before the material is disclosed or 24 produced. 25 Designation in conformity with this Order requires: 26 (a) for information in documentary form (apart from transcripts of 27 depositions or other pretrial or trial proceedings, and regardless of whether produced 28 in hardcopy or electronic form), that the Producing Party affix the legend

1 “CONFIDENTIAL: THESE DOCUMENTS ARE SUBJECT TO THE TERMS AND 2 CONDITIONS OF A PROTECTIVE ORDER, Case No. 5:24-cv-02405-SVW-DTB” 3 to each page that contains Protected Material. If only a portion or portions of the 4 material on a page qualifies for protection, the Producing Party also must clearly 5 identify the protected portion(s) (e.g., by making appropriate markings in the margins) 6 and must specify, for each portion that it is “CONFIDENTIAL.” The placement of 7 such “CONFIDENTIAL” stamp on such page(s) shall not obstruct the substance of 8 the page’s (or pages’) text or content and shall be in the margin of the document 9 whenever possible. 10 A Party or Non-Party that makes original documents or materials available for 2 11 || inspection need not designate them for protection until after the inspecting Party has x 12 || indicated which material it would like copied and produced. During the inspection 13 and before the designation, all of the material made available for inspection shall be 14 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents 15 it wants copied and produced, the Producing Party must determine which documents, or portions thereof, qualify for protection under this Order. Then, before producing 17 the specified documents, the Producing Party must affix the “CONFIDENTIAL” 18 legend to each page that contains Protected Material. If only a portion or portions of 19 the material on a page qualifies for protection, the Producing Party also must clearly 20 lidentify the protected portion(s) (e.g., by making appropriate markings in the 21 margins). 22 (b) fortestimony given in depositions that the Designating Party identify the 23 Disclosure or Discovery Material on the record, before the close of the deposition all 24 protected testimony. 25 (c) for information produced in some form other than documentary, and for 26 any other tangible items (including but not limited to information produced on disc or 27 electronic data storage device), that the Producing Party affix in a prominent place on 28 the exterior of the container or containers in which the information or item is stored

1 the legend “CONFIDENTIAL.” If only portions of the information or item warrant 2 protection, the Producing Party, to the extent practicable, shall identify the protected 3 portions, specifying the material as “CONFIDENTIAL.” 4 5.3. Inadvertent Failures to Designate. If timely corrected (preferably, 5 though not necessarily, within 30 days of production or disclosure of such material), 6 [an inadvertent failure to designate qualified information or items as 7 “CONFIDENTIAL” does not, standing alone, waive the Designating Party’s right to 8 secure protection under this Stipulation and its associated Order for such material. 9 If material is appropriately designated as “CONFIDENTIAL” after the material 10 was initially produced, the Receiving Party, on timely notification of the designation, 2 11 || must make reasonable efforts to assure that the material is treated in accordance with 2 this Stipulation and its associated Order. 13 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS. 14 6.1. Timing of Challenges. Any Party or Non-Party may challenge a 15 designation of confidentiality at any time that is consistent with the Court's 16 Scheduling Order. 17 6.2. Meet_and Confer. The Challenging Party shall initiate the dispute 18 resolution process under Local Rule 37.1 et seq. 19 6.3. The burden of persuasion in any such challenge proceeding shall be on 20 the Designating Party. Frivolous challenges, and those made for an improper purpose 21 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 22 expose the Challenging Party to sanctions. Unless the Designating Party has waived 23 □□ □□ withdrawn the confidentiality designation, all parties shall continue to afford the 24 material in question the level of protection to which it is entitled under the Producing 25 Party’s designation until the Court rules on the challenge. 26 6.4. Withdrawal of “CONFIDENTIAL” Designation. At its discretion, a 27 Designating Party may remove Protected Material/Confidential Documents from 28 some or all of the protections and provisions of this Stipulation and its associated

1 Order at any time by any of the following methods: 2 (a) Express Written Withdrawal. A Designating Party may withdraw a 3 “CONFIDENTIAL” designation made to any specified Protected Material 4 /Confidential Documents from some or all of the protections of this Stipulation and 5 its associated Order by an express withdrawal in a writing signed by such Party (or 6 such Party’s Counsel, but not including staff of such Counsel) that specifies and 7 itemizes the Disclosure or Discovery Material previously designated as Protected 8 Material/Confidential Documents that shall no longer be subject to all or some of the 9 provisions of this Stipulation and Order. Such express withdrawal shall be effective when transmitted or served upon the Receiving Party. If a Designating Party is 2 11 || withdrawing Protected Material from only some of the provisions/ protections of this x 12 || Stipulation and Order, such Party must state which specific provisions are no longer 13 to be enforced as to the specified material for which confidentiality protection S$ 14||hereunder is withdrawn: otherwise, such withdrawal shall be construed as a 15 withdrawal of such material from all of the protections/provisions of this Stipulation 16 and Order; 17 (b) Express Withdrawal on the Record. A Designating Party may withdraw 18]}a “CONFIDENTIAL” designation made to any _ specified Protected 19 Material/Confidential Documents from all of the provisions/protections of this 20 Stipulation and its associated Order by verbally consenting in court proceedings on 21 the record to such withdrawal — provided that such withdrawal specifies the 22 Disclosure or Discovery Material previously designated as Protected Material/ 23 Confidential Documents that shall no longer be subject to any of the provisions of this 24 Stipulation and Order. A Designating Party 1s not permitted to withdraw Protected 25 Material from only some of the protections/provisions of this Stipulation and Order 26 by this method; 27 (c) Implicit Withdrawal by Publication or Failure to Oppose Challenge. A 28 Designating Party shall be construed to have withdrawn a “CONFIDENTIAL”

1 designation made to any specified Protected Material/Confidential Documents from 2 all of the provisions/protections of this Stipulation and Order by either (1) making 3 such Protected Material/Confidential Records part of the public record — including 4 but not limited to attaching such as exhibits to any filing with the court without 5 moving, prior to such filing, for the court to seal such records; or (2) failing to timely 6 oppose a Challenging Party’s motion to remove a “CONFIDENTIAL” designation to 7 specified Protected Material/Confidential Documents. Nothing in this Stipulation and 8 Order shall be construed so as to require any Party to file Protected 9 Material/Confidential Documents under seal, unless expressly specified herein. 10 7. ACCESS TO AND USE OF PROTECTED MATERIAL. 2 11 7.1. Basic Principles. A Receiving Party may use Protected Material that is 12 /disclosed or produced by another Party or by a non-party in connection with this case 13 only for preparing, prosecuting, defending, or attempting to settle this litigation — up to and including final disposition of the above-entitled action — and not for any other 15 purpose, including any other litigation or dispute outside the scope of this action. 16 Such Protected Material may be disclosed only to the categories of persons and under 17 the conditions described in this Stipulation and its associated Order. When the above 18 entitled litigation has been terminated, a Receiving Party must comply with the 19 provisions of section 13, below (FINAL DISPOSITION). 20 Protected Material must be stored and maintained by a Receiving Party at a 21 location and in a secure manner that ensures that access is limited to the persons 22 authorized under this Stipulation and its Order. 23 7.2. Disclosure of “CONFIDENTIAL” Information or Items. Unless 24 otherwise ordered by the Court or permitted in writing by the Designating Party, a 25 Receiving Party may disclose any information or item designated CONFIDENTIAL 26 only to: 27 (a) the Receiving Party’s Outside Counsel of record in this action, as well 28 as employees of such Counsel to whom it is reasonably necessary to disclose the

1 information for this litigation; 2 (b) the Receiving Party and the officers, directors, and employees (including 3 House Counsel) of the Receiving Party to whom disclosure is reasonably necessary 4 for this litigation — each of whom, by accepting receipt of such Protected Material, 5 thereby agree to be bound by this Stipulation and Order; 6 (c) Experts (as defined in this Stipulation and Order) of the Receiving Party 7 to whom disclosure is reasonably necessary for this litigation — each of whom, by 8 accepting receipt of such Protected Material, thereby agree to be bound by this 9 Stipulation and Order; 10 (d) court reporters, their staffs, and Professional Vendors to whom 2 11 || disclosure is reasonably necessary for this litigation — each of whom, by accepting x 12 || receipt of such Protected Material, thereby agree to be bound by this Stipulation and 13 Order; S$ 14 (e) during their depositions, witnesses in the action to whom disclosure is 15 reasonably necessary — each of whom, by accepting receipt of such Protected Material, thereby agree to be bound by this Stipulation and Order. Pages of 17 transcribed deposition testimony or exhibits to depositions that reveal Protected 18 Material must have a confidential designation affixed by the court reporter to such 19 pages containing Protected Material and such may not be disclosed to anyone except 20 as permitted under this Stipulation and its Protective Order. 21 (f) the author or custodian of a document containing the information that 22 constitutes Protected Material, or other person who otherwise possessed or knew the 23 information. 24 (g) any mediator or settlement officer, and their supporting personnel, 25 mutually agreed upon by any of the parties engaged in settlement discussions. 26 7.3. Notice of Confidentiality. Prior to producing or disclosing Protected 27 Material/Confidential Documents to persons to whom this Stipulation and its Order 28 permits disclosure or production (see section 8.2, supra), a Receiving Party shall

1 provide a copy of this Stipulation and Order to such persons so as to put such persons 2 on notice as to the restrictions imposed upon them herein: except that, for court 3 reporters, Professional Vendors, and for witnesses being provided with Protected 4 Material during a deposition, it shall be sufficient notice for Counsel for the Receiving 5 Party to give the witness a verbal admonition (on the record, for witnesses) regarding 6 the provisions of this Stipulation and its Order and such provisions’ applicability to 7 specified Protected Material at issue. 8 7.4. Reservation of Rights. Nothing in this Stipulation and Order shall be 9 construed so as to require any Producing Party to designate any records or materials 10 }as “CONFIDENTIAL.” Nothing in this Stipulation and Order shall be construed so 2 to prevent the admission of Protected Material into evidence at the trial of this x 12 || action, or in any appellate proceedings for this action, solely on the basis that such 13 Disclosure or Discovery Material has been designated as _ Protected 14 Material/Confidential Documents. Notwithstanding the foregoing, nothing in this 15 Stipulation and Order shall be construed as a waiver of any privileges or of any rights to object to the use or admission into evidence of any Protected Material in any 17 proceeding; nor shall anything herein be construed as a concession that any privileges 18 asserted or objections made are valid or applicable. Nothing in this Stipulation and Order shall be construed so as to prevent the Designating Party (or its Counsel or 20 custodian of records) from having access to and using Protected Material designated 21 by that Party in the manner in which such persons or entities would typically use such 22 materials in the normal course of their duties or profession — except that the waiver of 23 confidentiality provisions shall apply (see section 6.4(c), supra). 24 7.5. Requirement to File Confidential Documents Under Seal. “Any party 25 seeking to file materials designated ‘CONFIDENTIAL’ must comply with Civil 26 Local Rule 79-5. No document shall be filed under seal absent a court order granting 27 such relief upon a showing of compelling reasons (for merits-related filings) or good 28 cause (for discovery materials). Designation alone does not justify sealing.” If any

1 Receiving Party attaches any Confidential Documents to any pleading, motion, or 2 other paper to be filed, lodged, or otherwise submitted to the Court, such Confidential 3 Document(s) shall be filed/lodged under seal pursuant to Federal Rules of Civil 4 Procedure 5.2 and 26 and/or United States District Court, Central District of 5 California Local Rules 79-5.1 and 79-5.2 to the extent applicable. 6 7 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER LITIGATION.

9 If a Party is served with a subpoena or a court order issued in other litigation 10 that compels disclosure of any information or items designated in this action as 11]/“CONFIDENTIAL,” that Party must: x 12 (a) promptly notify in writing the Designating Party, preferably (though not 13 necessarily) by facsimile or electronic mail. Such notification shall include a copy of 14 the subpoena or court order at issue; 15 (b) promptly notify in writing the party who caused the subpoena or order to 16 issue in the other litigation that some or all of the material covered by the subpoena 17 or order is subject to this Stipulation and its Protective Order. Such notification shall 18 include a copy of this Stipulation and its Protective Order; and 19 (c) cooperate with respect to all reasonable procedures sought to be pursued 20 by all sides in any such situation, while adhering to the terms of this Stipulation and 21 }its Order. 22 If the Designating Party timely seeks a protective order, the Party served with 23 the subpoena or court order shall not produce any information designated in this action 24 as “CONFIDENTIAL” before a determination by the court from which the subpoena 25 or order issued, unless the Party has obtained the Designating Party’s permission. The 26 Designating Party shall bear the burden and expense of seeking protection in that court 27 of its confidential material — and nothing in these provisions should be construed as 28 authorizing or encouraging a Receiving Party in this action to disobey a lawful

1 directive from another court. 2 The purpose of this section 1s to ensure that the affected Party has a meaningful 3 opportunity to preserve its confidentiality interests in the court from which the 4 subpoena or court order issued. “Nothing in this section authorizes or requires a party 5 to disobey a lawful order of another court. The Receiving Party may comply with 6 such orders after providing notice and an opportunity to seek protection, as required 7 by Rule 45.” 8/19. A NON-PARTY’S PROTECTED MATERIAL SOUGHT □□ □□ (a) The terms of this Order are applicable to information produced by a Non- Party in this Action and designated as “CONFIDENTIAL.” Such information <= produced by Non-Parties in connection with this litigation is protected by the © 3 remedies and relief provided by this Order. Nothing in these provisions should be 14 construed as prohibiting a Non-Party from seeking additional protections. < 15 (b) In the event that a Party is required, by a valid discovery request, to produce a Non-Party’s confidential information in its possession, and the Party is subject to an agreement with the Non-Party not to produce the Non-Party’s confidential information, then the Party shall: (1) promptly notify in writing the Requesting Party and the Non-Party that some or all of the information requested is subject to a confidentiality agreement with a Non-Party; (2) promptly provide the Non-Party with a copy of the Stipulated Protective Order in this Action, the relevant discovery request(s), and a reasonably specific description of the information requested; and 25 (3) make the information requested available for inspection by the Non-Party, if requested. 38 (c) “Ifthe Non-Party fails to seek protection within 7 days of notice, the Receiving

1 Party may produce the information. This timeframe is shortened to avoid undue delay 2 in discovery.” If the Non-Party timely seeks a protective order, the Receiving Party 3 shall not produce any information in its possession or control that is subject to the 4 confidentiality agreement with the Non-Party before a determination by the court. 5 Absent a court order to the contrary, the Non-Party shall bear the burden and expense 6 of seeking protection in this court of its Protected Material. 710. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL. 8 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 9 Protected Material to any person or in any circumstance not authorized under this 10 Stipulation and Order, the Receiving Party must immediately: 2 11 (a) notify in writing the Designating Party of the unauthorized disclosures; 2 (b) use its best efforts to retrieve all copies of the Protected Material; 13 (c) inform the person or persons to whom unauthorized disclosures were made Ss 14 || of all the terms of this Order; and 15 (d) request such person or persons consent to be bound by the Stipulation and 16 Order. 17 11. Inadvertent Production of Privileged or Otherwise Protected Material. 18 When a Producing Party gives notice to Receiving Parties that certain 19 inadvertently produced material is subject to a claim of privilege or other protection, 20 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 21 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 22 may be established in an e-discovery order that provides for production without prior 23 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 24 parties reach an agreement on the effect of disclosure of a communication or 25 information covered by the attorney-client privilege or work product protection, the 26 parties may incorporate their agreement in the stipulated protective order submitted 27 to the court. 28

1 }12. MISCELLANEOUS 2 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 3 person to seek its modification by the Court in the future. 4 12.2 Right to Assert Other Objections. By stipulating to the entry of this 5 Protective Order no Party waives any right it otherwise would have to object to 6 disclosing or producing any information or item on any ground not addressed in this 7 Stipulated Protective Order. Similarly, no Party waives any right to object on any 8 ground to use in evidence of any of the material covered by this Protective Order. 9 12.3 Filing Protected Material. A Party that seeks to file under seal any 10 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 2 11 || only be filed under seal pursuant to a court order authorizing the sealing of the specific x 12 || Protected Material at issue. If a Party's request to file Protected Material under seal is 13 denied by the court, then the Receiving Party may file the information in the public S$ 14 || record unless otherwise instructed by the court. 15 }13. FINAL DISPOSITION. 16 “Unless otherwise ordered, within 60 days after termination of this action each 17 Receiving Party must return or destroy Protected Material, except that counsel may 18 retain archival copies of pleadings, exhibits, deposition transcripts, correspondence, 19 and attorney work product as required by the California Rules of Professional 20 Conduct and federal law. Such archival materials remain subject to this Order.” 21 As used in this subdivision, “all Protected Material” includes all copies, 22 abstracts, compilations, summaries or any other form of reproducing or capturing any 23 of the Protected Material, regardless of the medium (hardcopy, electronic, or 24 otherwise) in which such Protected Material is stored or retained. 25 In the alternative, at the discretion of the Receiving Party, the Receiving Party 26 may destroy some or all of the Protected Material instead of returning it — unless such 27 Protected Material is an original, in which case, the Receiving Party must obtain the 28 Producing Party’s written consent before destroying such original Protected Material.

1 Whether the Protected Material is returned or destroyed, the Receiving Party 2 must submit a written certification to the Producing Party (and, if not the same person 3 /or entity, to the Designating Party) within sixty (60) days of the aforementioned written request by the Designating Party that specifically identifies (by category, 5 where appropriate) all the Protected Material that was returned or destroyed and that 6 affirms that the Receiving Party has not retained any copies, abstracts, compilations, 7 summaries or other forms of reproducing or capturing any of the Protected material 8 (Gn any medium, including but not limited to any hardcopy, electronic or digital copy, 9 or otherwise). 10 Notwithstanding this provision, Counsel are entitled to retain an archival copy 2 11 || of all pleadings, motion papers, transcripts, legal memoranda filed with the court in x 12 ||this action, as well as any correspondence or attorney work product prepared by 13 Counsel for the Receiving Party, even if such materials contain Protected Material; S$ 14 || however, any such archival copies that contain or constitute Protected Material remain 15 subject to this Protective Order as set forth in Section 4 (DURATION), above. 16 “Any violation of this Order may be addressed by the Court in accordance with 17 the Federal Rules of Civil Procedure, the Court’s inherent authority, and applicable 18 law. Sanctions, if any, shall be limited to those authorized under FRCP 37 and related 19 authority.” 20 DATED: August 13, 2025 MANNING & KASS 73 ELLROD, RAMIREZ, TRESTER LLP By: /s/ Kayleigh A. Andersen 5 Eugene P. Ramirez Eugene P. Hanrahan 26 Kayleigh A. Andersen 07 Attorneys for Defendants SHERIFF CHAD BIANCO, et al. 28

1 }; DATED: August 13, 2025 KHASHAN LAW FIRM, APC 2 By: /s/ Lewis G. Khashan 3 Lewis G. Khashan 4 Attorneys for Plaintiffs 5 6 7 9 10 < 11 — 12 2 13 S 14 Ss 16

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3 I, [print or type full 4 name], of [print or type full address], declare 5 under penalty of perjury that I have read in its entirety and understand the Stipulated 6 Protective Order that was issued by the United States District Court for the Central 7 District of California on [date] inthe caseof Dezarae Munoz, et al. v. 8 County of Riverside, et al., Case No. 5:23-cv-02063-JGB-DTB. I agree to comply 9 with and to be bound by all the terms of this Stipulated Protective Order and I 10 understand and acknowledge that failure to so comply could expose me to sanctions 2 11 || and punishment in the nature of contempt. I solemnly promise that I will not disclose x 12 ||in any manner any information or item that is subject to this Stipulated Protective 13 Order to any person or entity except in strict compliance with the provisions of this S$ 14 || Order. 15 I further agree to submit to the jurisdiction of the United States District Court 16 for the Central 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. I hereby appoint [print 19 or type full name] of [print or type 20 full address and telephone number] as my California agent for service of process 21 in connection with this action or any proceedings related to enforcement of this 22 Stipulated Protective Order. 23 Date: 24 City and State where sworn and signed: 25 Printed name: 26 Signature: 27 28

3 4 DATED: August 27, 2025 5

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8 HON.DAVIDT.BRISTOW ————CS 9 United States Magistrate Judge 10 11

2B 14

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