Dominique Ware v. City of Los Angeles

Opinion

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1 Thomas C. Hurrell, State Bar No. 119876 E-Mail: te ee oeeen 2 Farid Sharaby, State Bar No. 278259 E-Mail: fsharaby@hurrellcantrall.com 3 Tasha T. Salveron, State Bar No. 336596 E-Mail: tsalveron@hurrelleantrall.com 4 HURRELL CAN LL LLP 725 8. Bagucrag Street, Suite 3800 5 Los Angeles, California 90017 Telephone: 13) 426-2000 6 Facsimile: (213) 426-2020 7 Attorneys for Defendant, CITY OF LOS ANGELES 8 DANTE T. PRIDE (SBN 262362) Conde@oncelaw inn com 9 ZAC Y I. AVINA (SBN 325460) SpE endian Ament 2831 Camino Del Rio S., Ste. 104 , 11 || San Diego, CA 92108 So Tel: 619-516-8166 es 12 || Fax: 619-785-3414 Hess 13/||Attorneys for Plaintiff DOMINIQUE WARE Fabs ats 14 UNITED STATES DISTRICT COURT UO gu8 4 baer 15 CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION 2 16 17 DOMINIQUE WARE, an individual, Case No. 2:21-cv-06237 CAS (AGRx) 18 Plaintiff, DISCOVERY MATTER 19 v. STIPULATED [PROPOSED} PROTECTIVE ORDER 20 CITY OF LOS ANGELES; and DOES 1-25, inclusive; Judge: Hon. Alicia G. Rosenberg 21 Crtrm.: 550 Defendant. Be | eres □□□ to Judge Christina A. Snyder, ourtroom “apy 23 Trial Date: Mav 2. 2023 24 25 1. PURPOSE AND LIMITATIONS 26 Discovery in this action is likely to involve production of confidential or private 27 information for which special protection from public disclosure and from use for any 28 purpose other than prosecuting this action may be warranted. Accordingly, the parties

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1 hereby stipulate to and petition the Court to enter the following [Proposed] Stipulated 2 Protective Order (hereafter “this Order”). The parties acknowledge that this Order 3 does not confer blanket protections on all disclosures or responses to discovery; and 4 that the protection it affords from public disclosure and use extends only to the limited 5 information or items that are entitled to confidential treatment under the applicable 6 legal principles. 7\\2. GOOD CAUSE STATEMENT 8 This action is likely to involve confidential information pertaining to personnel 9 records and other materials subject to privacy protections for which special protection 10 from public disclosure and from use for any purpose other than prosecution of this a 11 || action is warranted. Limiting disclosure of these documents to the context of this ee 12 || litigation as provided herein will, accordingly, further important law enforcement 3 235 13 || objectives and interests, including the safety of personnel and the public, as well as Z pee 14 || the privacy rights of plaintiff, the individual defendants, and third party witnesses. 3 ae 15 || Such confidential materials and information consists of, among other things, materials sa 16 || entitled to privileges and/or protections under the following: the United States ° 17 || Constitution, First Amendment; the California Constitution, Article I, Section 1; 18 California Penal Code 8§ 832.5, 832.7, and 832.8; California Evidence Code §§ 1040 19 and 1043, et seqg.; the Privacy Act of 1974, 5 U.S.C. § 552a; Health Insurance 20 Portability and Accountability Act of 1996 (HIPAA), Public Law 104-191, decisional 21 law relating to such provisions; and information otherwise generally unavailable to 22 the public; or which may be privileged or otherwise protected from disclosure under 23 state or federal statutes, court rules, case decisions, or common law. Defendants also 24 contend that such confidential materials and information consists of materials entitled 25 to the Official Information Privilege. 26 Confidential information with respect to the Defendant may include: personnel 27 files; internal investigative files and documents; email and written correspondence 28 records; and policies and procedures that are kept from the public in the ordinary

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1 course of business, as well as other items subject to the Official Information Privilege 2 and other privileges. Confidential information with respect to the Plaintiff may 3 /include: employment and financial records; email and written correspondence 4 records; and psychological notes, evaluations, and report and treatment plans relating 5 to the treatment, care, and evaluation of the Plaintiff. 6 The parties reserve the right to challenge a designation of confidentiality 7 pursuant to the terms set forth under Paragraph 8 of this Order. 8 Accordingly, to expedite the flow of information; to facilitate the prompt 9 resolution of disputes over confidentiality of discovery materials; to adequately 10 protect information the parties are entitled to keep confidential; to ensure that the 11 parties are permitted to reasonably use such material in preparation for and in conduct ae 12 || of trial; to address their handling at the end of the litigation; and serve the ends of ase 13 || justice, a protective order for such information is justified in this matter. It is the 2 B58 14 || intent of the parties that information will not be designated as confidential for tactical 2 ue 15 || reasons and that nothing be so designated without a good faith belief that it has been oe 16 || maintained in a confidential, non-public manner; and there is good cause why it ~ ° 17 || should not be part of the public record of this case. 18 /}3. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER 20 The parties further acknowledge, as set forth in Section 14.3, below, that this 21 Order does not entitle them to file confidential information under seal; Local Civil 22 Rule 79-5 sets forth the procedures that must be followed and the standards that will 23 be applied when a party seeks permission from the court to file material under seal. 24 There is a strong presumption that the public has a right of access to judicial 25 proceedings and records in civil cases. In connection with non-dispositive motions, 26 good cause must be shown to support a filing under seal. See Kamakana v. City and 27 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors 28 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc.,

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1 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require good 2 cause showing, and a specific showing of good cause or compelling reasons with 3 proper evidentiary support and legal justification, must be made with respect to 4 material that a party seeks to file under seal). The parties’ mere designation of 5 material as “CONFIDENTIAL” does not— without the submission of competent 6 evidence by declaration, establishing that the material sought to be filed under seal 7 qualifies as confidential, privileged, or otherwise protectable—constitute good cause. 8 Further, if a party requests sealing related to dispositive motion or trial, then 9 compelling reasons, not only good cause, for the sealing must be shown, and the relief 10 sought shall be narrowly tailored to serve the specific interest to be protected. See ie 11 || Pintos v. Pacific Creditors Ass'n, 605 F.3d 665, 677-79 (9th Cir. 2010). 3 a 12 Any document that is not confidential, privileged, or otherwise protectable in 3 3 3 13 || its entirety will not be filed under seal if the confidential portions can be redacted. If Z ee S 14||documents can be redacted, then a redacted version for public viewing, omitting only 2 8 15 || the confidential, privileged, or otherwise protectable portions of the document, shall og 16 ||be filed. Any application that seeks to file documents under seal in their entirety = 17 || should include an explanation of why redaction is not feasible. 18/}4. DEFINITIONS 19 4.1 Action: Dominique Ware v. City of Los Angeles, et al. Case No. 2:21- 20 cv-06237 CAS (AGRx). 21 4.2 Challenging Party: a Party or Non-Party that challenges the designation 22 of information or items under this Order. 23 4.3. “CONFIDENTIAL” Information or Items: Information (regardless of 24 the medium or manner in which it is generated, stored, or maintained) or tangible 25 things that qualify for protection under Federal Rule of Civil Procedure 26(c), and as 26 specified above in the Good Cause Statement. 27 4.4 Counsel: General Counsel of Record and House Counsel (as well as 28 their support staff).

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1 4.5 Designating Party: a Party or Non-Party that designated information or 2 \/items that it produces in disclosures or in responses to discovery as 3 “CONFIDENTIAL.” 4 4.6 Disclosure or Discovery Material: all items or information, regardless 5 of the medium or manner in which it is generated, stored, or maintained (including, 6 among other things, testimony, transcripts, and tangible things), that are produced or 7 generated in disclosures or responses to discovery in this matter. 8 4.7 Expert: a person with specialized knowledge or experience in a matter 9 pertinent to the litigation who has been retained by a Party or its counsel to serve as 10 an expert witness or as a consultant in this Action. a. 11 4.8 House Counsel: attorneys who are employees of a party to this Action. Age 12 || House Counsel does not include General Counsel of Record or any other outside 3 age 13 || Counsel. Bos 6 Eas 14 4.9 Non-Party: any natural person, partnership, corporation, association or : uf 15 || other legal entity not named as a Party to this action. 68 F 16 4.10 General Counsel of Record: attorneys who are not employees of a Party - ° 17 || to this Action but are retained to represent or advise a Party to this Action and have 18 appeared in this Action on behalf of that party or are affiliated with a law firm that 19 has appeared on behalf of that Party, as well as their support staff. 20 4.11 Party: any Party to this Action, including all of its officers, directors, 21 employees, consultants, retained experts, and General Counsel of Record (and their 22 support staffs). 23 4.12 Producing Party: a Party or Non-Party that makes a Disclosure or 24 produces Discovery Material in this Action. 25 4.13. Professional Vendors: persons or entities that provide litigation support 26 jservices (e.g., photocopying, videotaping, translating, preparing exhibits or 27 demonstrations, and organizing, storing, or retrieving data in any form or medium) 28 and their employees and subcontractors.

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1 4.14 Protected Material: any Disclosure or Discovery Material that is 2 designated as “CONFIDENTIAL.” 3 4.15 Producing Party: a Party that makes a Disclosure or produces Discovery 4 Material to the Receiving Party. 5 4.15 Receiving Party: a Party that receives a Disclosure or Discovery 6 Material from a Producing Party. 715. SCOPE 8 The protections conferred by this Stipulation and Order cover not only 9 Protected Material (as defined above), but also (1) any information copied or extracted 10 from Protected Material; (2) all copies, excerpts, summaries, or compilations of A, 11 || Protected Material; and (3) any testimony, conversations, or presentations by Parties Be 12 || or their Counsel (as defined by Sections 4.8 and 4.10) that might reveal Protected S422 13 ||Material. Z Bug 14 Any use of Protected Material at trial shall be governed by the orders of the 2 pus 15 || trial judge. This Order does not govern the use of Protected Material at trial. zs! 16|6. DURATION ° 17 Even after final disposition of this litigation, the confidentiality obligations 18 imposed by this Order shall remain in effect until a Designating Party agrees 19 otherwise in writing or a court order otherwise directs. Final disposition shall be 20 deemed to be the later of (1) dismissal of all claims and defenses in this Action, with 21 or without prejudice; and (2) final judgment herein after the completion and 22 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 23 including the time limits for filing any motions or applications for extension of time 24 pursuant to applicable law. 25 7. DESIGNATING PROTECTED MATERIAL 26 7.1 Exercise of Restraint and Care in Designating Material for Protection. 27 Each Party or Non-Party that designates information or items for protection under 28 this Order must take care to limit any such designation to specific material that

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1 qualifies under the appropriate standards. The Designating Party must designate for 2 protection only those parts of material, documents, items or oral or written 3 communications that qualify so that other portions of the material, documents, items 4 or communications for which protection is not warranted are not swept unjustifiably 5 within the ambit of this Order. 6 Mass, indiscriminate, or routinized designations are prohibited. Designations 7\|that are shown to be clearly unjustified or that have been made for an improper 8 purpose (e.g., to unnecessarily encumber the case development process or to impose 9 unnecessary expenses and burdens on other parties) may expose the Designating Party 10 to sanctions. 11 If it comes to a Designating Party’s attention that information or items that it eb 12 || designated for protection do not qualify for protection, that Designating Party must 3 3g 13 || promptly notify all other Parties that it is withdrawing the inapplicable designation. z poe 14 7.2 Manner and Timing of Designations. Except as otherwise provided in all 15 || this Order (see, e.g., second paragraph of section 7.2(a) below), or as otherwise a age 16 || stipulated or ordered, Disclosure or Discovery Material that qualifies for protection ° 17 || under this Order must be clearly so designated before the material is disclosed or 18 produced. 19 Designation in conformity with this Order requires: 20 (a) for information in documentary form (e.g., paper or electronic 21 documents, but excluding transcripts of depositions or other pretrial or trial 22 proceedings), that the Producing Party affix at a minimum, the legend 23 “ “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 24 contains protected material. If only a portion of the material on a page qualifies for 25 protection, the Producing Party also must clearly identify the protected portion(s) 26 (e.g., by making appropriate markings in the margins). 27 A Party or Non-Party that makes original documents available for inspection 28 need not designate them for protection until after the inspecting Party has indicated

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1 which documents it would like copied and produced. During the inspection and before 2 the designation, all of the materials made available for inspection shall be deemed 3 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 4 copied and produced, the Producing Party must determine which documents, or 5 portions thereof, qualify for protection under this Order. Then, before producing the 6 specified documents, the Producing Party must affix the “CONFIDENTIAL legend” 7 to each page that contains Protected Material. If only a portion of the material on a 8 page qualifies for protection, the Producing Party also must clearly identify the 9 protected portion(s) (e.g., by making appropriate markings in the margins). 10 (b) for testimony given in depositions that the Designating Party identifies x; 11 || the Disclosure or Discovery Material on the record, and before the close of the : ib 12 || deposition all protected testimony. a Bee 13 (c) for information produced in some form other than documentary and for z P58 14 || any other tangible items, that the Producing Party affix in a prominent place on the 2 He 15 || exterior of the container or containers in which the information is stored the legend oa 16 ||“CONFIDENTIAL.” If only a portion or portions of the information warrants = ° 17 || protection, the Producing Party, to the extent practicable, shall identify the protected 18 portion(s). 19 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 20 failure to designate qualified information or items does not, standing alone, waive the 21 Designating Party’s right to secure protection under this Order for such material. 22 Upon timely correction of a designation, the Receiving Party must make reasonable 23 efforts to assure that the material is treated in accordance with the provisions of this 24 Order. 25 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS 26 8.1 Timing of Challenges. Any Party or Non-Party may challenge a 27 designation of confidentiality at any time that is consistent with the Court’s 28 Scheduling Order.

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1 8.2 Meet Confer. The Challenging Party shall initiate the meet and 2 confer process outlined in Local Rule 37.1, et seq. 3 8.3 Burden Persuasion. The burden of persuasion, in any such 4 challenge proceeding, shall be on the Designating Party. Frivolous challenges, and 5 those made for an improper purpose (e.g., to harass or impose unnecessary expenses 6 and burdens on other parties) may expose the Challenging Party to sanctions. Unless 7 \\the Designating Party has waived or withdrawn the confidentiality designation, all 8 parties shall continue to afford the material in question the level of protection to which 9 it is entitled under the Producing Party’s designation until the Court rules on the 10 challenge. ‘i, 11/9. ACCESS TO AND USE OF PROTECTED MATERIAL = Be , 2 9.1 Basic Principles. A Receiving Party may use Protected Material that is 3 238 13 || disclosed or produced by another Party or by a Non-Party in connection with this □□ 14 || Action only for prosecuting, defending or attempting to settle this Action. Such 2 ae 15 || Protected Material may be disclosed only to the categories of persons and under the 4 mg □ conditions described in this Order. When the Action has been terminated, a Receiving - ° 17 || Party must comply with the provisions of Section VI, infra. 18 Protected Material must be stored and maintained by a Receiving Party at a 19 location and in a secure manner that ensures that access is limited to the persons 20 authorized under this Order. 21 9.2 Disclosure of “CONFIDENTIAL” Information or Jtems. Unless 22 otherwise ordered by the Court or permitted in writing by the Designating Party, a 23 Receiving Party may disclose any information or item designated 24 “CONFIDENTIAL” only to: 25 (a) the Receiving Party’s General Counsel of Record in this Action, as well 26 as employees of said General Counsel of Record to whom it is reasonably necessary 27 to disclose the information for this Action; 28 (b) the officers, directors, and employees (including House Counsel) of the

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1 Receiving Party to whom disclosure is reasonably necessary for this Action; 2 (c) Experts (as defined in this Order) of the Receiving Party to whom 3 disclosure is reasonably necessary for this Action and who have signed the 4 “Acknowledgment and Agreement to Be Bound,” attached and hereafter referred to 5 as “Exhibit A.” 6 (d) the court and its personnel; 7 (e) court reporters and their staff; 8 (f) professional jury or trial consultants, mock jurors, and Professional 9 Vendors to whom disclosure is reasonably necessary for this Action and who have 10 signed Exhibit A; si, 11 (g) the author or recipient of a document containing the information or a 3 □□ _,_12||custodian or other person who otherwise possessed or knew the information, 4 238 13 (h) during their depositions, witnesses, and attorneys for witnesses, in the Z pee 14 || Action to whom disclosure is reasonably necessary provided: (1) the deposing party 2 eae 15 || requests that the witness sign Exhibit A; and (2) they will not be permitted to keep wea 16 /any confidential information unless they sign Exhibit A, unless otherwise agreed by ° 17||the Designating Party or ordered by the Court. Pages of transcribed deposition 18 testimony or exhibits to depositions that reveal Protected Material may be separately 19 bound by the court reporter and may not be disclosed to anyone except as permitted 20 under this Order; and Zi (1) any mediator or settlement officer, and their supporting personnel, 22 mutually agreed upon by any of the parties engaged in settlement discussions. 23 10. PROTECTED MATERIAL □ SUBPOENAED OR _ ORDERED 25 If a Party is served with a subpoena or a court order issued in other litigation 26 that compels disclosure of any information or items designated in this Action as 27 ““CONFIDENTIAL,” that Party must: 28 (a) promptly notify in writing the Designating Party. Such notification shall

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1 include a copy of the subpoena or court order; 2 (b) promptly notify in writing the party who caused the subpoena or order to 3 issue in the other litigation that some or all of the material covered by the subpoena 4 or order is subject to this Order. Such notification shall include a copy of this Order; 5 and; 6 (c) cooperate with respect to all reasonable procedures sought to be pursued by 7 the Designating Party whose Protected Material may be affected. 8 If the Designating Party timely seeks a protective order, the Party served with 9 the subpoena or court order shall not produce any information designated in this action 10 as “CONFIDENTIAL” before a determination by the Court from which the subpoena as 11 || or order issued, unless the Party has obtained the Designating Party’s permission. The : as 12 || Designating Party shall bear the burden and expense of seeking protection in that court ae se 13 || of its confidential material and nothing in these provisions should be construed as z HE 14 || authorizing or encouraging a Receiving Party in this Action to disobey a lawful 2 ae 15 || directive from another court. 4 sae 16||11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE ~ ° 17 PRODUCED IN THIS LITIGATION 18 (a) The terms of this Order are applicable to information produced by a Non- 19 Party in this Action and designated as “CONFIDENTIAL.” Such information 20 produced by Non-Parties in connection with this litigation is protected by the 21 remedies and relief provided by this Order. Nothing in these provisions should be 22 construed as prohibiting a Non-Party from seeking additional protections. 23 (b) In the event that a Party is required, by a valid discovery request, to 24 produce a Non-Party’s confidential information in its possession, and the Party is 25 subject to an agreement with the Non-Party not to produce the Non-Party’s 26 confidential information, then the Party shall: 27 (1) promptly notify in writing the Requesting Party and the Non-Party 28 that some or all of the information requested is subject to a confidentiality agreement

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1 with a Non-Party; 2 (2) promptly provide the Non-Party with a copy of this Order in this 3 Action, the relevant discovery request(s), and a reasonably specific description of the 4 information requested; and 5 (3) make the information requested available for inspection by the Non- 6 Party, if requested. (c) If the Non-Party fails to seek a protective order from this Court within 8 fourteen (14) days of receiving the notice and accompanying information, the 9 Receiving Party may produce the Non-Party’s confidential information responsive to 10 the discovery request. If the Non-Party timely seeks a protective order, the Receiving a 11 || Party shall not produce any information in its possession or control that is subject to 4 5 SO 12 || the confidentiality agreement with the Non-Party before a determination by the Court. 3 ass 13 || Absent a court order to the contrary, the Non-Party shall bear the burden and expense Z pag 14 || of seeking protection in this Court of its Protected Material. 2 eis 15|)12. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL a 16 Ifa Receiving Party learns that, by inadvertence or otherwise, it has disclosed 17 Protected Material to any person or in any circumstance not authorized under this 18 Order, the Receiving Party must immediately (a) notify in writing the Designating 19 Party of the unauthorized disclosures; (b) use its best efforts to retrieve all 20 unauthorized copies of the Protected Material; (c) inform the person or persons to 21 whom unauthorized disclosures were made of all the terms of this Order; and (d) 22 request such person or persons to execute Exhibit A. 23 13. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE Zs When a Producing Party gives notice to Receiving Parties that certain 26 inadvertently produced material is subject to a claim of privilege or other protection, 27 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 28 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure

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1 may be established in an e-discovery order that provides for production without prior 2 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 3 Parties reach an agreement on the effect of disclosure of a communication or 4 information covered by the attorney-client privilege or work product protection, the 5 Parties may incorporate their agreement in a subsequent stipulation to the Court. 6 14. MISCELLANEOUS 14.1 Right to Further Relief. Nothing in this Order abridges the right of any 8 person to seek its modification by the Court in the future. 9 14.2 Right to Assert Other Objections. By stipulating to the entry of this 10 Order, no Party waives any right it otherwise would have to object to disclosing or a 11 || producing any information or item on any ground not addressed in this Order. Se 12 || Similarly, no Party waives any right to object on any ground to use in evidence of any 338 13 || of the material covered by this Order. 2 Hae 14 14.3 Filing Protected Material. A Party that seeks to file under seal any 2 ne 15 || Protected Material must comply with Local Civil Rule 79-5. Protected Material may es a 16 || only be filed under seal pursuant to a court order authorizing the sealing of the specific + 17 || Protected Material at issue. If a Party’s request to file Protected Material under seal 18 is denied by the Court, then the Receiving Party may file the information in the public 19 record unless otherwise instructed by the Court. 20)}15. FINAL DISPOSITION 21 After the final disposition of this Action, as defined in Section VI, supra, within 22 60 days of a written request by the Designating Party, each Receiving Party must 23 return all Protected Material to the Producing Party or destroy such material. As used 24 \in this subdivision, “all Protected Material” includes all copies, abstracts, 25 compilations, summaries, and any other format reproducing or capturing any of the 26 Protected Material. Whether the Protected Material is returned or destroyed, the 27 Receiving Party must submit a written certification to the Producing Party (and, if not 28 the same person or entity, to the Designating Party) by the 60-day deadline that (1)

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1 identifies (by category, where appropriate) all the Protected Material that was returned 2 or destroyed and (2) affirms that the Receiving Party has not retained any copies, 3 abstracts, compilations, summaries or any other format reproducing or capturing any 4 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 5 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 6 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 7 reports, attorney work product, and consultant and expert work product, even if such 8 materials contain Protected Material. Any such archival copies that contain or 9 constitute Protected Material remain subject to this Order as set forth in Section 6, 10 supra. A, 11||16. VIOLATION 4 SE 12 Any violation of this Order may be punished by appropriate measures ese 2222 13]{including, without limitation, contempt proceedings and/or monetary sanctions. lies 14 OU geez igre 15 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD: Pen □□ 16 i 17 || Dated: January 12, 2022 THE PRIDE LAW FIRM 18 By: /s/ Zachary I. Avina DANTE T. PRIDE 20 Attorneys for Plaintiff DOMINIQUE WARE 2? By: /s/ Tasha T. Salveron THOMAS C. HURRELL Attorneys for Defendant, CITY OF LOS 26 27 28

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3 Dated: January 31, 2023 Whar h Keundang, 4 Honorable Alicia G. Rosenburg 5 United States Magistrate Judge 10 11 neg 38, 12 FESS Sasi 13 E Hee zHSe 14 qige 15 a P25 meg 16 =e Hy 17 18 19 20 21 22 23 24 25 26 27 28

ID

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1 ATTACHMENT “A” 3 I; [full name], of 4 [address], declare under penalty of perjury that I have read in its entirety and 5 understand the Stipulated Protective Order that was issued by the United States 6 District Court for the Central District of California on [date] 7 in the case of Dominique Ware v. City of Los Angeles, et al., United States District 8 Court for the Central District of California, Central Division, Case No. Case No. 9 Case No. 2:21-cv-06237 CAS (AGRx). I agree to comply with and to be bound by 10 all the terms of this Stipulated Protective Order, and I understand and acknowledge wi 11 || that failure to so comply could expose me to sanctions and punishment in the nature : as 3 12 || of contempt. I solemnly promise that J will not disclose in any manner any 2 ase 13 || information or item that is subject to this Stipulated Protective Order to any person Z bes 14 || or entity except in strict compliance with the provisions of this Stipulated Protective 2 eae 15 || Order. oat 16 I further agree to submit to the jurisdiction of the United States District Court = ° 17 || for the Central District of California for the purpose of enforcing the terms of this 18 Stipulated Protective Order, even if such enforcement proceedings occur after 19 termination of this action. I hereby appoint [full name] 20 of {address and telephone number] 21 )as my California agent for service of process in connection with this action or any 22 proceedings related to enforcement of this Stipulated Protective Order. 23 24 Signature: 25 Printed Name: 26 Date: = 27 City and State Where Sworn and Signed: 28