Dominique Ware v. City of Los Angeles

• Court: District Court, C.D. California
• Decided: January 31, 2023
• Docket: 2:21-cv-06237
• Status: Unknown

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 10 E PRIDE LAW FIRM 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 19 SEAL 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 24 PRODUCED IN OTHER LITIGATION 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 24 PROTECTED MATERIAL 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 19 ZACHARY I. AVINA 20 Attorneys for Plaintiff DOMINIQUE WARE 21 HURRELL CANTRALL LLP 2? By: /s/ Tasha T. Salveron THOMAS C. HURRELL 23 FARID SHARABY 24 TASHA T. SALVERON Attorneys for Defendant, CITY OF LOS 25 ANGELES 26 27 28

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1 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 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” 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 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