Isaiah Clifton Gaines v. City of Los Angeles

• Court: District Court, C.D. California
• Decided: June 7, 2023
• Docket: 2:21-cv-09992
• Status: Unknown

Opinion

1 HYDEE FELDSTEIN SOTO, City Attorney SCOTT MARCUS, Chief Assistant City Attorney (SBN 184980) 2 CORY M. BRENTE, Senior Assistant City Attorney (SBN 115453) SHANT TASLAKIAN, Deputy City Attorney (SBN 272485) 3 200 N. Main Street, 6th Floor, City Hall East Los Angeles, California 90012 4 Tel: (213) 978-8722 Fax: (213) 978-8785 Email: Shant.Taslakian@lacity.org 5 Attorneys for Defendants, CITY OF LOS ANGELES and LOS ANGELES POLICE 6 DEPARTMENT

7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10

11 ISAIAH CLIFTON GAINES, CASE NO. CV21-09992-AB-MRW 12 Hon. Judge Andre Birotte Jr; 1st St CH - Ctrm. 7B Hon. Magistrate Judge Michael R. Wilner 13 Plaintiff,

14 v. STIPULATED PROTECTIVE ORDER 15 (MRW VERSION 4/19)

16 CITY OF LOS ANGELES, a Check if submitted without material municipal entity, CHIEF MICHEL R. 17 modifications to MRW form MOORE, in his official Capacity as 18 Chief of Los Angeles Police Department, LOS ANGELES POLICE 19 DEPARTMENT, a municipal entity, DOE 1-4 inclusive, 20

21 Defendants. 22

24 25 1. INTRODUCTION 26 1.1 PURPOSES AND LIMITATIONS 27 Discovery in this action is likely to involve production of confidential, 28 proprietary, or private information for which special protection from public disclosure 1 |}and from use for any purpose other than prosecuting this litigation may be warranted. 2 || Accordingly, the parties hereby stipulate to and petition the Court to enter the 3 || following Stipulated Protective Order. The parties acknowledge that this Order does 4 || not confer blanket protections on all disclosures or responses to discovery and that the 5 || protection it affords from public disclosure and use extends only to the limited 6 || information or items that are entitled to confidential treatment under the applicable 7 legal principles. The parties further acknowledge, as set forth in Section 12.3, below, 8 || that this Stipulated Protective Order does not entitle them to file confidential ? || information under seal; Civil Local Rule 79-5 sets forth the procedures that must be 10 followed and the standards that will be applied when a party seeks permission from the court to file material under seal. 12 1.2 GOOD CAUSE STATEMENT 13 This action involves the City of Los Angeles and members of the Los Angeles Police Department. Plaintiff is seeking through discovery materials and information 15 that Defendants the City of Los Angeles et al. (“City”) maintains as confidential, 16 video recordings, audio recordings, and information and other administrative iM materials and information currently in the possession of the City and which the City 18 believes need special protection from public disclosure and from use for any purpose 19 other than prosecuting this litigation. 20 The City asserts that the confidentiality of the materials and information sought 1 by Plaintiff is recognized by California and federal law, as evidenced inter alia by 22 California Penal Code section 832.7 and Kerr v. United States Dist. Ct. for N.D. Cal., |! 511 F.2d 192, 198 (9th Cir. 1975), afd, 426 U.S. 394 (1976). The City has not publicly 24 released the materials and information referenced above except under protective order 25 or pursuant to a court order, if at all. 26 The City contends that absent a protective order delineating the responsibilities 27 of nondisclosure on the part of the parties hereto, there is a specific risk of unnecessary 28 and undue disclosure by one or more of the many attorneys, secretaries, law clerks,

1 paralegals and expert witnesses involved in this case, as well as the corollary risk of 2 embarrassment, harassment and professional and legal harm on the part of the LAPD 3 officers referenced in the materials and information. 4 The City also contends that the unfettered disclosure of the materials and 5 information, absent a protective order, would allow the media to share this information 6 with potential jurors in the area, impacting the rights of the City herein to receive a fair 7 trial. 8 Accordingly, to expedite the flow of information, to facilitate the prompt 9 resolution of disputes over confidentiality of discovery materials, to adequately protect 10 information the parties are entitled to keep confidential, to ensure that the parties are 11 permitted reasonable necessary uses of such material in preparation for and in the 12 conduct of trial, to address their handling at the end of the litigation, and serve the ends 13 of justice, a protective order for such information is justified in this matter. It is the 14 intent of the parties that information will not be designated as confidential for tactical 15 reasons and that nothing be so designated without a good faith belief that it has been 16 maintained in a confidential, non-public manner, and there is good cause why it should 17 not be part of the public record of this case. 18 Plaintiff agrees that there is Good Cause for a Protective Order so as to preserve 19 the respective interests of the parties while streamlining the process of resolving any 20 disagreements. 21 The parties therefore stipulate that there is Good Cause for, and hereby jointly 22 request that the honorable Court issue a Protective Order regarding confidential 23 documents consistent with the terms and provisions of this Stipulation. However, the 24 entry of a Protective Order by the Court pursuant to this Stipulation shall not be 25 construed as any ruling by the Court on the aforementioned legal statements or privilege 26 claims in this section, nor shall this section be construed as part of any such Court Order.

27 28 1 |}2. DEFINITIONS 2 2.1 Action: this pending federal law suit, entitled /saiah Clifton Gaines v. 3 || City of Los Angeles, et al., CV21-09992-AB-MRW 4 2.2. Challenging Party: a Party or Non-Party that challenges the designation 5 || of information or items under this Order. 6 2.3. “CONFIDENTIAL” Information or Items: information (regardless of 7 |Ihow it is generated, stored or maintained) or tangible things that qualify for protection 8 || under Federal Rule of Civil Procedure 26(c), and as specified above in the Good ? Cause Statement. This also includes (1) any information copied or extracted from 10 the Confidential information; (2) all copies, excerpts, summaries, abstracts or compilations of Confidential information; and (3) any testimony, conversations, or presentations that might reveal Confidential information. 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their support staff). 2.5 Designating Party: a Party or Non-Party that designates information or

7 items that it produces in disclosures or in responses to discovery as

18 “CONFIDENTIAL.” 19 2.6 Disclosure or Discovery Material: all items or information, regardless of 20 the medium or manner in which it is generated, stored, or maintained (including, 51 || among other things, testimony, transcripts, and tangible things), that are produced or 09 generated in disclosures or responses to discovery in this matter. 03 2.7 Expert: a person with specialized knowledge or experience in a matter 74 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 25 expert witness or as a consultant in this Action. 26 2.8 Final Disposition: when this Action has been fully and completely 77 || terminated by way of settlement, dismissal, trial, appeal and/or remand to state court. 28

1 2.9 House Counsel: attorneys who are employees of a party to this Action. 2 || House Counsel does not include Outside Counsel of Record or any other outside 3 || counsel. 4 2.10 Non-Party: any natural person, partnership, corporation, association, or 5 || other legal entity not named as a Party to this action. 6 2.11 Outside Counsel of Record: attorneys who are not employees of a party 7 |Ito this Action but are retained to represent or advise a party to this Action and have 8 appeared in this Action on behalf of that party or are affiliated with a law firm which ? has appeared on behalf of that party, and includes support staff. 10 2.12 Party: any party to this Action, including all of its officers, directors, employees, consultants, retained experts, and Outside Counsel of Record (and their support staffs). 3 2.13 Producing Party: a Party or Non-Party that produces Disclosure or Discovery Material in this Action. 2.14 Professional Vendors: persons or entities that provide litigation support 7 services (e.g., photocopying, videotaping, translating, preparing exhibits or

12 demonstrations, and organizing, storing, or retrieving data in any form or medium) 19 and their employees and subcontractors. 20 2.15 Protected Material: any Disclosure or Discovery Material that is designated as “CONFIDENTIAL.” 2.16 Receiving Party: a Party that receives Disclosure or Discovery Material 3 || from a Producing Party. 24 25 SCOPE 26 The protections conferred by this Stipulation and Order cover not only 27 || Protected Material (as defined above), but also (1) any information copied or 28 || extracted from Protected Material; (2) all copies, excerpts, summaries, or

1 ||compilations of Protected Material; and (3) any testimony, conversations, or 2 || presentations by Parties or their Counsel that might reveal Protected Material. 3 Any use of Protected Material at trial will be governed by the orders of the trial 4 ||judge. This Order does not govern the use of Protected Material at trial. 5|/4. | DURATION 6 Once a case proceeds to trial, all of the information that was designated as 7 || CONFIDENTIAL or maintained as such pursuant to this Protective Order becomes 8 public and will be presumptively available to all members of the public, including the ? press, unless compelling reasons supported by specific factual findings to proceed 10 otherwise are made to the trial judge in advance of the trial. See Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing 12 “good cause” showing for sealing documents produced in discovery from “compelling 3 reasons” standard when merits-related documents are part of court record). 4 Accordingly, the terms of this protective order do not extend to that Protected Material admitted into evidence beyond the commencement of the trial.

7 Even after final disposition of this Action, the confidentiality obligations 12 imposed by this Order will remain in effect as to all Protected Material that was not 19 introduced or not admitted into evidence at trial, until a Designating Party agrees 20 otherwise in writing or a court order otherwise directs. Final disposition will be deemed to be the later of (1) dismissal of all claims and defenses in this Action, with 49 without prejudice; and (2) final judgment herein after the completion and 93 || exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 74 || including the time limits for filing any motions or applications for extension of time 25 || pursuant to applicable law. 26 27 28

1 DESIGNATING 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 under this 4 || Order must take care to limit any such designation to specific material that qualifies 5 |/under the appropriate standards. The Designating Party must designate for protection 6 only those parts of material, documents, items, or oral or written communications that 7 qualify so that other portions of the material, documents, items, or communications 8 for which protection is not warranted are not swept unjustifiably within the ambit of ? this Order. 10 Mass, indiscriminate, or routinized designations are prohibited. Designations that are shown to be clearly unjustified or that have been made for an improper 12 purpose (e.g., to unnecessarily encumber the case development process or to impose IS unnecessary expenses and burdens on other parties) may expose the Designating Party to sanctions. If it comes to a Designating Party’s attention that information or items that it

7 designated for protection do not qualify for protection, that Designating Party must

12 promptly notify all other Parties that it is withdrawing the inapplicable designation. 19 5.2 Manner and Timing of Designations. Except as otherwise provided in 20 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 09 under this Order must be clearly so designated before the material is disclosed or 93 || produced. 74 Designation in conformity with this Order requires: 25 (a) for information in documentary form (e.g., paper or electronic documents, 26 || but excluding transcripts of depositions or other pretrial or trial proceedings), that the 27 || Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 28 ||““CONFIDENTIAL legend”), to each page that contains protected material. If only a

1 || portion or portions of the material on a page qualifies for protection, the Producing 2 || Party also must clearly identify the protected portion(s) (e.g., by making appropriate 3 || markings in the margins). 4 A Party or Non-Party that makes original documents available for 5 inspection need not designate them for protection until after the inspecting Party has 6 || indicated which documents it would like copied and produced. During the inspection 7 and before the designation, all of the material made available for inspection will be 8 || deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents ? it wants copied and produced, the Producing Party must determine which documents, 10 or portions thereof, qualify for protection under this Order. Then, before producing the specified documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page that contains Protected Material. If only a portion or portions of 3 the material on a page qualifies for protection, the Producing Party also must clearly identify the protected portion(s) (e.g., by making appropriate markings in the margins). (b) for testimony given in depositions that the Designating Party identify the

12 Disclosure or Discovery Material on the record, before the close of the deposition all 19 protected testimony. 20 (c) for information produced in some form other than documentary and for any other tangible items, that the Producing Party affix in a prominent place on the 09 exterior of the container or containers in which the information is stored the legend 93 || “CONFIDENTIAL.” If only a portion or portions of the information warrants 74 protection, the Producing Party, to the extent practicable, will identify the protected 25 || portion(s). 26 5.3. Inadvertent Failures to Designate. If timely corrected, an inadvertent 27 || failure to designate qualified information or items does not, standing alone, waive the 28 || Designating Party’s right to secure protection under this Order for such material.

1 Upon timely correction of a designation, the Receiving Party must make reasonable 2 || efforts to assure that the material is treated in accordance with the provisions of this 3 |] Order. 4 51/6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 6 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 7 designation of confidentiality at any time that is consistent with the Court’s 8 Scheduling Order. ? 6.2 Meet and Confer. The Challenging Party will initiate the dispute 10 resolution process (and, if necessary, file a discovery motion) under Local Rule 37.1 et seq. 6.3. The burden of persuasion in any such challenge proceeding will be on the 3 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., to harass or impose unnecessary expenses and burdens on other parties) may expose the Challenging Party to sanctions. Unless the Designating Party has waived

or withdrawn the confidentiality designation, all parties will continue to afford the

12 material in question the level of protection to which it is entitled under the Producing 19 Party’s designation until the Court rules on the challenge. 20 >, ACCESS TO AND USE OF PROTECTED MATERIAL 7.1 Basic Principles. A Receiving Party may use Protected Material that is 3 || disclosed or produced by another Party or by a Non-Party in connection with this 74 || Action only for prosecuting, defending, or attempting to settle this Action. Such 25 || Protected Material may be disclosed only to the categories of persons and under the 26 || conditions described in this Order. When this Action has been terminated, a Receiving 27 || Party must comply with the provisions of section 13 below (FINAL DISPOSITION). 28

1 Protected Material must be stored and maintained by a Receiving Party at a 2 location and in a secure manner that ensures that access is limited to the persons 3 authorized under this Order. 4 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 5 || otherwise ordered by the court or permitted in writing by the Designating Party, a 6 Receiving Party may disclose any information or item designated “CONFIDENTIAL” 7 only to: 8 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well ? employees of said Outside Counsel of Record to whom it is reasonably necessary to 10 disclose the information for this Action; (b) the officers, directors, and employees (including House Counsel) of the 12 Receiving Party to whom disclosure is reasonably necessary for this Action; IS (c) Experts (as defined in this Order) of the Receiving Party to whom 4 disclosure is reasonably necessary for this Action and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); (d) the Court and its personnel; 18 (e) court reporters and their staff; 19 (f) professional jury or trial consultants, mock jurors, and Professional 20 Vendors to whom disclosure is reasonably necessary for this Action and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); (g) the author or recipient of a document containing the information or a 93 || custodian or other person who otherwise possessed or knew the information; 74 (h) during their depositions, witnesses, and attorneys for witnesses, in the 25 || Action to whom disclosure is reasonably necessary provided: (1) the deposing party 26 || requests that the witness sign the form attached as Exhibit A hereto; and (2) they will 27 be permitted to keep any confidential information unless they sign the 28 ||““Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed 10

1 || by the Designating Party or ordered by the court. Pages of transcribed deposition 2 testimony or exhibits to depositions that reveal Protected Material may be separately 3 || bound by the court reporter and may not be disclosed to anyone except as permitted 4 || under this Stipulated Protective Order; and 5 (i) any mediator or settlement officer, and their supporting personnel, 6 mutually agreed upon by any of the parties engaged in settlement discussions and who 7 |Ihave signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A). 8 PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN ? || OTHER LITIGATION 10 If a Party is served with a subpoena or a court order issued in other litigation that compels disclosure of any information or items designated in this Action as 12 “CONFIDENTIAL,” that Party must: 3 (a) promptly notify in writing the Designating Party. Such notification will include a copy of the subpoena or court order; (b) promptly notify in writing the party who caused the subpoena or order

to issue in the other litigation that some or all of the material covered by the subpoena 12 or order is subject to this Protective Order. Such notification will include a copy of 19 this Stipulated Protective Order; and 20 (c) cooperate with respect to all reasonable procedures sought to be pursued by the Designating Party whose Protected Material may be affected. 09 If the Designating Party timely seeks a protective order, the Party served with 93 || the subpoena or court order will not produce any information designated in this action 74 |}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 will 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

1 || authorizing or encouraging a Receiving Party in this Action to disobey a lawful 2 directive from another court. 3 4 A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 5 ||PRODUCED IN THIS LITIGATION 6 (a) The terms of this Order are applicable to information produced by a 7 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 8 produced by Non-Parties in connection with this litigation is protected by the ? || remedies and relief provided by this Order. Nothing in these provisions should be 10 construed as prohibiting a Non-Party from seeking additional protections. (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 3 subject to an agreement with the Non-Party not to produce the Non-Party’s confidential information, then the Party will: (1) promptly notify in writing the Requesting Party and the Non-Party 7 that some or all of the information requested 1s subject to a confidentiality agreement 12 with a Non-Party; 19 (2) promptly provide the Non-Party with a copy of the Stipulated 20 Protective Order in this Action, the relevant discovery request(s), and a reasonably specific description of the information requested; and 09 (3) make the information requested available for inspection by the Non- 93 || Party, if requested. 74 (c) If the Non-Party fails to seek a protective order from this court within 14 25 || days of receiving the notice and accompanying information, the Receiving Party may 26 || produce the Non-Party’s confidential information responsive to the discovery request. 27 || If the Non-Party timely seeks a protective order, the Receiving Party will not produce 28 || any information in its possession or control that is subject to the confidentiality 12

1 ||agreement with the Non-Party before a determination by the court. Absent a court 2 order to the contrary, the Non-Party will bear the burden and expense of seeking 3 || protection in this court of its Protected Material. 4 5 |110. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 6 Ifa Receiving Party learns that, by inadvertence or otherwise, it has disclosed 7 || Protected Material to any person or in any circumstance not authorized under this 8 Stipulated Protective Order, the Receiving Party must immediately (a) notify in ? writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 10 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or persons to whom unauthorized disclosures were made of all the terms of this Order, 12 and (d) request such person or persons to execute the “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit A.

15 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED MATERIAL

12 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 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 99 || may be established in an e-discovery order that provides for production without prior 93 || privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 74 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 to 27 || 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. ? 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 only be filed under seal pursuant to a court order authorizing the sealing of the 12 specific Protected Material at issue. Ifa Party's request to file Protected Material 3 under seal is denied by the court, then the Receiving Party may file the information in the public record unless otherwise instructed by the court.

16 7 13. FINAL DISPOSITION

12 After the final disposition of this Action, as defined in paragraphs 2.8 and 4, 19 within 60 days of a written request by the Designating Party, each Receiving Party 20 must return all Protected Material to the Producing Party or destroy such material. As used in this subdivision, “all Protected Material” includes all copies, abstracts, || compilations, summaries, and any other format reproducing or capturing any of the 93 || Protected Material. Whether the Protected Material is returned or destroyed, the 74 || Receiving Party must submit a written certification to the Producing Party (and, if not 25 || the same person or entity, to the Designating Party) by the 60 day deadline that (1) 26 || identifies (by category, where appropriate) all the Protected Material that was returned 27 || or destroyed and (2) affirms that the Receiving Party has not retained any copies, 28 || abstracts, compilations, summaries or any other format reproducing or capturing any

1 || of the Protected Material. Notwithstanding this provision, Counsel are entitled to 2 ||retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 3 || transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 4 || reports, attorney work product, and consultant and expert work product, even if such 5 || materials contain Protected Material. Any such archival copies that contain or 6 || constitute Protected Material remain subject to this Protective Order as set forth in 7 || Section 4 (DURATION). 8 9 14. Any willful violation of this Order may be punished by civil or criminal 10 contempt proceedings, financial or evidentiary sanctions, reference to disciplinary authorities, or other appropriate action at the discretion of the Court. 12 13 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 14 15 DATED: June 5, 2023 LBD LZ 16 Attorneys for Plaintiff 17 18 DATED: _ June 6, 2023 ISl__ Shant Saslahian 9 Attorneys for Defendant 20 21 97 |, FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 23 24 _ 25 || DATED: 6/7/23 A HON. MICHAEL R. WILNER 26 United States Magistrate Judge 27 28

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 I, ISAIAH CLIFTON GAINES, of 3000 LILLARD DRIVE, APT.# 260, 5 Davis, CA 95618, declare under penalty of perjury that I have read in its entirety 6 and understand the Stipulated Protective Order that was issued by the United States 7 District Court for the Central District of California on [date] in the case of Gaines 8 vs. City of Los Angeles, et at. I agree to comply with and to be bound by all the 9 terms of this Stipulated Protective Order and I understand and acknowledge that 10 failure to so comply could expose me to sanctions and punishment in the nature of 11 contempt. I solemnly promise that I will not disclose in any manner any information 12 or item that is subject to this Stipulated Protective Order to any person or entity 13 except in strict compliance with the provisions of this Order. 14 I further agree to submit to the jurisdiction of the United States District Court 15 for the Central District of California for the purpose of enforcing the terms of this 16 Stipulated Protective Order, even if such enforcement proceedings occur after 17 termination of this action. I hereby appoint ISAIAH CLIFTON GAINES 3000 18 LILLARD DRIVE, APT.# 260, Davis, CA 95618, (949) 397-7382 as my California 19 agent for service of process in connection with this action or any proceedings related 20 to enforcement of this Stipulated Protective Order. 21 Date: JUNE 5, 2023 22 City and State where signed: LOS ANGELES, CA 23 24 Printed name: ISAIAH CLIFTON GAINES 25 26 Signature: __________________________________ 27