Keisha Morehead v. City of Oxnard

• Court: District Court, C.D. California
• Decided: April 26, 2022
• Docket: 2:21-cv-07689
• Status: Unknown

Opinion

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1 || David C. Moore, Esq. (State Bar No. 156114) 7 || Caroline M. Park, Esq. (State Bar No. 334008) COLLINS + COLLINS LLP 3 ||790 E. Colorado Boulevard, Suite 600 4 ||Pasadena, CA 91101 (626) 243-1100 — FAX (626) 243-1111 3 ||Email: dmoore@cellp.law 6 ||Email: cpark@ccllp.law 7 || Attorneys for Defendants g_ ||CITY OF OXNARD, OFFICER LEAH CASTELLANO, AND OFFICER KEVIN FESSLER 10 UNITED STATES DISTRICT COURT 11 CENTRAL DISTRICT OF CALIFORNIA 12 13 || KEISHA MOREHEAD, CASE NO. 21-cv-07689-DOC-(ADSx) [Assigned to Hon. David O. Carter — 14 Plaintiffs, Courtroom 9D] 15 [DISCOVERY MATTER] Magistrate ig Ee Judge Autumn D. Spaeth 17 ||CITY OF OXNARD, OXNARD STIPULATED PROTECTIVE ORDER POLICE DEPARTMENT; OFFICER 18 |}LEAH CASTELLANO IN HER 19 || LNDIVIDUAL AND OFFICIAL CAPACITY, OFFICER KEVIN epg,

31 || AND OFFICIAL CAPACITY: AND rial Date: one DOES 1 THROUGH 10, 22 33 Defendants. 24 25 || TO THE HONORABLE COURT: 26 |] /// 27 |W /// 28 |] /// Couns coun |) 22562 CA 91107 Fax 269-1111 r STIPULATED PROTECTIVE ORDER

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1 |]1. INTRODUCTION 2 1.1 PURPOSES AND LIMITATIONS 3 Discovery in this action is likely to involve production of confidential, proprietary, 4 lor private information for which special protection from public disclosure and from use 5 || for any purpose other than prosecuting this litigation may be warranted. Accordingly, 6 ||the parties hereby stipulate to and petition the Court to enter the following Stipulated 7 ||Protective Order. The parties acknowledge that this Order does not confer blanket 8 || protections on all disclosures or responses to discovery and that the protection it affords 9 || from public disclosure and use extends only to the limited information or items that are 10 || entitled to confidential treatment under the applicable legal principles. The parties further 11 || acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective Order 12 || does not entitle them to file confidential information under seal: Civil Local Rule 79-5 13 |!sets forth the procedures that must be followed and the standards that will be applied 14 || when a party seeks permission from the court to file material under seal. 15 12 GOOD CAUSE STATEMENT 16 The case arises from an alleged use of force between Plaintiff KEISHA 17 || MOREHEAD (‘Plaintiff’) and Officers employed by Defendant CITY OF OXNARD 18 || (“City”) that occurred during Plaintiffs arrest on September 28, 2019. Plaintiff alleges 19 || Officer Leah Castellano, Officer Kevin Fessler, and the City violated her constitutional 20 ||rights through the use of excessive force in violation of 28 U.S.C. § 1983. 21 This action is likely to involve materials protected by California Evidence Code 22 ||section 1040, California Code of Civil Procedure section 129, California Penal Code 23 || section 632, the official information privilege or other state or federal statutes, court rules, 24 ||case decisions, or common law prohibiting dissemination and disclosure. Additionally, 25 ||this action may involve other proprietary information concerning police practices and 26 ||security protocols for which special protection from public disclosure and from use for 27 || any purpose other than prosecution of this action 1s warranted. 28 In terms of discovery, Defendants anticipate that a protective order will be ee | | 23562 =a |—————sapiarmp orem EompER

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1 ||necessary in connection with the following items of evidence: (1) surveillance and 2 ||handheld video footage arising from Plaintiff's arrest; (2) personnel and administrative 3 records of peace officers: (3) medical records protected by HIPPA; (4) photographs and 4 || audio recordings: and (5) such other evidence for which dissemination should be limited 5 || for use in this action only. 6 Accordingly, to expedite the flow of information, to facilitate the prompt 7 ||resolution of disputes over confidentiality of discovery materials, to adequately protect 8 || information the parties are entitled to keep confidential, to ensure that the parties are 9 || permitted reasonably necessary uses of such material in preparation for and in the conduct 10 || of trial, to address their handling at the end of the litigation, and serve the ends of justice, 11 |/a protective order for such information is justified in this matter. It is the intent of the 12 || parties that information will not be designated as confidential for tactical reasons and that 13 |/nothing be so designated without a good faith belief that it has been maintained in a 14 | confidential, non-public manner, and there is good cause why it should not be part of the 13 || public record of this case. 16 ||2.. DEFINITIONS 17 2.1 Action: Keisha Morehead v. City of Oxnard, et al. (Case No.: 2:21-cv- 18 ||07689-DOC-ADS) 19 2.2 Challenging Party: a Party or Non-Party that challenges the designation of 20 ||information or items under this Order. 21 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how 22 ||it 1s generated, stored or maintained) or tangible things that qualify for protection under 23 ||Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 24 || Statement. 25 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 26 support staff). 27 2.5 Designating Party: a Party or Non-Party that designates information or 28 || items that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.” ee | | 23562 =a |}—————saparmp Ronse

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1 2.6 Disclosure or Discovery Material: all items or information, regardless of the 2 || medium or manner in which it is generated, stored, or maintained (including, among other 3 |/things, testimony, transcripts, and tangible things), that are produced or generated in 4 || disclosures or responses to discovery in this matter. 5 2.7 Expert: a person with specialized knowledge or experience in a matter 6 || pertinent to the litigation who has been retained by a Party or its counsel to serve as an 7 || expert witness or as a consultant in this Action. 8 2.8 House Counsel: attorneys who are employees of a party to this Action. 9 || House Counsel does not include Outside Counsel of Record or any other outside counsel. 10 2.9 Non-Party: any natural person, partnership, corporation, association, or 11 || other legal entity not named as a Party to this Action. 12 2.10 Qutside Counsel of Record: attorneys who are not employees of a party to 13 || this Action but are retained to represent or advise a party to this Action and have appeared 14 |! in this Action on behalf of that party or are affiliated with a law firm which has appeared 15 || on behalf of that party, and includes support staff. 16 2.11 Party: any party to this Action, including all of its officers, directors, 17 ||employees, consultants, retained experts, and Outside Counsel of Record (and their 18 || support staffs). 19 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 20 || Discovery Material in this Action. 21 2.13 Professional Vendors: persons or entities that provide litigation support 22 |/services (e.g., photocopying, videotaping, translating, preparing exhibits or 23 || demonstrations, and organizing, storing, or retrieving data in any form or medium) and 24 || their employees and subcontractors. 25 2.14 Protected Material: any Disclosure or Discovery Material that is designated 26 ||as “CONFIDENTIAL.” 27 2.15 Receiving Party: a Party that recetves Disclosure or Discovery Material 28 || from a Producing Party. ee | | 23562 CA 91101 Fax (see) 263-117 STIPULATED PROTECTIVEORDER (tstststi‘“‘CS;C:~S™

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1 ||3. SCOPE 2 The protections conferred by this Stipulation and Order cover not only Protected 3 ||Material (as defined above), but also (1) any information copied or extracted from 4 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 5 ||Material; and (3) any testimony, conversations, or presentations by Parties or their 6 Counsel that might reveal Protected Material. 7 Any use of Protected Material at trial will be governed by the orders of the trial 8 ||judge. This Order does not govern the use of Protected Material at trial. Likewise, the 9 ||mere existence of this stipulation and Order shall not serve as a basis to preclude the 10 || admission of any protected materials as evidence at the time of trial. 11 |/4. DURATION 12 4.1 Except for imformation specified in section 4.2, the confidentiality 13 || obligations imposed by this Order will remain in effect until a Designating Party agrees 14 |! otherwise in writing or a court order otherwise directs. Final disposition will be deemed 15 || to be the later of (1) dismissal of all claims and defenses in this Action, with or without 16 || prejudice; and (2) final judgment herein after the completion and exhaustion of all 17 || appeals, rehearings, remands, trials, or reviews of this Action, including the time limits 18 || for filing any motions or applications for extension of time pursuant to applicable law. 19 42 If the case proceeds to tnial, information designated as CONFIDENTIAL 20 |) under this protective order that is authorized for use at tnal by stipulation, order or is 21 || otherwise admitted as an exhibit will become public and will be presumptively available 22 ||to all members of the public, including the press, unless compelling reasons supported 23 || by specific factual findings to proceed otherwise are made to the trial judge in advance 24 |/of the tnal. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” showing 25 || for sealing documents produced in discovery from “compelling reasons” standard when 26 || merits-related documents are part of court record). 27 115. DESIGNATING PROTECTED MATERIAL 28 5.1 Exercise of Restraint and Care in Designating Material for Protection ee | | 23562 [eos np prove rnconpeR

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1 Each Party or Non-Party that designates information or items for protection under 2 |/this Order must take care to limit any such designation to specific material that qualifies 3 _|lunder the appropriate standards. The Designating Party must designate for protection 4 only those parts of material, documents, items, or oral or written communications that 5 || qualify so that other portions of the material, documents, items, or communications for 6 which protection is not warranted are not swept unjustifiably within the ambit of this 7 || Order. 8 Mass, indiscriminate, or routinized designations are prohibited. Designations that 9 || are shown to be clearly unjustified or that have been made for an improper purpose (e.g. 10 |/to unnecessarily encumber the case development process or to impose unnecessary 11 || expenses and burdens on other parties) may expose the Designating Party to sanctions. 12 If it comes to a Designating Party’s attention that information or items that it 13 designated for protection do not qualify for protection, that Designating Party must 14 || promptly notify all other Parties that it is withdrawing the inapplicable designation. 15 5.2 Manner and Timing of Designations 16 Except as otherwise provided in this Order (see, e.g., second paragraph of section 17 ||5.2(a) below), or as otherwise stipulated or ordered, Disclosure or Discovery Material 18 ||that qualifies for protection under this Order must be clearly so designated before the 19 || material is disclosed or produced. 20 Designation in conformity with this Order requires: 21 (a) for information in documentary form (e.g., paper or electronic documents, but 22 ||excluding transcripts of depositions or other pretrial or tnal proceedings), that the 23 ||Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 24 ||“CONFIDENTIAL legend”), to each page that contains protected material. If only a 25 || portion or portions of the material on a page qualifies for protection, the Producing Party 26 also must clearly identify the protected portion(s) (e.g., by making appropriate markings 27 |\in the margins). 28 A Party or Non-Party that makes original documents available for inspection need ee | | 23562 [eos ep pRoree none

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1 ||not designate them for protection until after the inspecting Party has indicated which 2 ||documents it would like copied and produced. During the inspection and before the 3 |! designation, all of the material made available for inspection will be deemed 4 ||“CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 5 |! copied and produced, the Producing Party must determine which documents, or portions 6 ||thereof, qualify for protection under this Order. Then, before producing the specified 7 || documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page 8 ||that contains Protected Material. If only a portion or portions of the material on a page 9 qualifies for protection, the Producing Party also must clearly identify the protected 10 || portion(s) (e.g., by making appropriate markings in the margins). 11 (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 13 || protected testimony. 14 (c) for information produced in some form other than documentary and for any 15 || other tangible items, that the Producing Party affix in a prominent place on the exterior 16 |/of the container or containers in which the information is stored the legend 17 ||““CONFIDENTIAL.” If only a portion or portions of the information warrants protection, 18 || the Producing Party, to the extent practicable, will identify the protected portion(s). 19 5.3. Inadvertent Failures to Designate 20 If timely corrected, an inadvertent failure to designate qualified information or 21 ||/items does not, standing alone, waive the Designating Party’s night to secure protection 22 |/under this Order for such material. Upon timely correction of a designation, the 23 || Receiving Party must make reasonable efforts to assure that the material is treated in 24 □□ accordance with the provisions of this Order. 25 5.4 Independent Source 26 The protections conferred by this Stipulation and Order shall not apply to materials 27 || which have been lawfully obtained by the Receiving Party through means independent 28 || of discovery in this case even if the Designating Party later designates the same materials ee | | 23562 [eos np prover cone

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1 |]as CONFIDENTIAL in accordance with the provisions of this Order. 2 116. CHALLENGING CONFIDENTIALITY DESIGNATIONS 3 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation 4 |! of confidentiality at any time that is consistent with the Court’s Scheduling Order. 5 6.2 Meetand Confer. The Challenging Party will initiate the dispute resolution 6 || process (and, if necessary, file a discovery motion) under Local Rule 37.1 et seq. 7 6.3. The burden of persuasion in any such challenge proceeding will be on the 8 || Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., 9 ||to harass or impose unnecessary expenses and burdens on other parties) may expose the 10 || Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn 11 || the confidentiality designation, all parties will continue to afford the material in question 12 || the level of protection to which it is entitled under the Producing Party’s designation until 13 |! the Court rules on the challenge. 14 117. ACCESS TO AND USE OF PROTECTED MATERIAL 15 7.1. Basic Principles, A Receiving Party may use Protected Material that is 16 || disclosed or produced by another Party or by a Non-Party in connection with this Action 17 ||only for prosecuting, defending, or attempting to settle this Action. Such Protected 18 || Material may be disclosed only to the categories of persons and under the conditions 19 || described in this Order. When the Action has been terminated, a Receiving Party must 20 ||comply with the provisions of section 13 below (FINAL DISPOSITION). 21 Protected Material must be stored and maintained by a Receiving Party at a 22 ||location and in a secure manner that ensures that access is limited to the persons 23 || authorized under this Order. 24 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise 25 || ordered by the court or permitted in writing by the Designating Party, a Receiving Party 26 ||may disclose any information or item designated “CONFIDENTIAL” only to: 27 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as 28 ||employees of said Outside Counsel of Record to whom it is reasonably necessary to ee | | 23562 □□ |——————saparmp Rone EoRDER

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1 || disclose the information for this Action: 2 (b) the officers, directors, and employees (including House Counsel) of the 3 || Receiving Party to whom disclosure is reasonably necessary for this Action: 4 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure 5 |lis reasonably necessary for this Action and who have signed the “Acknowledgment and 6 || Agreement to Be Bound” (Exhibit A); 7 (d) the Court and its personnel: 8 (e) court reporters and their staff; 9 (f) professional jury or trial consultants, mock jurors, and Professional Vendors 10 |/to whom disclosure is reasonably necessary for this Action and who have signed the 11 |/“Acknowledgment and Agreement to Be Bound” (Exhibit A): 12 (g) the author or recipient of a document containing the information or a custodian 13 |! or other person who otherwise possessed or knew the information: 14 (h) during their depositions, witnesses, and attorneys for witnesses, in the Action 15 || to whom disclosure is reasonably necessary provided: (1) the deposing party requests that 16 || the witness sign the form attached as Exhibit A hereto; and (2) they will not be permitted 17 ||to keep any confidential information unless they sign the “Acknowledgment and 18 || Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party 19 ||or ordered by the court. Pages of transcribed deposition testimony or exhibits to 20 || depositions that reveal Protected Material may be separately bound by the court reporter 21 ||and may not be disclosed to anyone except as permitted under this Stipulated Protective 22 || Order: and 23 (1) any mediator or settlement officer, and their supporting personnel, mutually 24 ||agreed upon by any of the parties engaged in settlement discussions. 25 118. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 26 ||IN OTHER LITIGATION 27 If a Party is served with a subpoena or a court order issued in other litigation that 28 ||compels disclosure of any information or items designated in this Action as ee | | 23562 [eos rp protien conpeR

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1 ||“CONFIDENTIAL,” that Party must: 2 (a) promptly notify in writing the Designating Party. Such notification will include 3 copy of the subpoena or court order: 4 (b) promptly notify in writing the party who caused the subpoena or order to issue 5 |lin the other litigation that some or all of the material covered by the subpoena or order is 6 subject to this Protective Order. Such notification will include a copy of this Stipulated 7 || Protective Order: and 8 (c) cooperate with respect to all reasonable procedures sought to be pursued by 9 ||the Designating Party whose Protected Material may be affected. 10 If the Designating Party timely seeks a protective order, the Party served with the 11 |/subpoena or court order will not produce any information designated in this action as 12 ||“CONFIDENTIAL” before a determination by the court from which the subpoena or 13 order issued, unless the Party has obtained the Designating Party’s permission. The 14 || Designating Party will bear the burden and expense of seeking protection in that court of 15 ||/its confidential material and nothing in these provisions should be construed as 16 || authorizing or encouraging a Receiving Party in this Action to disobey a lawful directive 17 || from another court. 18 119. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 19 || PRODUCED IN THIS LITIGATION 20 (a) The terms of this Order are applicable to information produced by a Non- 21 || Party in this Action and designated as “CONFIDENTIAL.” Such information produced 22 || by Non-Parties in connection with this litigation is protected by the remedies and relief 23 || provided by this Order. Nothing in these provisions should be construed as prohibiting 24 ||a Non-Party from seeking additional protections. 25 (b) In the event that a Party is required, by a valid discovery request, to produce a 26 ||Non-Party’s confidential information in its possession, and the Party is subject to an 27 ||agreement with the Non-Party not to produce the Non-Party’s confidential information, 28 || then the Party will: ee | | 23562 eye, = |] TTC” Fax (626) 243-1111 STIPULATED PROTECTIVE ORDER

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1 (1) promptly notify in writing the Requesting Party and the Non-Party that 2 |!some or all of the information requested is subject to a confidentiality agreement with a 3 || Non-Party: 4 (2) promptly provide the Non-Party with a copy of the Stipulated Protective 5 |/Order in this Action, the relevant discovery request(s), and a reasonably specific 6 || description of the information requested: and 7 (3) make the information requested available for inspection by the Non- 8 || Party, if requested. 9 (c) Ifthe Non-Party fails to seek a protective order from this court within 14 days 10 || of receiving the notice and accompanying information, the Receiving Party may produce 11 || the Non-Party’s confidential information responsive to the discovery request. If the Non- 12 ||Party timely seeks a protective order, the Receiving Party will not produce any 13 || information in its possession or control that is subject to the confidentiality agreement 14 || with the Non-Party before a determination by the court. Absent a court order to the 15 || contrary, the Non-Party will bear the burden and expense of seeking protection in this 16 || court of its Protected Material. 17 ||10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 18 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 19 ||Protected Material to any person or in any circumstance not authorized under this 20 || Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 21 ||the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 22 |/all unauthorized copies of the Protected Material, (c) inform the person or persons to 23 || whom unauthorized disclosures were made of all the terms of this Order, and (d) request 24 ||such person or persons to execute the “Acknowledgment and Agreement to Be Bound” 25 || that is attached hereto as Exhibit A. 26 |}11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 27 PROTECTED MATERIAL 28 When a Producing Party gives notice to Receiving Parties that certain ee | | 23562 rege, |] TTC” Fax (626) 243-1111 STIPULATED PROTECTIVE ORDER

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1 || inadvertently produced material is subject to a claim of privilege or other protection, the 2 || obligations of the Receiving Parties are those set forth in Federal Rule of Civil Procedure 3 |/26(b)(5)(B). This provision is not intended to modify whatever procedure may be 4 |lestablished in an e-discovery order that provides for production without prior privilege 5 |lreview. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the parties reach 6 ||an agreement on the effect of disclosure of a communication or information covered by 7 ||the attorney-client privilege or work product protection, the parties may incorporate their 8 || agreement in the stipulated protective order submitted to the court. 9 ||12. MISCELLANEOUS 10 12.1 Right to Further Relief Nothing in this Order abridges the right of any 11 || person to seek its modification by the Court in the future. 12 12.2 Right to Assert Other Objections. By stipulating to the entry of this 13 || Protective Order no Party waives any right it otherwise would have to object to disclosing 14 |! or producing any information or item on any ground not addressed in this Stipulated 15 || Protective Order. Similarly, no Party waives any right to object on any ground to use in 16 || evidence of any of the material covered by this Protective Order. 17 12.3 Filing Protected Material. A Party that seeks to file under seal any Protected 18 || Material must comply with Civil Local Rule 79-5. Protected Material may only be filed 19 ||under seal pursuant to a court order authorizing the sealing of the specific Protected 20 || Material at issue. If a Party's request to file Protected Material under seal is denied by 21 ||the court, then the Receiving Party may file the information in the public record unless 22 || otherwise instructed by the court. 23 |/13. FINAL DISPOSITION 24 After the final disposition of this Action, as defined in paragraph 4, within 60 days 25 ||of a written request by the Designating Party, each Receiving Party must return all 26 ||Protected Material to the Producing Party or destroy such material. As used in this 27 ||subdivision, “all Protected Material” includes all copies, abstracts, compilations, 28 ||summaries, and any other format reproducing or capturing any of the Protected Material. ee | | 23562 CA 91101 12 Fax (see) 263-117 STIPULATED PROTECTIVEORDER (tstststi‘“‘CS;C:~S™

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1 || Whether the Protected Material is returned or destroyed, the Receiving Party must submit 2 written certification to the Producing Party (and, if not the same person or entity, to the 3 ||Designating Party) by the 60 day deadline that (1) identifies (by category, where 4 || appropriate) all the Protected Material that was returned or destroyed and (2) affirms that 5 |!the Receiving Party has not retained any copies, abstracts, compilations, summaries or 6 || any other format reproducing or capturing any of the Protected Material. Notwithstanding 7 ||this provision, Counsel are entitled to retain an archival copy of all pleadings, motion 8 ||papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence, 9 || deposition and trial exhibits, expert reports, attorney work product, and consultant and 10 |/expert work product, even if such materials contain Protected Material. Any such 11 archival copies that contain or constitute Protected Material remain subject to this 12 || Protective Order as set forth in Section 4. 13 14. Any willful violation of this Order may be punished by civil or criminal 14 |/contempt proceedings, financial or evidentiary sanctions, reference to disciplinary 15 || authorities, or other appropriate action at the discretion of the Court. 16 17 IS SO STIPULATED, THROUGH ALL PARTIES. 18 19 ||DATED: April 21, 2022 COLLINS + COLLINS Lip 20 21 CafLacd By: Nea 22 DAVID C. MOORE 33 CAROLINE M. PARK Attorneys for Defendants 24 CITY OF OXNARD, OFFICER LEAH 95 CASTELLANO, AND OFFICER KEVIN FESSLER 26 at 28 eee cern” || 23562 CA 91107 1 3 (ez) 260-1111 r STIPULATED PROTECTIVE ORDER

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1 |]/DATED: April 13, 2022 THE LAW OFFICES OF LUDLOW B. 2 CREARY II » 2-—IL LUDLOW B. CREARY II 5 Attorney for Plaintiff 6 KEISHA MOREHEAD g ||FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 19 || DATED: _ April 26, 2022 /s/ Autumn D. Spaeth i HON. AUTUMN D. SPAETH b United States Magistrate Judge

13 14 15 16 17 18 19 20 21 22 23 24 25 26 at 28 See || 23502 CA 81101 14 Fae (620) 265-111 STIPULATED PROTECTIVEORDER (tstststi‘“‘CS;C:~S™

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1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 4 I, [full name], of 5 ||{full address], declare under penalty of perjury that I have read in its entirety and 6 □□ understand the Stipulated Protective Order that was issued by the United States District 7 || Court for the Central District of California on [date] in the case of Keisha Morehead v. 8 || City of Oxnard, et al. (Case No.: 2:21-cv-07689-DOC-ADS). I agree to comply with and 9 ||to be bound by all the terms of this Stipulated Protective Order and I understand and 10 |! acknowledge that failure to so comply could expose me to sanctions and punishment 11 |/in the nature of contempt. I solemnly promise that I will not disclose in any manner 12 |! any information or item that is subject to this Stipulated Protective Order to any person 13 |! or entity 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 [full 18 |/name] of [full address and 19 ||telephone number] as my California agent for service of process in connection with 20 ||this action or any proceedings related to enforcement of this Stipulated Protective 21 || Order. 22 || Date: 23 || City and State where signed: 24 25 || Printed name: 26 27 || Signature: 28 ee | | 23562 CA 91101 15 Fax (see) 263-117 STIPULATED PROTECTIVEORDER (tstststi‘“‘CS;C:~S™