11 THE SEHAT LAW FIRM, PLC Nicholas Brosamle, Esq. (SBN 356492) 22 Cameron Sehat, Esq. (SBN: 256535) Jeffrey Mikel, Esq (SBN: 350671) 33 5100 Campus Dr., Suite 200 Newport Beach, CA 92660 44 Telephone: (949) 825-5200 Facsimile: (949) 313-5001 55 Cameron@sehatlaw.com
n.brosamle@sehatlaw.com 66 j.mikel@sehatlaw.com
77 Attorney for Plaintiffs, L.J., K.J., Raya Johnson-Kelly and Chris Kelly 88
99 UNITED STATES DISTRICT COURT 1100 CENTRAL DISTRICT OF CALIFORNIA
1111 L.J. a minor, individually and as Case No: 2:25-cv-03751 MRA (Ex) 1122 personal representative of the Estate of Rhaquan Johnson, by her mother and Hon. Monica Ramirez Almadani 1133 guardian ad litem Mia Tafoya, K.J. a 1144 minor, individually and as personal STIPULATED PROTECTIVE representative of the Estate of Rhaquan ORDER 1155 Johnson, by her mother and guardian 1166 ad litem Mia Tafoya, Raya Johnson- Kelly individually, Chris Kelly, 1177 individually, 1188 Plaintiffs, 1199 vs. 2200
CITY OF LOS ANGELES, a 2211 government entity, Michael Meiser, 2222 and DOES 1-10 inclusive
2233 Defendants. 2244
1. A. PURPOSES AND LIMITATIONS 2266 Discovery in this action is likely to involve production of confidential, 2277 proprietary, or private information for which special protection from public 11 disclosure and from use for any purpose other than prosecuting this litigation 22 may be warranted. Accordingly, the parties hereby stipulate to and petition the 33 Court to enter the following Stipulated Protective Order. The parties 44 acknowledge that this Order does not confer blanket protections on all disclosures 55 or responses to discovery and that the protection it affords from public 66 disclosure and use extends only to the limited information or items that are 77 entitled to confidential treatment under the applicable legal principles. The parties 88 further acknowledge, as set forth in Section 12.3, below, that this Stipulated 99 Protective Order does not entitle them to file confidential information under seal; 1100 Civil Local Rule 79-5 sets forth the procedures that must be followed and the 1111 standards that will be applied when a party seeks permission from the Court to file 1122 material under seal. The parties must also comply with any pertinent orders from 1133 District Judge Monica Ramirez Almadani and Magistrate Judge Charles F. Eick. 1144
1155 B. GOOD CAUSE STATEMENT 1166 The Parties represent that pre-trial discovery in this case is likely to include 1177 the production of information and/or documents that are confidential and/or 1188 privileged, including the production of peace officer personnel file information 1199 and/or documents which the Parties agree includes: (1) Personal data, including 2200 marital status, family members, educational and employment history, home 2211 addresses, or similar information; (2) Medical history; (3) Police officer employee 2222 personnel file; (4) Employee advancement, appraisal, or discipline; (5) Evidence 2233 gathered by law enforcement as part of an ongoing criminal investigation (6) 2244 Complaints, or investigations of complaints, concerning an event or transaction in 2255 which a peace officer participated, or which a peace officer perceived, and 2266 pertaining to the manner in which the peace officer performed his or her duties 2277 including compelled statements by peace officers unless specifically denoted as 11 “not confidential” pursuant to Penal Code section 832.7; (7) internal investigative 22 files and documents; (8) email and written correspondence records; (8) 33 confidential information with financial records; (9) video footage and/or 44 photographs related to the incident; (10) psychological and medical notes, 55 evaluations, reports, and treatment plans; and (11) policies and procedures that are 66 kept from the public in the ordinary course of business, as well as other 77 information that is not generally available to the public and Defendants contend is 88 subject to the Official Information Privilege and other privileges. Sanchez v. City 99 of Santa Ana, 936 F.2d 1027, 1033 (9th Cir. Cal. 1990); see also Kerr v. United 1100 States Dist. Ct. for N.D. Cal., 511 F.2d 192, 198 (9th Cir.1975), aff'd, 426 U.S. 1111 394 (1976). 1122 Testimony taken at a deposition may be designated as Confidential by making 1133 a statement to that effect on the record at the deposition. Arrangements shall be made 1144 with the court reporter transcribing the deposition to separately bind such portions 1155 of the transcript containing information designated as Confidential, and to label such 1166 portions appropriately. Confidential photographs, video or audio footage obtained 1177 through the course of discovery or otherwise may not be used for any purpose other 1188 than litigating this lawsuit. The parties agree to refrain from directly or indirectly 1199 disclosing or publicly disseminating confidential deposition testimony, and/or 2200 photographs, video or audio footage obtained through the course of discovery or 2211 otherwise, specifically including, but not limited to, dissemination via billboard 2222 advertisements, print and online media organizations, or any other internet posting 2233 or social media. If any party intends to use such confidential materials for any 2244 purpose other than litigating this lawsuit, the party seeking public disclosure must 2255 first seek approval from the Court. 2266 The incident at issue in this action involves events that include the alleged 2277 illicit smuggling of narcotics into the Pitchess Detention Center at the North 11 County Correctional Facility, operated by the Los Angeles County Sheriff’s 22 Department. Defendant Meiser and at least 18 other individuals have been 33 indicted pursuant to a joint and ongoing investigation by the Los Angeles County 44 Sheriff’s Department and the FBI’s San Gabriel Valley Safe Streets Task Force in 55 regards to drug smuggling within the County jail system. Discovery may require 66 the production of certain Los Angeles County Sheriff’s Department’s 77 investigative findings and materials that are privileged and confidential during the 88 pendency of the criminal prosecution. This information and materials are not 99 available to the public and public disclosure at this time could risk compromising 1100 the underlying criminal prosecution, and/or impeding further investigation. In 1111 addition to the aforesaid investigative findings and materials, Peace officer 1122 personnel file information and/or documents and security-sensitive policies and 1133 procedures are hereinafter referred to as "Confidential Information". 1144 The parties contend that that public disclosure of such material poses a 1155 substantial risk and jeopardy to the underlying criminal prosecution. Finally, the 1166 parties contend that the benefit of public disclosure of Confidential Information is 1177 minimal while the potential disadvantages are great. 1188 In light of the nature of the claims and allegations in this case and the parties’ 1199 representations that discovery in this case will involve the production of confidential 2200 records, and in order to expedite the flow of information, to facilitate the prompt 2211 resolution of disputes over confidentiality of discovery materials, to adequately 2222 protect information the parties are entitled to keep confidential, to ensure that the 2233 parties are permitted reasonable necessary uses of such material in connection with 2244 this action, to address their handling of such material at the end of the litigation, and 2255 to serve the ends of justice, a protective order for such information is justified in this 2266 matter. The parties shall not designate any information/documents as confidential 2277 without a good faith belief that such information/documents have been maintained 11 in a confidential, non-public manner, and that there is good cause or a compelling 22 reason why it should not be part of the public record of this case. 33 Accordingly, good cause exists for entry of this Protective Order to 44 facilitate pre-trial disclosure to allow the parties to support their claims and 55 defenses while assuring the safety of these sensitive disclosures. See Fed. R. Civ. 66 Proc. 26(c). 77 2. DEFINITIONS 88 2.1 Action: L.J., et al. v. County of Los Angeles, et al., Case No. 2:25-cv- 99 03751 MRA (Ex) 1100 2.2 Challenging Party: a Party or Non-Party that challenges the 1111 designation of information or items under this Order. 1122 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how 1133 it is generated, stored, or maintained) or tangible things that qualify for protection 1144 under Federal Rule of Civil Procedure 26(c), and as specified above in the 1155 Good Cause Statement. 1166 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 1177 their support staff). 1188 2.5 Designating Party: a Party or Non-Party that designates information or 1199 items that it produces in disclosures or in responses to discovery as 2200 “CONFIDENTIAL.” 2211 2.6 Disclosure or Discovery Material: all items or information, regardless of 2222 the medium or manner in which it is generated, stored, or maintained (including, 2233 among other things, testimony, transcripts, and tangible things), that are produced 2244 or generated in disclosures or responses to discovery in this matter. 2255 2.7 Expert: a person with specialized knowledge or experience in a matter 2266 pertinent to the litigation who has been retained by a Party or its counsel to serve 2277 as an expert witness or as a consultant in this Action. 11 2.8 House Counsel: attorneys who are employees of a party to this Action. 22 House Counsel does not include Outside Counsel of Record or any other 33 outside counsel. 44 2.9 Non-Party: any natural person, partnership, corporation, association, or 55 other legal entity not named as a Party to this action. 66 2.10 Outside Counsel of Record: attorneys who are not employees of a 77 party to this Action but are retained to represent or advise a party to this Action 88 and have appeared in this Action on behalf of that party or are affiliated with a 99 law firm which has appeared on behalf of that party, and includes support staff. 1100 2.11 Party: any party to this Action, including all of its officers, directors, 1111 employees, consultants, retained experts, and Outside Counsel of Record (and 1122 their support staffs). 1133 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 1144 Discovery Material in this Action. 1155 2.13 Professional Vendors: persons or entities that provide litigation support 1166 services (e.g., photocopying, videotaping, translating, preparing exhibits or 1177 demonstrations, and organizing, storing, or retrieving data in any form or 1188 medium) and their employees and subcontractors. 1199 2.14 Protected Material: any Disclosure or Discovery Material that is designated 2200 as “CONFIDENTIAL.” 2211 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 2222 from a Producing Party. 2233
2244 3. SCOPE 2255 The protections conferred by this Stipulation and Order cover not only Protected 2266 Material (as defined above), but also (1) any information copied or extracted from 2277 Protected Material; (2) all copies, excerpts, summaries, or compilations of 11 Protected Material; and (3) any testimony, conversations, or presentations by 22 Parties or their Counsel that might reveal Protected Material. 33 Any use of Protected Material at trial shall be governed by the orders of the trial 44 judge. This Order does not govern the use of Protected Material at trial. 55
66 4. DURATION 77 Once a case proceeds to trial, all of the court-filed information to be introduced 88 that was previously designated as confidential or maintained pursuant to this 99 protective order becomes public and will be presumptively available to all 1100 members of the public, including the press, unless compelling reasons supported 1111 by specific factual findings to proceed otherwise are made to the trial judge in 1122 advance of the trial. See Kamakana v. City and County of Honolulu, 447 F.3d 1133 1172, 1180-81 (9th Cir. 2006) (distinguishing “good cause” showing for sealing 1144 documents produced in discovery from “compelling reasons” standard when 1155 merits-related documents are part of court record). Accordingly, the terms of this 1166 protective order do not extend beyond the commencement of the trial. 1177
1188 5. DESIGNATING PROTECTED MATERIAL 1199 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each 2200 Party or Non-Party that designates information or items for protection under this 2211 Order must take care to limit any such designation to specific material that 2222 qualifies under the appropriate standards. The Designating Party must designate 2233 for protection only those parts of material, documents, items, or oral or written 2244 communications that qualify so that other portions of the material, documents, or 2255 communications for which protection is not warranted are not swept unjustifiably 2266 within the ambit of this Order. 2277
Mass, indiscriminate, or routinized designations are prohibited. Designations that 11 are shown to be clearly unjustified or that have been made for an improper 22 purpose (e.g., to unnecessarily encumber the case development process or to 33 impose unnecessary expenses and burdens on other parties) may expose the 44 Designating Party to sanctions. 55 If it comes to a Designating Party’s attention that information or items that it 66 designated for protection do not qualify for protection, that Designating Party 77 must promptly notify all other Parties that it is withdrawing the inapplicable 88 designation. 99 5.2 Manner and Timing of Designations. Except as otherwise provided in this 1100 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 1111 stipulated or ordered, Disclosure or Discovery Material that qualifies for 1122 protection under this Order must be clearly so designated before the material is 1133 disclosed or produced. 1144 Designation in conformity with this Order requires: 1155 (a) for information in documentary form (e.g., paper or electronic documents, 1166 but excluding transcripts of depositions or other pretrial or trial proceedings), that 1177 the Producing Party affix at a minimum, the legend “CONFIDENTIAL” 1188 (hereinafter “CONFIDENTIAL legend”), to each page that contains protected 1199 material. If only a portion or portions of the material on a page qualifies for 2200 protection, the Producing Party also must clearly identify the protected portion(s) 2211 (e.g., by making appropriate markings in the margins). 2222 A Party or Non-Party that makes original documents available for inspection need 2233 not designate them for protection until after the inspecting Party has indicated 2244 which documents it would like copied and produced. During the inspection and 2255 before the designation, all of the material made available for inspection shall be 2266 deemed “CONFIDENTIAL.” After the inspecting Party has identified 2277 the documents, it wants copied and produced, the Producing Party must determine 11 which documents, or portions thereof, qualify for protection under this Order. 22 Then, before producing the specified documents, the Producing Party must affix 33 the “CONFIDENTIAL legend” to each page that contains Protected Material. If 44 only a portion or portions of the material on a page qualifies for protection, the 55 Producing Party also must clearly identify the protected portion(s) (e.g., by 66 making appropriate markings in the margins). 77 (b) for testimony given in depositions that the Designating Party (or if the 88 Designating party is a non-party not present at the deposition, the Receiving Party) 99 identify the Disclosure or Discovery Material on the record, before the close of 1100 the deposition all protected testimony. 1111 (c) for information produced in some form other than documentary and for 1122 any other tangible items, that the Producing Party affix in a prominent place on 1133 the exterior of the container or containers in which the information is stored 1144 the legend “CONFIDENTIAL.” If only a portion or portions of the information 1155 warrants protection, the Producing Party, to the extent practicable, shall identify 1166 the protected portion(s). 1177 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 1188 failure to designate qualified information or items does not, standing alone, 1199 waive the Designating Party’s right to secure protection under this Order for such 2200 material. Upon timely correction of a designation, the Receiving Party must make 2211 reasonable efforts to assure that the material is treated in accordance with the 2222 provisions of this Order. 2233
2244 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 2255 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 2266 designation of confidentiality at any time that is consistent with the Court’s 2277 Scheduling Order. 11 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 22 resolution process under Local Rule 37.1 et seq. Any discovery motion must 33 strictly comply with the procedures set forth in Local Rules 37-1, 37-2, and 37- 44 3, or follow the procedures for informal, telephonic discovery hearings on the 55 Court's website. 66 6.3 The burden of persuasion in any such challenge proceeding shall be on the 77 Designating Party. Frivolous challenges, and those made for an improper 88 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 99 parties) may expose the Challenging Party to sanctions. Unless the Designating 1100 Party has waived or withdrawn the confidentiality designation, all parties shall 1111 continue to afford the material in question the level of protection to which it is 1122 entitled under the Producing Party’s designation until the Court rules on the 1133 challenge. 1144
7. ACCESS TO AND USE OF PROTECTED MATERIAL 1166
7.1 Basic Principles. A Receiving Party may use Protected Material that is 1177
disclosed or produced by another Party or by a Non-Party in connection with this 1188
Action only for prosecuting, defending, or attempting to settle this Action. Such 1199
Protected Material may be disclosed only to the categories of persons and under 2200
the conditions described in this Order. When the Action has been terminated, a 2211
Receiving Party must comply with the provisions of section 13 below (FINAL 2222
DISPOSITION). 2233
2244 Protected Material must be stored and maintained by a Receiving Party at a
2255 location and in a secure manner that ensures that access is limited to the persons
2266 authorized under this Order.
2277 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise
ordered by the Court or permitted in writing by the Designating Party, a Receiving 11 Party may disclose any information or item designated “CONFIDENTIAL” only 22 to: 33 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as 44 employees of said Outside Counsel of Record to whom it is reasonably necessary 55 to disclose the information for this Action; 66 b) the officers, directors, and employees (including House Counsel) of the 77 Receiving Party to whom disclosure is reasonably necessary for this Action; 88 (c) Experts (as defined in this Order) of the Receiving Party to whom 99 disclosure is reasonably necessary for this Action and who have signed the 1100 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 1111 (d) the Court and its personnel; 1122 (e) court reporters and their staff; 1133 (f) professional jury or trial consultants, mock jurors, and Professional Vendors 1144 to whom disclosure is reasonably necessary for this Action and who have signed 1155 the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 1166 (g) the author or recipient of a document containing the information or a 1177 custodian or other person who otherwise possessed or knew the information; 1188 (h) during their depositions, witnesses ,and attorneys for witnesses, in the Action 1199 to whom disclosure is reasonably necessary provided: (1) the deposing party 2200 requests that the witness sign the form attached as Exhibit A hereto; and (2) they 2211 will not be permitted to keep any confidential information unless they sign the 2222 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless 2233 otherwise agreed by the Designating Party or ordered by the Court. Pages of 2244 transcribed deposition testimony or exhibits to depositions that reveal Protected 2255 Material may be separately bound by the court reporter and may not be disclosed 2266 to anyone except as permitted under this Stipulated Protective Order; and 2277 (i) any mediator or settlement officer, and their supporting personnel, mutually 11 agreed upon by any of the parties engaged in settlement discussions, or appointed 22 by the Court 33
44 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 55 PRODUCED IN OTHER LITIGATION 66 If a Party is served with a subpoena or a court order issued in other litigation that 77 compels disclosure of any information or items designated in this Action as 88 “CONFIDENTIAL,” that Party must: 99 (a) promptly notify in writing the Designating Party. Such notification shall 1100 include a copy of the subpoena or court order; 1111 (b) promptly notify in writing the party who caused the subpoena or order to 1122 issue in the other litigation that some or all of the material covered by the 1133 subpoena or order is subject to this Protective Order. Such notification shall 1144 include a copy of this Stipulated Protective Order; and 1155 (c) cooperate with respect to all reasonable procedures sought to be pursued by 1166 the Designating Party whose Protected Material may be affected. 1177 If the Designating Party timely seeks a protective order, the Party served with the 1188 subpoena or court order shall not produce any information designated in this 1199 action as “CONFIDENTIAL” before a determination by the court from which the 2200 subpoena or order issued, unless the Party has obtained the Designating Party’s 2211 permission. The Designating Party shall bear the burden and expense of seeking 2222 protection in that court of its confidential material and nothing in these provisions 2233 should be construed as authorizing or encouraging a Receiving Party in this 2244 Action to disobey a lawful directive from another court. 2255
2266 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 2277 PRODUCED IN THIS LITIGATION 11 (a) The terms of this Order are applicable to information produced by a Non- 22 Party in this Action and designated as “CONFIDENTIAL.” Such information 33 produced by Non-Parties in connection with this litigation is protected by the 44 remedies and relief provided by this Order. Nothing in these provisions should be 55 construed as prohibiting a Non-Party from seeking additional protections. 66 (b) In the event that a Party is required, by a valid discovery request, to produce 77 a Non-Party’s confidential information in its possession, then the Party shall: 88 (1) promptly notify in writing the Requesting Party and the Non-Party that some 99 or all of the information requested is subject to a confidentiality agreement with a 1100 Non-Party; 1111 (2) promptly provide the Non-Party with a copy of the Stipulated Protective 1122 Order in this Action, the relevant discovery request(s), and a reasonably specific 1133 description of the information requested; and 1144 (3) make the information requested available for inspection by the 1155 Non-Party, if requested. 1166 (c) If the Non-Party fails to seek a protective order from this Court within 1177 14 days of receiving the notice and accompanying information, the Receiving 1188 Party may produce the Non-Party’s confidential information responsive to the 1199 discovery request. If the Non-Party timely seeks a protective order, the Receiving 2200 Party shall not produce any information in its possession or control that is subject 2211 to this order, or any confidentiality agreement with the Non-Party, before a 2222 determination by the Court. Absent a court order to the contrary, the Non-Party 2233 shall bear the burden and expense of seeking protection in this Court of its 2244 Protected Material. 2255
2266 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 2277 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 11 Protected Material to any person or in any circumstance not authorized under this 22 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 33 writing the Designating Party of the unauthorized disclosures, (b) use its best 44 efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the 55 person or persons to whom unauthorized disclosures were made of all the terms of 66 this Order, and (d) request such person or persons to execute the 77 “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit 88 A. 99 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 1100 PROTECTED MATERIAL 1111 When a Producing Party gives notice to Receiving Parties that certain 1122 inadvertently produced material is subject to a claim of privilege or other 1133 protection, the obligations of the Receiving Parties are those set forth in Federal 1144 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 1155 whatever procedure may be established in an e-discovery order that provides 1166 for production without prior privilege review. Pursuant to Federal Rule of 1177 Evidence 502(d) and (e), insofar as the parties reach an agreement on the effect of 1188 disclosure of a communication or information covered by the attorney-client 1199 privilege or work product protection, the parties may incorporate their agreement 2200 in the stipulated protective order submitted to the Court. 2211
2222 12. MISCELLANEOUS 2233 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 2244 person to seek its modification by the Court in the future. 2255 12.2 Right to Assert Other Objections. By stipulating to the entry of this 2266 Protective Order, no Party waives any right it otherwise would have to object to 2277 disclosing or producing any information or item on any ground not addressed in 11 this Stipulated Protective Order. Similarly, no Party waives any right to object on 22 any ground to use in evidence of any of the material covered by this Protective 33 Order. 44 12.3 Filing Protected Material. A Party that seeks to file under seal any 55 Protected Material must comply with Civil Local Rule 79-5. Protected Material 66 may only be filed under seal pursuant to a court order authorizing the sealing of 77 the specific Protected Material at issue. If a Party's request to file Protected 88 Material under seal is denied by the Court, then the Receiving Party may file the 99 information in the public record only after providing the designating party with 1100 notice and opportunity to object, and unless otherwise instructed by the Court. 1111
1122 13. FINAL DISPOSITION 1133
1144 After the final disposition of this Action, as defined in paragraph 4, within 60 days 1155 of a written request by the Designating Party, each Receiving Party must return all 1166 Protected Material to the Producing Party or destroy such material. As used in 1177 this subdivision, “all Protected Material” includes all copies, abstracts, 1188 compilations, summaries, and any other format reproducing or capturing any of 1199 the Protected Material. Whether the Protected Material is returned or destroyed, 2200 the Receiving Party must submit a written certification to the Producing Party 2211 (and, if not the same person or entity, to the Designating Party) by the 60 day 2222 deadline that (1) identifies (by category, where appropriate) all the Protected 2233 Material that was returned or destroyed, and (2)affirms that the Receiving 2244 Party has not retained any copies, abstracts, compilations, summaries or any 2255 other format reproducing or capturing any of the Protected Material. 2266 Notwithstanding this provision, Counsel are entitled to retain an archival copy of 2277 all pleadings, motion papers, trial, deposition, and hearing transcripts, legal 11 memoranda, correspondence, deposition and trial exhibits, expert reports, attorney
22 work product, and consultant and expert work product, even if such materials 33 contain Protected Material. Any such archival copies that contain or constitute 44 Protected Material remain subject to this Protective Order as set forth in Section 4 55 (DURATION). 66
77 14. VIOLATION OF ORDER 88
1100 Any violation of this Order may be punished by any and all appropriate measures
1111 including, without limitation, contempt proceedings sanctions and/or monetary
1122 sanctions.
IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD 1144
1166 DATED: 1/7/2026 THE SEHAT LAW FIRM, PLC
1177 s/ Cameron Sehat
1188 Cameron Sehat, Esq. Jeffrey Mikel, Esq. 1199 Attorneys for Plaintiffs
2200 DATED: 1/7/2026 2211
2222 s/ Christina Gasparian Thomas C. Hurrell, Esq. 2233 Christina Gasparian, Esq.
2244 Angela S. Parayno, Esq. Attorneys for Defendant, County 2255 of Los Angeles
2277 11 DATED: 1/7/2026
22 s/ Tiffany L. Salayer 33 Tomas A. Guterres, Esq.
Tiffany L. Salayer, Esq. 44 Attorneys for Defendant 55 Michael Meiser
88 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
99 DATED: 1/9/2026 1100 __________________________________ 1111 Hon. Charles F. Eick United States Magistrate Judge 1122
2277 11 EXHIBIT A
22 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
33 I, [print or type full name], of____________________ 44 [full address], declare under penalty of perjury that I have read in its entirety 55 and understand the Stipulated Protective Order that was issued by the United 66 States District Court for the Central District of California on _________ [date] in 77 the case of L.J. v. City of Los Angeles; Case No: 2:25-cv-03751 MRA-Ex. I 88 agree to comply with and to be bound by all the terms of this Stipulated Protective 99 Order and I understand and acknowledge that failure to so comply could expose 1100 me to sanctions and punishment in the nature of contempt. I solemnly promise that 1111 I will not disclose in any manner any information or item that is subject to this 1122 Stipulated Protective Order to any person or entity except in strict compliance 1133 with the provisions of this Order. 1144 I further agree to submit to the jurisdiction of the United States District Court for 1155 the Central District of California for the purpose of enforcing the terms of this 1166 Stipulated Protective Order, even if such enforcement proceedings occur after 1177 termination of this action. I hereby appoint [print 1188 or type full name] of [print or 1199 type full address and telephone number] as my California agent for service of 2200 process in connection with this action or any proceedings related to enforcement 2211 of this Stipulated Protective Order. 2222
2233 Date:
2244 City and State where sworn and signed: 2255
2266 Printed name: 2277