Noah Shumate v. City of Placentia, Officer Contreras, Officer Lemus, Sgt. Tom McKenzie, Chief Butts, Former Chief Leny

• Court: District Court, C.D. California
• Decided: October 14, 2025
• Docket: 2:24-cv-06532
• Status: Unknown

Opinion

Allison N. Imam-Hedrick, Esq. (State Bar No. 345539) 2 Adam A. Ainslie, Esq. (State Bar No. 311427) 3 COLLINS + COLLINS LLP 750 The City Drive, Suite 400 4 Orange, CA 92868 5 (714) 823-4100 - FAX (714) 823-4101 Email: mwroniak@ccllp.law 6 Email: aimam-hedrick@ccllp.law 7 Email: aainslie@ccllp.law

8 Attorneys for Defendants 9 CITY OF PLACENTIA, OFFICER CONTRERAS, OFFICER LEMUS, SGT. TOM MCKENZIE, CHIEF BUTTS, FORMER CHIEF LENYI 10

11 UNITED STATES DISTRICT COURT 12 CENTRAL DISTRICT OF CALIFORNIA - WESTERN DIVISION 13 NOAH SHUMATE, CASE NO. 2:24-cv-6532FMO-SSC 14 Assigned to Hon. Fernando M. Olguin in 15 Plaintiff, Dept. Courtroom 6D

16 vs. DISCOVERY MATTER 17 CITY OF PLACENTIA; OFCR. [PROPOSED] STIPULATED 18 CAMARGO; OFCR CONTRERAS; PROTECTIVE ORDER 19 OCFR LEMUS; SGT. MCKENZIE; CHEIF BUTTS; FORMER CHIEF Complaint Filed: 8/01/2024 20 LENYI, individually and in their Trial Date: None 21 official capacities; and DOES 1-10 inclusive, 22

23 Defendants.

24 25 / / / 26 / / / 27 / / / 28 / / / Pursuant to Federal Rule of Civil Procedure 26(c), Plaintiff Noah Shumate and 2 Defendants City of Placentia, Officer Contreras, Officer Lemus, Sergeant McKenzie, 3 Chief Butts, and Former Chief Lenyi (collectively, the Parties) hereby stipulate to, and 4 move the Court to enter, this Protective Order1, on the grounds that the discovery 5 sought is highly sensitive. 6 7 1. GENERAL 8 1.1. PURPOSES & LIMITATIONS 9 Discovery in this action is likely to involve production of confidential, 10 proprietary, or private information for which special protection from public disclosure 11 and from use for any purposes other than prosecuting this litigation may be warranted. 12 Accordingly, the Parties hereby stipulate to and petition the Court to enter this 13 Protective Order (“Order”). The Parties acknowledge that this Order does not confer 14 blanket protections on all disclosures or responses to discovery and the protection that 15 it affords from public disclosure and use extends only to the limited information or 16 items that are entitled to confidential treatment under applicable legal principles. The 17 Parties further acknowledge, as set forth in Section 12.3 below, that this Order does 18 not entitle them to file confidential information under seal; Civil Local Rule 79-5 sets 19 forth the procedures that must be followed and the standards that will be applied when 20 a party seeks permission from the Court to file material under seal. 21 1.2. GOOD CAUSE STATEMENT 22 This action involves the City of Placentia and peace officers employed by the 23 City of Placentia Police Department. Plaintiff will seek materials and information the 24 City of Placentia (“City”) maintains as confidential, such as personnel files of the 25 Officers involved in the Incident, Internal Affairs materials and information, video 26 recordings, local criminal history information, video recordings, body worn camera 27 1 This stipulated protective order is substantially based on the model protective order published and 28 used throughout the Central District. footage, criminal investigative files, and other administrative materials and other 2 information that the City believes need special protection from public disclosure and 3 from use for any purpose other than prosecuting this litigation. 4 Accordingly, to expedite the flow of information, to facilitate the prompt 5 resolution of disputes over confidentiality of discovery materials, to adequately protect 6 information the Parties are permitted reasonable necessary uses of such material in 7 preparation for and in the conduct of trial, to address their handling at the end of the 8 litigation, and serve the ends of justice, a protective order for such information is 9 justified in this matter. It is the intent of the Parties that information will not be 10 designated as confidential for tactical reasons and that nothing be so designated without 11 a good faith belief that it has been maintained in a confidential, non-public manner, 12 and there is good cause why it should not be part of the public record of this case. 13 1.3. ACKNOWLEDGMENT OF UNDER SEAL FILING PROCEDURE 14 The parties further acknowledge, as set forth in Section 12.3, below, that this 15 Stipulated Protective Order does not entitle them to file confidential information under 16 seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the 17 standards that will be applied when a party seeks permission from the court to file 18 material under seal. There is a strong presumption that the public has a right of access 19 to judicial proceedings and records in civil cases. In connection with non-dispositive 20 motions, good cause must be shown to support a filing under seal. See, Kamakana v. 21 City and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. 22 Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony 23 Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders 24 require good cause showing), and a specific showing of good cause or compelling 25 reasons with proper evidentiary support and legal justification, must be made with 26 respect to Protected Material that a party seeks to file under seal. The Parties’ mere 27 designation of Disclosure or Discovery Material as CONFIDENTIAL does not— 28 without the submission of competent evidence by declaration, establishing that the 2 material sought to be filed under seal qualifies as confidential, privileged, or otherwise 3 protectable—constitute good cause. Further, if a party requests sealing related to a 4 dispositive motion or trial, then compelling reasons, not only good cause, for the 5 sealing must be shown, and the relief sought shall be narrowly tailored to serve the 6 specific interest to be protected. See, Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 7 677-79 (9th Cir. 2010). For each item or type of information, document, or thing sought 8 to be filed or introduced under seal, the party seeking protection must articulate 9 compelling reasons, supported by specific facts and legal justification, for the 10 requested sealing order. Again, competent evidence supporting the application to file 11 documents under seal must be provided by declaration. Any document that is not 12 confidential, privileged, or otherwise protectable in its entirety will not be filed under 13 seal if the confidential portions can be redacted. If documents can be redacted, then a 14 redacted version for public viewing, omitting only the confidential, privileged, or 15 otherwise protectable portions of the document, shall be filed. Any application that 16 seeks to file documents under seal in their entirety should include an explanation of 17 why redaction is not feasible. 18 19 2. DEFINITIONS 20 2.1. Action: Noah Shumate v. Thomas McKenzie, et al., case no. 2:24-cv-6532FMO- 21 SSC. 22 2.2. Challenging Party: a Party or Non-Party that challenges the designation of 23 information or items under this Order. 24 2.3. “CONFIDENTIAL” Information or Items: information (regardless of how it 25 is generated, stored, or maintained) or tangible things that qualify for protection under 26 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 27 Statement. 28 2.4. Counsel: Outside Counsel of Record and House Counsel (as well as their 2 support staff). 3 2.5. Designating Party: a Party or Non-Party that designates information or items 4 that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 5 2.6. Disclosure or Discovery Material: all items or information, regardless of the 6 medium or manner in which it is generated, stored, or maintained (including, among 7 other things, testimony, transcripts, and tangible things), that are produced or generated 8 in disclosures or responses to discovery in this matter. 9 2.7. Expert: a person with specialized knowledge or experience in a matter pertinent 10 to the litigation who has been retained by a Party or its counsel to serve as an expert 11 witness or as a consultant in this Action. 12 2.8. House Counsel: attorneys who are employees of a Party to this Action. House 13 Counsel does not include Outside Counsel of Record or any other outside counsel. 14 2.9. Non-Party: any natural person, partnership, corporation, association, or other 15 legal entity not named as a Party to this Action. 16 2.10. Outside Counsel of Record: attorneys who are not employees of a Party to this 17 Action but are retained to represent or advise a Party to this Action and have appeared 18 in this Action on behalf of that Party or are affiliated with a law firm that has appeared 19 on behalf of that Party, including support staff. 20 2.11. Party: any Party to this Action, including all of its officers, directors, 21 employees, consultants, retained experts, and Outside Counsel of Record (and their 22 support staffs). 23 2.12. Producing Party: a Party or Non-Party that produces Disclosure or Discovery 24 Material in this Action. 25 2.13. Professional Vendors: persons or entities that provide litigation support 26 services (e.g., photocopying, videotaping, translating, preparing exhibits or 27 28 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 2 their employees and subcontractors. 3 2.14. Protected Material: any Disclosure or Discovery Material that is designated as 4 “CONFIDENTIAL.” 5 2.15. Receiving Party: a Party that receives Disclosure or Discovery Material from a 6 Producing Party. 7 8 3. SCOPE 9 The protections conferred by this Stipulation and Order cover not only Protected 10 Material (as defined above), but also (1) any information copied or extracted from 11 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 12 Material; and (3) any testimony, conversations, or presentations by Parties or their 13 Counsel that might reveal Protected Material. 14 Any use of Protected Material at trial shall be governed by the orders of the trial 15 judge. This Order does not govern the use of Protected Material at trial. 16 17 4. DURATION 18 Once a case proceeds to trial, all of the court-filed information to be introduced 19 that was previously designated as confidential or maintained pursuant to this Order 20 becomes public and will be presumptively available to all members of the public, 21 including the press, unless compelling reasons supported by specific factual findings 22 to proceed otherwise are made to the trial judge in advance of the trial. See, Kamakana 23 v. City and Cty. of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing 24 “good cause” showing for sealing documents produced in discovery from “compelling 25 reasons” standard when merits-related documents are part of court record). 26 Accordingly, the terms of this Order do not extend beyond the commencement of the 27 trial. 28 5. DESIGNATING PROTECTED MATERIAL 2 5.1. EXERCISE OF RESTRAINT AND CARE IN DESIGNATING MATERIAL FOR 3 PROTECTION 4 Each Party or Non-Party that designates information or items for protection 5 under this Order must take care to limit any such designation to specific material that 6 qualifies under the appropriate standards. The Designating Party must designate for 7 protection only those parts of material, documents, items, or oral or written 8 communications that qualify so that other portions of the material, documents, items, 9 or communications for which protection is not warranted are not swept unjustifiably 10 within the ambit of this Order. 11 Mass, indiscriminate, or routinized designations are prohibited. Designations 12 that are shown to be clearly unjustified or that have been made for an improper purpose 13 (e.g., to unnecessarily encumber the case development process or to impose 14 unnecessary expenses and burdens on other parties) may expose the Designating Party 15 to sanctions. 16 If it comes to a Designating Party’s attention that information or items that it 17 designated for protection do not qualify for protection, that Designating Party must 18 promptly notify all other Parties that it is withdrawing the inapplicable designation. 19 5.2. MANNER AND TIMING OF DESIGNATIONS 20 Except as otherwise provided in this Order (see, e.g., second paragraph of 21 section 5.2.1 below), or as otherwise stipulated or ordered, Disclosure or Discovery 22 Material that qualifies for protection under this Order must be clearly so designated 23 before the material is disclosed or produced. 24 Designation in conformity with this Order requires the following: 25 5.2.1. 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 2 portion or portions of the material on a page qualifies for protection, the Producing 3 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 4 markings in the margins). 5 A Party or Non-Party that makes original documents available for inspection 6 need not designate them for protection until after the inspecting Party has indicated 7 which documents it would like copied and produced. During the inspection and before 8 the designation, all of the material made available for inspection shall be deemed 9 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 10 copied and produced, the Producing Party must determine which documents, or 11 portions thereof, qualify for protection under this Order. Then, before producing the 12 specified documents, the Producing Party must affix the “CONFIDENTIAL legend” 13 to each page that contains Protected Material. If only a portion or portions of the 14 material on a page qualifies for protection, the Producing Party also must clearly 15 identify the protected portion(s) (e.g., by making appropriate markings in the margins). 16 5.2.2. for testimony given in depositions that the Designating Party identify the 17 Disclosure or Discovery Material on the record, before the close of the deposition. 18 5.2.3. for information produced in some form other than documentary and for 19 any other tangible items, that the Producing Party affix in a prominent place on the 20 exterior of the container or containers in which the information is stored the legend 21 “CONFIDENTIAL.” If only a portion or portions of the information warrants 22 protection, the Producing Party, to the extent practicable, shall identify the protected 23 portion(s). 24 5.3. INADVERTENT FAILURES TO DESIGNATE 25 If timely corrected, an inadvertent failure to designate qualified information or 26 items does not, standing alone, waive the Designating Party’s right to secure protection 27 under this Order for such material. Upon timely correction of a designation, the 28 Receiving Party must make reasonable efforts to assure that the material is treated in 2 accordance with the provisions of this Order. 3 4 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 5 6.1. TIMING OF CHALLENGES 6 Any Party or Non-Party may challenge a designation of confidentiality at any 7 time that is consistent with the Court’s Scheduling Order. 8 6.2. MEET AND CONFER 9 The Challenging Party shall initiate the dispute resolution process under Local 10 Rule 37-1, et seq. Any discovery motion must strictly comply with the procedures set 11 forth in Local Rules 37-1, 37-2, and 37-3. 12 6.3. JOINT STIPULATION 13 Any challenge submitted to the Court shall be via a joint stipulation pursuant to 14 Local Rule 37-2. 15 6.4. BURDEN 16 The burden of persuasion in any such challenge proceeding shall be on the 17 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., 18 to harass or impose unnecessary expenses and burdens on other parties) may expose 19 the Challenging Party to sanctions. Unless the Designating Party has waived or 20 withdrawn the confidentiality designation, all parties shall continue to afford the 21 material in question the level of protection to which it is entitled under the Producing 22 Party’s designation until the Court rules on the challenge. 23 24 7. ACCESS TO AND USE OF PROTECTED MATERIAL 25 7.1. BASIC PRINCIPLES 26 A Receiving Party may use Protected Material that is disclosed or produced by 27 another Party or by a Non-Party in connection with this Action only for prosecuting, 28 defending, or attempting to settle this Action. Such Protected Material may be 2 disclosed only to the categories of persons and under the conditions described in this 3 Order. When the Action has been terminated, a Receiving Party must comply with the 4 provisions of Section 13 below (FINAL DISPOSITION). 5 Protected Material must be stored and maintained by a Receiving Party at a 6 location and in a secure manner that ensures that access is limited to the persons 7 authorized under this Order. 8 7.2. DISCLOSURE OF “CONFIDENTIAL” INFORMATION OR ITEMS 9 Unless otherwise ordered by the Court or permitted in writing by the 10 Designating Party, a Receiving Party may disclose any information or item designated 11 “CONFIDENTIAL” only to: 12 7.2.1. the Receiving Party’s Outside Counsel of Record in this Action, as well 13 as employees of said Outside Counsel of Record to whom it is reasonably necessary to 14 disclose the information for this Action; 15 7.2.2. the officers, directors, and employees (including House Counsel) of the 16 Receiving Party to whom disclosure is reasonably necessary for this Action; 17 7.2.3. Experts (as defined in this Order) of the Receiving Party to whom 18 disclosure is reasonably necessary for this Action and who have signed the 19 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 20 7.2.4. the Court and its personnel; 21 7.2.5. court reporters and their staff; 22 7.2.6. professional jury or trial consultants, mock jurors, and Professional 23 Vendors to whom disclosure is reasonably necessary for this Action and who have 24 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 25 7.2.7. the author or recipient of a document containing the information or a 26 custodian or other person who otherwise possessed or knew the information; 27 28 7.2.8. during their depositions, witnesses, and attorneys for witnesses, in the 2 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 3 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will 4 not be permitted to keep any confidential information unless they sign the 5 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed 6 by the Designating Party or ordered by the Court. Pages of transcribed deposition 7 testimony or exhibits to depositions that reveal Protected Material may be separately 8 bound by the court reporter and may not be disclosed to anyone except as permitted 9 under this Stipulated Protective Order; and 10 7.2.9. any mediator or settlement officer, and their supporting personnel, 11 mutually agreed upon by any of the parties engaged in settlement discussions. 12 13 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 14 PRODUCED IN OTHER LITIGATION 15 If a Party is served with a subpoena or a court order issued in other litigation that 16 compels disclosure of any information or items designated in this Action as 17 “CONFIDENTIAL,” that Party must: 18 8.1. promptly notify in writing the Designating Party. Such notification shall include 19 a copy of the subpoena or court order; 20 8.2. promptly notify in writing the party who caused the subpoena or order to issue 21 in the other litigation that some or all of the material covered by the subpoena or order 22 is subject to this Protective Order. Such notification shall include a copy of this 23 Stipulated Protective Order; and 24 8.3. cooperate with respect to all reasonable procedures sought to be pursued by the 25 Designating Party whose Protected Material may be affected. 26 If the Designating Party timely seeks a protective order, the Party served with 27 the subpoena or court order shall not produce any information designated in this action 28 as “CONFIDENTIAL” before a determination by the court from which the subpoena 2 or order issued, unless the Party has obtained the Designating Party’s permission. The 3 Designating Party shall bear the burden and expense of seeking protection in that court 4 of its confidential material and nothing in these provisions should be construed as 5 authorizing or encouraging a Receiving Party in this Action to disobey a lawful 6 directive from another court. 7 8 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 9 PRODUCED IN THIS LITIGATION 10 9.1. The terms of this Order are applicable to information produced by a Non-Party 11 in this Action and designated as “CONFIDENTIAL.” Such information produced by 12 Non-Parties in connection with this litigation is protected by the remedies and relief 13 provided by this Order. Nothing in these provisions should be construed as prohibiting 14 a Non-Party from seeking additional protections. 15 9.2. In the event that a Party is required, by a valid discovery request, to produce a 16 Non-Party’s confidential information in its possession, and the Party is subject to an 17 agreement with the Non-Party not to produce the Non-Party’s confidential information, 18 then the Party shall: 19 9.2.1. promptly notify in writing the Requesting Party and the Non-Party that 20 some or all of the information requested is subject to a confidentiality agreement with 21 a Non-Party; 22 9.2.2. promptly provide the Non-Party with a copy of the Stipulated Protective 23 Order in this Action, the relevant discovery request(s), and a reasonably specific 24 description of the information requested; and 25 9.2.3. make the information requested available for inspection by the Non-Party, 26 if requested. 27 28 9.3. If the Non-Party fails to seek a protective order from this Court within 14 days 2 of receiving the notice and accompanying information, the Receiving Party may 3 produce the Non-Party’s confidential information responsive to the discovery request. 4 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce 5 any information in its possession or control that is subject to the confidentiality 6 agreement with the Non-Party before a determination by the Court. Absent a court 7 order to the contrary, the Non-Party shall bear the burden and expense of seeking 8 protection in this Court of its Protected Material. 9 10 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 11 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 12 Protected Material to any person or in any circumstance not authorized under this 13 Stipulated Protective Order, the Receiving Party must immediately (1) notify in writing 14 the Designating Party of the unauthorized disclosures, (2) use its best efforts to retrieve 15 all unauthorized copies of the Protected Material, (3) inform the person or persons to 16 whom unauthorized disclosures were made of all the terms of this Order, and 17 (4) request such person or persons to execute the “Acknowledgment and Agreement to 18 Be Bound” that is attached hereto as Exhibit A. 19 20 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 21 PROTECTED MATERIAL 22 When a Producing Party gives notice to Receiving Parties that certain 23 inadvertently produced material is subject to a claim of privilege or other protection, 24 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 25 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 26 may be established in an e-discovery order that provides for production without prior 27 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 28 parties reach an agreement on the effect of disclosure of a communication or 2 information covered by the attorney-client privilege or work product protection, the 3 parties may incorporate their agreement in the stipulated protective order submitted to 4 the Court. 5 6 12. MISCELLANEOUS 7 12.1. RIGHT TO FURTHER RELIEF 8 Nothing in this Order abridges the right of any person to seek its modification 9 by the Court in the future. 10 12.2. RIGHT TO ASSERT OTHER OBJECTIONS 11 By stipulating to the entry of this Protective Order, no Party waives any right it 12 otherwise would have to object to disclosing or producing any information or item on 13 any ground not addressed in this Stipulated Protective Order. Similarly, no Party 14 waives any right to object on any ground to use in evidence of any of the material 15 covered by this Protective Order. 16 12.3. FILING PROTECTED MATERIAL 17 A Party that seeks to file under seal any Protected Material must comply with 18 Civil Local Rule 79-5. Protected Material may only be filed under seal pursuant to a 19 court order authorizing the sealing of the specific Protected Material at issue; good 20 cause must be shown in the request to file under seal. If a Party’s request to file 21 Protected Material under seal is denied by the Court, then the Receiving Party may file 22 the information in the public record unless otherwise instructed by the Court. 23 24 13. FINAL DISPOSITION 25 After the final disposition of this Action, within 60 days of a written request by 26 the Designating Party, each Receiving Party must return all Protected Material to the 27 Producing Party or destroy such material. As used in this subdivision, “all Protected 28 Material” includes all copies, abstracts, compilations, summaries, and any other format 2 reproducing or capturing any of the Protected Material. Whether the Protected Material 3 is returned or destroyed, the Receiving Party must submit a written certification to the 4 Producing Party (and, if not the same person or entity, to the Designating Party) by the 5 60 day deadline that (1) identifies (by category, where appropriate) all the Protected 6 Material that was returned or destroyed, and (2) affirms that the Receiving Party has 7 not retained any copies, abstracts, compilations, summaries or any other format 8 reproducing or capturing any of the Protected Material. Notwithstanding this 9 provision, counsel are entitled to retain an archival copy of all pleadings, motion 10 papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence, 11 deposition and trial exhibits, expert reports, attorney work product, and consultant and 12 expert work product, even if such materials contain Protected Material. Any such 13 archival copies that contain or constitute Protected Material remain subject to this 14 Protective Order as set forth in Section 4 (DURATION). 15 16 14. VIOLATION 17 Any violation of this Order may be punished by any and all appropriate measures 18 including, without limitation, contempt proceedings and/or monetary sanctions. 19 / / / 20 / / / 21 / / / 22 / / / 23 / / / 24 / / / 25 / / / 26 / / / 27 / / / 28 | IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 2 DATED: 10/03/2025 COLLINS + COLLINS LLP 3 4 S By: A 2a SA 6 ALLISON N. IMAM-HEDRICK MICHAEL L. WRONIAK 7 ADAM A. AINSLIE 8 Attorneys for Defendants CITY OF PLACENTIA, OFFICER 9 CONTRERAS, OFFICER LEMUS, SGT 10 TOM MCKENZIE, CHIEF BUTTS, FORMER CHIEF LENYIT 11 12 || DATED: 10/03/2025 LAW OFFICES OF CAREE HARPER 13 By: _/s/ Caree Harper 14 CAREE HARPER Attorney for Plaintiff NOAH SHUMATE 15 16 17 18 19 20 21 22 23 24 25 26 27 28 26759 16

1 ||FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 2 > || DATED: _October 14, 2025 —__ 4 HON. STEPHANIE S. CHRISTENSEN ; UNITED STATES MAGISTRATE JUDGE 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, _____________________________ [full name], of _________________ 4 [full 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 District 6 Court for the Central District of California on ____________ [date] in the case of ______________________________________________________ [insert case 7 name and number]. I agree to comply with and to be bound by all the terms of this 8 Stipulated Protective Order and I understand and acknowledge that failure to so comply 9 could expose me to sanctions and punishment in the nature of contempt. I solemnly 10 promise that I will not disclose in any manner any information or item that is subject to this Stipulated Protective Order to any person or entity except in strict compliance 11 with the provisions of this Order. 12 I further agree to submit to the jurisdiction of the United States District Court 13 for the Central District of California for the purpose of enforcing the terms of this 14 Stipulated Protective Order, even if such enforcement proceedings occur after 15 termination of this action. I hereby appoint __________________________ [full name] of _______________________________________ [full address and 16 telephone number] as my California agent for service of process in connection with 17 this action or any proceedings related to enforcement of this Stipulated Protective 18 Order. 19 Date: ______________ 20

21 City and State where signed: __________________________________ 22

23 24 Printed name: __________________________________ 25 26 Signature: __________________________________ 27

28 State of California, ) (CCP §§ 1013(a) and 2015.5; FRCP 5) 2 ) ss. County of Los Angeles. ) 3 I am employed in the County of Los Angeles. I am over the age of 18 and not a party to the within action. My business 4 address is 790 E. Colorado Boulevard, Suite 600, Pasadena, CA 91101.

On this date, I served the foregoing document described as [PROPOSED] STIPULATED PROTECTIVE ORDER on the 5 interested parties in this action by placing same in a sealed envelope, addressed as follows:

6 SEE ATTACHED SERVICE LIST

7 ☐ (BY MAIL) - I caused such envelope(s) with postage thereon fully prepaid to be placed in the United States mail in Pasadena, California to be served on the parties as indicated on the attached service list. I am “readily familiar” with the firm’s practice of collection and processing correspondence for mailing. Under that practice, it would be deposited with the U.S. Postal Service on 8 that same day with postage thereon fully prepaid at Pasadena, California in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after 9 date of deposit for mailing in affidavit.

10 ☐ (BY CERTIFIED MAIL) – I caused such envelope(s) with postage thereon fully prepaid via Certified Mail Return Receipt Requested to be placed in the United States Mail in Pasadena, California. 11 ☐ FEDERAL EXPRESS - I caused the envelope to be delivered to an authorized courier or driver authorized to receive documents with delivery fees provided for. 12 ☐ (BY ELECTRONIC FILING AND/OR SERVICE) – I served a true copy, with all exhibits, electronically on designated 13 recipients listed on the attached service list.

14 ☐ (ELECTRONIC SERVICE PER CODE CIV. PROC., § 1010.6) – By prior consent or request or as required by rules of court (Code Civ. Proc., § 1010.6 (amended Jan. 1, 2021); Code Civ. Proc., § 1013(g); Cal. Rules of Court, rule 2.251(a)).

15 ☐ (BY PERSONAL SERVICE) - I caused such envelope(s) to be delivered by hand to the office(s) of the addressee(s).

16 Executed on 10/03/2025 at Pasadena, California.

17 ☐ (STATE) - I declare under penalty of perjury under the laws of the State of California that the above is true and correct.

18 ☒ (FEDERAL) - I declare that I am employed in the office of a member of the bar of this court at whose direction the service was m ade. 19

20 ------------------------------------------------------------------------------------- Click "Once" and Type "Name of Person Serving Document" here 21 xx@ccllp.law 22 23 24 25 26 27 28 Case CNCumLLbePr :F 2il:e2 N4-ucmv-b6e5r3:2 2F6M75O9- SSC 2 SERVICE LIST 3 Caree Harper 4 LAW OFFICES OF CAREE HARPER 401 Wilshire Blvd. Suite 1200 Santa Monica, CA 90401 5 T: (213) 386-5078 ch1@attorneyharper.com 6 careeharper@aol.com jorge@attorneyharper.com 7 dwc4009@sbcglobal.net ATTORNEYS FOR PLAINTIFF NOAH SHUMATE

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