Noho Diagnostic Center, Inc. v. City of Los Angeles

• Court: District Court, C.D. California
• Decided: August 7, 2025
• Docket: 2:24-cv-07952
• Status: Unknown

Opinion

8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10

11 NOHO DIAGNOSTIC CENTER, INC; CASE NO. 2:24-cv-07952-ODW-SSC 12 USTIANA SHAGINIAN Hon. Otis D. Wright, II, Ctrm. 5D, 5th Floor (First Street Courthouse) 13 Plaintiff(s), Hon. Magis. Stephanie S. Christensen– Ctrm. 790, ( Roybal) 14 v. 15 CITY OF LOS ANGELES; LOS 16 ANGELES POLICE DEPARTMENT; [PROPOSED] STIPULATED DOE OFFICERS OF THE LOS 17 PROTECTIVE ORDER ANGELES POLICE DEPARTMENT;

18 KENNETH FRANCO; CHIEF MICHAEL MOORE; and DOES 1 19 through 20, inclusive

20 Defendant(s).

27 1 1. INTRODUCTION 2 1.1 Purposes and Limitations. Discovery in this action is likely to involve 3 production of confidential, proprietary, or private information for which special 4 protection from public disclosure and from use for any purpose other than prosecuting 5 this litigation may be warranted. Accordingly, the parties hereby stipulate to and 6 petition the court to enter the following Stipulated Protective Order. The parties 7 acknowledge that this Order does not confer blanket protections on all disclosures or 8 responses to discovery and that the protection it affords from public disclosure and use 9 extends only to the limited information or items that are entitled to confidential 10 treatment under the applicable legal principles. 11 1.2 Good Cause Statement. 12 This action involves the City of Los Angeles (“CITY) and individual sworn police 13 officers of the Los Angeles Police Department (“LAPD”) on one side; and on the other, 14 Plaintiffs who claim damages from the City and LAPD Officers. 15 As such, Plaintiff may seek materials and information that the City maintains as 16 confidential, such as personnel files of the police officers involved in the incident, video 17 recordings (including Body-Worn Video recordings and Digital In-Car Video 18 recordings), audio recordings, and other administrative materials and information 19 currently in the possession of the City and which the City believes needs special 20 protection from public disclosure and from use for any purpose other than prosecuting 21 this litigation. Plaintiff may also seek official information contained in the personnel 22 files of the Police Officers involved in the subject incident, which the City maintains as 23 strictly confidential and which the City believes needs special protection from public 24 disclosure and from use for any purpose other than prosecuting this litigation. 25 The City asserts that the confidentiality of materials and information sought by 26 Plaintiff is recognized by California and federal law as evidenced by, inter alia, 27 California Penal Code section 832.7, California Evidence Code section 1043 et. seq. 1 aff’d, 426 U.S. 394 (1976); Sanchez v. City of Santa Ana, 936 F.2d 1027, 1033 (9th Cir. 2 1990); Miller v. Pancucci, 141 F.R.D. 292 (C.D. Cal. 1992). The City has not and does 3 not publicly release the materials and information referenced above except under a 4 protective order or pursuant to a court order, if at all. These materials and information 5 are of the type that has been used to initiate disciplinary action against LAPD officers 6 and has been used as evidence in disciplinary proceedings, where officers’ conduct was 7 considered to be contrary to LAPD policy. 8 The City contends that absent a protective order delineating the responsibilities 9 of nondisclosure on the part of the parties hereto, there is a specific risk of unnecessary 10 and undue disclosure by one or more of the many attorneys, secretaries, law clerks, 11 paralegals, and expert witnesses involved in the case, as well as the corollary risk of 12 embarrassment, harassment and professional and legal harm on the part of the LAPD 13 officers referenced in the materials and information. 14 Defendants also seek discovery of various information relating to Plaintiff’s 15 damages claims, including employment information, housing information, financial 16 information, and confidential medical records that may be personal, private, and 17 potentially embarrassing if unnecessarily disseminated; thus, Plaintiff contends such 18 information should not be disseminated beyond this litigation. 19 Accordingly, to expedite the flow of information, to facilitate the prompt resolute 20 of disputes over the confidentiality of discovery materials, to adequately protect 21 information the parties are entitled to keep confidential, to ensure that the parties are 22 permitted reasonably necessary uses of such material in preparation for and in the 23 conduct of trial, to address their handling at the end of litigation, and serve the ends of 24 justice, a protective order is necessary, Such information will not be designated as 25 confidential for tactical reasons and nothing will be designated without a good faith 26 belief that it has been maintained in a confidential, non-public manner, and there is good 27 cause why it should not be part of the public record in this case. 1 1.3 Acknowledgment of Procedure for Filing Under Seal. The parties further 2 acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective Order 3 does not entitle them to file confidential information under seal; Local Rule 79-5 sets 4 forth the procedures that must be followed and the standards that will be applied when a 5 party seeks permission from the court to file material under seal. 6 There is a strong presumption that the public has a right of access to judicial 7 proceedings and records in civil cases. In connection with non-dispositive motions, 8 good cause must be shown to support a filing under seal. See Kamakana v. City and 9 Cnty. of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd v. 10 Gen. Motors Corp., 307 F.3d 1206, 1210–11 (9th Cir. 2002), Makar-Welbon v. Sony 11 Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders 12 require good cause showing), and a specific showing of good cause or compelling 13 reasons with proper evidentiary support and legal justification, must be made with 14 respect to Protected Material that a party seeks to file under seal. The parties’ mere 15 designation of Disclosure or Discovery Material as CONFIDENTIAL does not— 16 without the submission of competent evidence by declaration, establishing that the 17 material sought to be filed under seal qualifies as confidential, privileged, or otherwise 18 protectable—constitute good cause. 19 Further, if a party requests sealing related to a dispositive motion or trial, then 20 compelling reasons, not only good cause, for the sealing must be shown, and the relief 21 sought shall be narrowly tailored to serve the specific interest to be protected. See 22 Pintos v. Pac. Creditors Ass’n, 605 F.3d 665, 677–79 (9th Cir. 2010). For each item or 23 type of information, document, or thing sought to be filed or introduced under seal in 24 connection with a dispositive motion or trial, the party seeking protection must 25 articulate compelling reasons, supported by specific facts and legal justification, for the 26 requested sealing order. Again, competent evidence supporting the application to file 27 documents under seal must be provided by declaration. 1 Any document that is not confidential, privileged, or otherwise protectable in its 2 entirety will not be filed under seal if the confidential portions can be redacted. If 3 documents can be redacted, then a redacted version for public viewing, omitting only 4 the confidential, privileged, or otherwise protectable portions of the document, shall be 5 filed. Any application that seeks to file documents under seal in their entirety should 6 include an explanation of why redaction is not feasible. 7 8 2. DEFINITIONS 9 2.1 Action: [this pending federal lawsuit]. [*Option: consolidated or related 10 actions.] 11 2.2 Challenging Party: a Party or Non-Party that challenges the designation of 12 information or items under this Order. 13 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how 14 it is generated, stored or maintained) or tangible things that qualify for protection under 15 Rule 26(c) of the Federal Rules of Civil Procedure, and as specified above in the Good 16 Cause Statement. 17 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 18 support staff). 19 2.5 Designating Party: a Party or Non-Party that designates information or 20 items that it produces in disclosures or in responses to discovery as 21 “CONFIDENTIAL.” 22 2.6 Disclosure or Discovery Material: all items or information, regardless of 23 the medium or manner in which it is generated, stored, or maintained (including, among 24 other things, testimony, transcripts, and tangible things), that are produced or generated 25 in disclosures or responses to discovery in this matter. 26 2.7 Expert: a person with specialized knowledge or experience in a matter 27 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 1 2.8 Final Disposition: the later of (1) dismissal of all claims and defenses in 2 this Action, with or without prejudice; and (2) final judgment herein after the 3 completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of this 4 Action, including the time limits for filing any motions or applications for extension of 5 time pursuant to applicable law. 6 2.9 In-House Counsel: attorneys who are employees of a party to this Action. 7 In-House Counsel does not include Outside Counsel of Record or any other outside 8 counsel. 9 2.10 Non-Party: any natural person, partnership, corporation, association, or 10 other legal entity not named as a Party to this action. 11 2.11 Outside Counsel of Record: attorneys who are not employees of a party to 12 this Action but are retained to represent or advise a party to this Action and have 13 appeared in this Action on behalf of that party or are affiliated with a law firm which 14 has appeared on behalf of that party, and includes support staff. 15 2.12 Party: any party to this Action, including all of its officers, directors, 16 employees, consultants, retained experts, and Outside Counsel of Record (and their 17 support staffs). 18 2.13 Producing Party: a Party or Non-Party that produces Disclosure or 19 Discovery Material in this Action. 20 2.14 Professional Vendors: persons or entities that provide litigation- support 21 services (e.g., photocopying, videotaping, translating, preparing exhibits or 22 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 23 their employees and subcontractors. 24 2.15 Protected Material: any Disclosure or Discovery Material that is designated 25 as “CONFIDENTIAL.” 26 2.16 Receiving Party: a Party that receives Disclosure or Discovery Material 27 from a Producing Party. 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 shall be governed by the orders of the trial 8 judge. This Stipulated Protective Order does not govern the use of Protected Material at 9 trial. 10 11 4. TRIAL AND DURATION 12 The terms of this Stipulated Protective Order apply through Final Disposition of 13 the Action. 14 Once a case proceeds to trial, information that was designated as 15 CONFIDENTIAL or maintained pursuant to this Stipulated Protective Order and used 16 or introduced as an exhibit at trial becomes public and will be presumptively available 17 to all members of the public, including the press, unless compelling reasons supported 18 by specific factual findings to proceed otherwise are made to the trial judge in advance 19 of the trial. See Kamakana, 447 F.3d at 1180–81 (distinguishing “good cause” showing 20 for sealing documents produced in discovery from “compelling reasons” standard when 21 merits-related documents are part of court record). Accordingly, for such materials, the 22 terms of this Stipulated Protective Order do not extend beyond the commencement of 23 the trial. 24 [Optional addition:] 25 Even after Final Disposition of this litigation, the confidentiality obligations 26 imposed by this Stipulated Protective Order shall remain in effect until a Designating 27 Party agrees otherwise in writing or a court order otherwise directs. 1 5. DESIGNATING PROTECTED MATERIAL 2 5.1 Exercise of Restraint and Care in Designating Material for Protection. 3 Each Party or Non-Party that designates information or items for protection under 4 this Order must take care to limit any such designation to specific material that qualifies 5 under the appropriate standards. The Designating Party must designate for protection 6 only those parts of material, documents, items, or oral or written communications that 7 qualify so that other portions of the material, documents, items, or communications for 8 which protection is not warranted are not swept unjustifiably within the ambit of this 9 Order. 10 Mass, indiscriminate, or routinized designations are prohibited. Designations that 11 are shown to be clearly unjustified or that have been made for an improper purpose 12 (e.g., to unnecessarily encumber the case development process or to impose unnecessary 13 expenses and burdens on other parties) may expose the Designating Party to sanctions. 14 If it comes to a Designating Party’s attention that information or items that it 15 designated for protection do not qualify for protection, that Designating Party must 16 promptly notify all other Parties that it is withdrawing the inapplicable designation. 17 5.2 Manner and Timing of Designations. Except as otherwise provided in this 18 Stipulated Protective Order (see, e.g., second paragraph of section 5.2(a) below), or as 19 otherwise stipulated or ordered, Disclosure or Discovery Material that qualifies for 20 protection under this Stipulated Protective Order must be clearly so designated before 21 the material is disclosed or produced. 22 Designation in conformity with this Stipulated Protective Order requires: 23 (a) for information in documentary form (e.g., paper or electronic documents, 24 but excluding transcripts of depositions or other pretrial or trial proceedings), that the 25 Producing Party affix at a minimum, the legend “CONFIDENTIAL” to each page that 26 contains protected material. If only a portion or portions of the material on a page 27 qualifies for protection, the Producing Party also must clearly identify the protected 1 A Party or Non-Party that makes original documents available for inspection need 2 not designate them for protection until after the inspecting Party has indicated which 3 documents it would like copied and produced. During the inspection and before the 4 designation, all of the material made available for inspection shall be deemed 5 CONFIDENTIAL. After the inspecting Party has identified the documents it wants 6 copied and produced, the Producing Party must determine which documents, or portions 7 thereof, qualify for protection under this Stipulated Protective Order. Then, before 8 producing the specified documents, the Producing Party must affix the 9 “CONFIDENTIAL” legend to each page that contains Protected Material. If only a 10 portion or portions of the material on a page qualifies for protection, the Producing 11 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 12 markings in the margins). 13 (b) for testimony given in depositions that the Designating Party identify the 14 Disclosure or Discovery Material on the record, before the close of the deposition all 15 protected testimony. 16 (c) for information produced in some form other than documentary and for 17 any other tangible items, that the Producing Party affix in a prominent place on the 18 exterior of the container or containers in which the information is stored the 19 “CONFIDENTIAL” legend. If only a portion or portions of the information warrants 20 protection, the Producing Party, to the extent practicable, shall identify the protected 21 portion(s). 22 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 23 failure to designate qualified information or items does not, standing alone, waive the 24 Designating Party’s right to secure protection under this Order for such material. Upon 25 timely correction of a designation, the Receiving Party must make reasonable efforts to 26 assure that the material is treated in accordance with the provisions of this Stipulated 27 Protective Order. 1 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 2 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 3 designation of confidentiality at any time that is consistent with the court’s Scheduling 4 Order. 5 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 6 resolution process under Local Rule 37.1 et seq. and with Section 2 of Judge 7 Christensen’s Civil Procedures titled “Brief Pre-Discovery Motion Conference.”1 8 6.3 The burden of persuasion in any such challenge proceeding shall be on the 9 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., 10 to harass or impose unnecessary expenses and burdens on other parties) may expose the 11 Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn 12 the confidentiality designation, all parties shall continue to afford the material in 13 question the level of protection to which it is entitled under the Producing Party’s 14 designation until the court rules on the challenge. 15 16 7. ACCESS TO AND USE OF PROTECTED MATERIAL 17 7.1 Basic Principles. A Receiving Party may use Protected Material that is 18 disclosed or produced by another Party or by a Non-Party in connection with this Action 19 only for prosecuting, defending, or attempting to settle this Action. Such Protected 20 Material may be disclosed only to the categories of persons and under the conditions 21 described in this Order. When the Action reaches a Final Disposition, a Receiving Party 22 must comply with the provisions of section 13 below. 23 Protected Material must be stored and maintained by a Receiving Party at a location and 24 in a secure manner that ensures that access is limited to the persons authorized under 25 this Stipulated Protective Order. 26 27 1 Judge Christensen’s Procedures are available at https://www.cacd.uscourts.gov/honorable-stephanie-s-christensen. 1 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise 2 ordered by the court or permitted in writing by the Designating Party, a Receiving Party 3 may disclose any information or item designated “CONFIDENTIAL” only: 4 (a) to the Receiving Party’s Outside Counsel of Record in this Action, as well 5 as employees of said Outside Counsel of Record to whom it is reasonably necessary to 6 disclose the information for this Action; 7 (b) to the officers, directors, and employees (including House Counsel) of the 8 Receiving Party to whom disclosure is reasonably necessary for this Action; 9 (c) to Experts (as defined in this Order) of the Receiving Party to whom 10 disclosure is reasonably necessary for this Action and who have signed the 11 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 12 (d) to the court and its personnel; 13 (e) to court reporters and their staff; 14 (f) to professional jury or trial consultants, mock jurors, and Professional 15 Vendors to whom disclosure is reasonably necessary for this Action and who have 16 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 17 (g) to the author or recipient of a document containing the information or a 18 custodian or other person who otherwise possessed or knew the information; 19 (h) during their depositions, to witnesses, and attorneys for witnesses, in the 20 Action to whom disclosure is reasonably necessary, provided: (1) the deposing party 21 requests that the witness sign the “Acknowledgment and Agreement to Be Bound” 22 (Exhibit A); and (2) the witness will not be permitted to keep any confidential 23 information unless they sign the “Acknowledgment and Agreement to Be Bound” 24 (Exhibit A), unless otherwise agreed by the Designating Party or ordered by the court. 25 Pages of transcribed deposition testimony or exhibits to depositions that reveal 26 Protected Material may be separately bound by the court reporter and may not be 27 disclosed to anyone except as permitted under this Stipulated Protective Order; and 1 (i) to any mediator or settlement officer, and their supporting personnel, 2 mutually agreed upon by any of the parties engaged in settlement discussions. 3 4 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 5 IN OTHER LITIGATION 6 If a Party is served with a subpoena or a court order issued in other litigation that 7 compels disclosure of any information or items designated in this Action as 8 “CONFIDENTIAL,” that Party must: 9 (a) promptly notify in writing the Designating Party. Such notification shall 10 include a copy of the subpoena or court order; 11 (b) promptly notify in writing the party who caused the subpoena or order to 12 issue in the other litigation that some or all of the material covered by the subpoena or 13 order is subject to this Protective Order. Such notification shall include a copy of this 14 Stipulated Protective Order; and 15 (c) cooperate with respect to all reasonable procedures sought to be pursued by 16 the Designating Party whose Protected Material may be affected. 17 If the Designating Party timely seeks a protective order, the Party served with the 18 subpoena or court order shall not produce any information designated in this action as 19 “CONFIDENTIAL” before a determination by the court from which the subpoena or 20 order issued, unless the Party has obtained the Designating Party’s permission. The 21 Designating Party shall bear the burden and expense of seeking protection in that court 22 of its confidential material and nothing in these provisions should be construed as 23 authorizing or encouraging a Receiving Party in this Action to disobey a lawful 24 directive from another court. 25 26 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 27 PRODUCED IN THIS LITIGATION 1 information produced by a Non-Party in this Action and designated as 2 “CONFIDENTIAL.” Such information produced by Non-Parties in connection with 3 this litigation is protected by the remedies and relief provided by this Order. Nothing in 4 these provisions should be construed as prohibiting a Non-Party from seeking additional 5 protections. 6 9.2 Notification. In the event that a Party is required, by a valid discovery 7 request, to produce a Non-Party’s confidential information in its possession, and the 8 Party is subject to an agreement with the Non-Party not to produce the Non-Party’s 9 confidential information, then the Party shall: 10 (a) promptly notify in writing the Requesting Party and the Non-Party that 11 some or all of the information requested is subject to a confidentiality agreement with a 12 Non-Party; 13 (b) make the information requested available for inspection by the Non-Party, 14 if requested. 15 9.3 Conditions of Production. If the Non-Party fails to seek a protective order 16 from this court within 14 days of receiving the notice and accompanying information, 17 the Receiving Party may produce the Non-Party’s confidential information responsive 18 to the discovery request. If the Non-Party timely seeks a protective order, the Receiving 19 Party shall not produce any information in its possession or control that is subject to the 20 confidentiality agreement with the Non-Party before a determination by the court. 21 Absent a court order to the contrary, the Non-Party shall bear the burden and expense of 22 seeking protection in this court of its Protected Material. 23 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 24 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 25 Protected Material to any person or in any circumstance not authorized under this 26 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 27 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 1 whom unauthorized disclosures were made of all the terms of this Order, and (d) request 2 such person or persons to execute the “Acknowledgment and Agreement to Be Bound” 3 (Exhibit A). 4 5 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 6 PROTECTED MATERIAL 7 When a Producing Party gives notice to Receiving Parties that certain 8 inadvertently produced material is subject to a claim of privilege or other protection, the 9 obligations of the Receiving Parties are those set forth in Rule 26(b)(5)(B) of the 10 Federal Rules of Civil Procedure. This provision is not intended to modify whatever 11 procedure may be established in an e-discovery order that provides for production 12 without prior privilege review. Pursuant to Rules 502(d) and (e) of the Federal Rules of 13 Evidence, insofar as the parties reach an agreement on the effect of disclosure of a 14 communication or information covered by the attorney-client privilege or work product 15 protection, the parties may incorporate their agreement in the stipulated protective order 16 submitted to the court. 17 18 12. MISCELLANEOUS 19 12.1 Right to Further Relief. Nothing in this Stipulated Protective Order 20 abridges the right of any person to seek its modification by the court in the future. 21 12.2 Right to Assert Other Objections. By stipulating to the entry of this 22 Stipulated Protective Order no Party waives any right it otherwise would have to object 23 to disclosing or producing any information or item on any ground not addressed in this 24 Stipulated Protective Order. Similarly, no Party waives any right to object on any 25 ground to use in evidence of any of the material covered by this Stipulated Protective 26 Order. 27 12.3 Filing Protected Material. A Party that seeks to file under seal any 1 filed under seal pursuant to a court order authorizing the sealing of the specific 2 Protected Material at issue. If a Party's request to file Protected Material under seal is 3 denied by the court, then the Receiving Party may file the information in the public 4 record unless otherwise instructed by the court. 5 6 13. FINAL DISPOSITION 7 After the Final Disposition of this Action, as defined in paragraph 4, within 60 8 days of a written request by the Designating Party, each Receiving Party must return all 9 Protected Material to the Producing Party or destroy such material. As used in this 10 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 11 summaries, and any other format reproducing or capturing any of the Protected 12 Material. Whether the Protected Material is returned or destroyed, the Receiving Party 13 must submit a written certification to the Producing Party (and, if not the same person or 14 entity, to the Designating Party) by the 60 day deadline that (1) identifies (by category, 15 where appropriate) all the Protected Material that was returned or destroyed and (2) 16 affirms that the Receiving Party has not retained any copies, abstracts, compilations, 17 summaries or any other format reproducing or capturing any of the Protected Material. 18 Notwithstanding this provision, Counsel is entitled to retain an archival copy of all 19 pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda, 20 correspondence, deposition and trial exhibits, expert reports, attorney work product, and 21 consultant and expert work product, even if such materials contain Protected Material. 22 Any such archival copies that contain or constitute Protected Material remain subject to 23 this Protective Order as set forth in Section 4. 24 25 14. VIOLATION 26 Any violation of this Stipulated Protective Order may be punished by any and all 27 appropriate measures including, without limitation, contempt proceedings and/or 1 2 | IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 3 4 || Dated: July 21, 2025 YMPK Law Group, LLP 5 6 By: /s/ Hayk Yeghoyan Hayk Yeghoyan, Esq. 7 Attorneys for Plaintiff NOHO DIAGNOSTIC 8 CENTER, INC and USTIANA SHAGINIAN 9 10 Dated: August 6, 2025 Respectfully submitted 12 HYDEE FELDSTEIN SOTO, City Attorney 13 DENISE C. MILLS, Chief Deputy City Attorney KATHLEEN KENEALY, Chief Asst. City Attorney 14 CORY M. BRENTE, Senior Assistant City Attorney 15 16 By: |si Yeremy 8. Warren 17 JEREMY B. WARREN, 18 Deputy City Attorney, Attorneys for Defendant, CITY OF LOS ANGELES and 19 LOS ANGELES POLICE DEPARTMENT 20 21 22 3 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 24 Z— 5 Dated: August 7, 2025 HON. STEPHANIE S. CHRISTENSEN 26 United States Magistrate Judge 27 28

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 I, [print or type full name], of 5 [print or type full address], declare under penalty of perjury 6 that I have read in its entirety and understand the Stipulated Protective Order that was 7 issued by the United States District Court for the Central District of California on 8 [date] in the case of NOHO DIAGNOSTIC CENTER, INC; USTIANA 9 SHAGINIAN v. CITY OF LOS ANGELES ET AL., USDC Case No. 2:24-cv-07952- 10 ODW-SSC. I agree to comply with and to be bound by all the terms of this Stipulated 11 Protective Order and I understand and acknowledge that failure to so comply could 12 expose me to sanctions and punishment in the nature of contempt. I solemnly promise 13 that I will not disclose in any manner any information or item that is subject to this 14 Stipulated Protective Order to any person or entity except in strict compliance with the 15 provisions of this Order. 16 I further agree to submit to the jurisdiction of the United States District Court for 17 the Central District of California for the purpose of enforcing the terms of this 18 Stipulated Protective Order, even if such enforcement proceedings occur after 19 termination of this action. I hereby appoint ________________________[print or type 20 full name] of 21 [print or type full address and telephone number] as my California agent for service 22 of process in connection with this action or any proceedings related to enforcement of 23 this Stipulated Protective Order. 24 25 Date: __________________________________ 26 City and State where signed: __________________________________ 27 Printed name: __________________________________