Norma Segovia v. City of Los Angeles

• Court: District Court, C.D. California
• Decided: July 14, 2023
• Docket: 2:23-cv-00415
• Status: Unknown

Opinion

Muammar Reed, Esq., SBN #275133 1 REED LAW, P.C. 5777 W Century Blvd., STE 1088 2 Los Angeles, CA 90045 Tel.: (323) 545-6858 3 Fax: (323) 546-0902 Email: reedm@reedlawyer.com 4 Attorney for Plaintiffs, NORMA SEGOVIA & ISAAC ALEMAN 5

6 HYDEE FELDSTEIN SOTO, City Attorney (SBN 106866) 7 DENISE C. MILLS, Chief Deputy City Attorney (SBN 191992) SCOTT MARCUS, Chief Assistant City Attorney (SBN 184980) 8 CORY M. BRENTE, Senior Assistant City Attorney (SBN 115453) IRVING R. ESTRADA, Deputy City Attorney (SBN 314785) 9 200 N. Main Street, 6th Floor, City Hall East Los Angeles, California 90012 10 Tel: (213) 978-2247 Fax: (213) 978-8785 Email: Irving.Estrada@lacity.org 11 Attorneys for Defendants, CITY OF LOS ANGELES, MILAGROS ACEVES and 12 SAMUEL HONG

14 UNITED STATES DISTRICT COURT 15 CENTRAL DISTRICT OF CALIFORNIA 16

17 NORMA SEGOVIA, an individual, CASE NO. 2:23-cv-00415-JLS-PD ISAAC ALEMAN, an individual, Hon. Josephine L. Staton; 1st St CH – Ctrm. 8A 18 Hon. Mag. Patricia Donahue; Roybal – Ctrm.580 Plaintiffs, 19

20 vs. STIPULATED PROTECTIVE ORDER

21 CITY OF LOS ANGELES, OFFICER ACESVES, an individual, OFFICER 22 HONG, an individual, and DOES 1 23 through 20, inclusive,

24 Defendants. 25

27 1 1. A. PURPOSES AND LIMITATIONS 2 Discovery in this action is likely to involve production of confidential, 3 proprietary, or private information for which special protection from public disclosure 4 and from use for any purpose other than prosecuting this litigation may be warranted. 5 Accordingly, the parties hereby stipulate to and petition the Court to enter the 6 following Stipulated Protective Order. The parties acknowledge that this Order does 7 not confer blanket protections on all disclosures or responses to discovery and that the 8 protection it affords from public disclosure and use extends only to the limited 9 information or items that are entitled to confidential treatment under the applicable 10 legal principles. 11 B. GOOD CAUSE STATEMENT 12 WHEREAS Plaintiffs NORMA SEGOVIA and ISAAC ALEMAN 13 (“Plaintiffs”) are seeking materials and information that Defendant CITY OF LOS 14 ANGELES (“City”) maintains as confidential, including but limited to, video 15 recordings, audio recordings, other confidential information and documents regarding 16 this incident, and other administrative materials and information currently in the 17 possession of the City and which the City believes need special protection from public 18 disclosure and from use for any purpose other than prosecuting this litigation. 19 The City asserts that the confidentiality of the materials and information sought 20 by Plaintiffs is recognized by California and federal law, as evidenced inter alia by 21 California Penal Code section 832.7 and Kerr v. United States Dist. Ct. for N.D. Cal., 22 511 F.2d 192, 198 (9th Cir. 1975), aff'd, 426 U.S. 394 (1976). The City has not 23 publicly released the materials and information referenced above except under 24 protective order or pursuant to a court order, if at all. These materials and information 25 are of the type that has been used to initiate disciplinary action against Los Angeles 26 Police Department (“LAPD”) officers, and has been used as evidence in disciplinary 27 proceedings, where the officers’ conduct was considered to be contrary to LAPD 1 The City contends that absent a protective order delineating the responsibilities 2 of nondisclosure on the part of the parties hereto, there is a specific risk of 3 unnecessary and undue disclosure by one or more of the many attorneys, secretaries, 4 law clerks, paralegals and expert witnesses involved in this case, as well as the 5 corollary risk of embarrassment, harassment and professional and legal harm on the 6 part of the LAPD officers referenced in the materials and information. The unfettered 7 disclosure of the materials and information, absent a protective order, would allow the 8 media to share this information with potential jurors in the area, impacting the rights 9 of Defendant herein to receive a fair trial. 10 Accordingly, to expedite the flow of information, to facilitate the prompt 11 resolution of disputes over confidentiality of discovery materials, to adequately 12 protect information the parties are entitled to keep confidential, to ensure that the 13 parties are permitted reasonable necessary uses of such material in preparation for and 14 in the conduct of trial, to address their handling at the end of the litigation, and serve 15 the ends of justice, a protective order for such information is justified in this matter. It 16 is the intent of the parties that information will not be designated as confidential for 17 tactical reasons and that nothing be so designated without a good faith belief that it 18 has been maintained in a confidential, non-public manner, and there is good cause 19 why it should not be part of the public record of this case. 20 The parties therefore stipulate that there is Good Cause for, and hereby jointly 21 request that the honorable Court issue a Protective Order regarding confidential 22 documents consistent with the terms and provisions of this Stipulation. However, the 23 entry of a Protective Order by the Court pursuant to this Stipulation shall not be 24 construed as any ruling by the Court on the aforementioned legal statements or 25 privilege claims in this section, no shall this section be construed as part of any such 26 Court Order. 27 The City has not publicly released the documents, video or information 1 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 2 The parties further acknowledge, as set forth in Section 12.3, below, that this 3 Stipulated Protective Order does not entitle them to file confidential information 4 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and 5 the standards that will be applied when a party seeks permission from the court to file 6 material under seal. 7 There is a strong presumption that the public has a right of access to judicial 8 proceedings and records in civil cases. In connection with non-dispositive motions, 9 good cause must be shown to support a filing under seal. See Kamakana v. City and 10 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors 11 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc., 12 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require good 13 cause showing), and a specific showing of good cause or compelling reasons with 14 proper evidentiary support and legal justification, must be made with respect to 15 Protected Material that a party seeks to file under seal. The parties’ mere designation 16 of Disclosure or Discovery Material as CONFIDENTIAL does not—without the 17 submission of competent evidence by declaration, establishing that the material 18 sought to be filed under seal qualifies as confidential, privileged, or otherwise 19 protectable—constitute good cause. 20 Further, if a party requests sealing related to a dispositive motion or trial, then 21 compelling reasons, not only good cause, for the sealing must be shown, and the relief 22 sought shall be narrowly tailored to serve the specific interest to be protected. See 23 Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For each item 24 or type of information, document, or thing sought to be filed or introduced under seal 25 in connection with a dispositive motion or trial, the party seeking protection must 26 articulate compelling reasons, supported by specific facts and legal justification, for 27 the requested sealing order. Again, competent evidence supporting the application to 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 5 be filed. Any application that seeks to file documents under seal in their entirety 6 should include an explanation of why redaction is not feasible. 7 8 2. DEFINITIONS 9 2.1 Action: Norma Segovia, et al. v. City of Los Angeles, et al.; 10 Case No.: 2:23-cv-00415-JLS-PD 11 2.2 Challenging Party: a Party or Non-Party that challenges the 12 designation of information or items under this Order. 13 2.3 “CONFIDENTIAL” Information or Items: information (regardless 14 of how it is generated, stored or maintained) or tangible things that qualify for 15 protection under Federal Rule of Civil Procedure 26(c), and as specified above in the 16 Good Cause Statement. 17 2.4 Counsel: Outside Counsel of Record and House Counsel (as well 18 as their support staff). 19 2.5 Designating Party: a Party or Non-Party that designates 20 information or 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, 23 regardless of the medium or manner in which it is generated, stored, or maintained 24 (including, among other things, testimony, transcripts, and tangible things), that are 25 produced or generated in disclosures or responses to discovery in this matter. 26 2.7 Expert: a person with specialized knowledge or experience in a 27 matter pertinent to the litigation who has been retained by a Party or its counsel to 1 2.8 House Counsel: attorneys who are employees of a party to this 2 Action. House Counsel does not include Outside Counsel of Record or any other 3 outside counsel. 4 2.9 Non-Party: any natural person, partnership, corporation, 5 association, or other legal entity not named as a Party to this action. 6 2.10 Outside Counsel of Record: attorneys who are not employees of a 7 party to this Action but are retained to represent or advise a party to this Action and 8 have appeared in this Action on behalf of that party or are affiliated with a law firm 9 which has appeared on behalf of that party, and includes support staff. 10 2.11 Party: any party to this Action, including all of its officers, 11 directors, employees, consultants, retained experts, and Outside Counsel of Record 12 (and their support staffs). 13 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 14 Discovery Material in this Action. 15 2.13 Professional Vendors: persons or entities that provide litigation 16 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 17 demonstrations, and organizing, storing, or retrieving data in any form or medium) 18 and their employees and subcontractors. 19 2.14 Protected Material: any Disclosure or Discovery Material that is 20 designated as “CONFIDENTIAL.” 21 2.15 Receiving Party: a Party that receives Disclosure or Discovery 22 Material from a Producing Party. 23 24 3. SCOPE 25 The protections conferred by this Stipulation and Order cover not only 26 Protected Material (as defined above), but also (1) any information copied or 27 extracted from Protected Material; (2) all copies, excerpts, summaries, or 1 presentations by Parties or their Counsel that might reveal Protected Material. 2 Any use of Protected Material at trial shall be governed by the orders of the trial 3 judge. This Order does not govern the use of Protected Material at trial. 4 5 4. DURATION 6 FINAL DISPOSITION of the action is defined as the conclusion of any 7 appellate proceedings, or, if no appeal is taken, when the time for filing of an appeal 8 has run. Except as set forth below, the terms of this protective order apply through 9 FINAL DISPOSITION of the action. The parties may stipulate that they will be 10 contractually bound by the terms of this agreement beyond FINAL DISPOSITION, 11 but will have to file a separate action for enforcement of the agreement once all 12 proceedings in this case are complete. 13 Once a case proceeds to trial, information that was designated as 14 CONFIDENTIAL or maintained pursuant to this protective order used or introduced 15 as an exhibit at trial becomes public and will be presumptively available to all 16 members of the public, including the press, unless compelling reasons supported by 17 specific factual findings to proceed otherwise are made to the trial judge in advance of 18 the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” showing 19 for sealing documents produced in discovery from “compelling reasons” standard 20 when merits-related documents are part of court record). Accordingly, for such 21 materials, the terms of this protective order do not extend beyond the commencement 22 of the trial. 23 24 5. DESIGNATING PROTECTED MATERIAL 25 5.1 Exercise of Restraint and Care in Designating Material for Protection. 26 Each Party or Non-Party that designates information or items for protection under this 27 Order must take care to limit any such designation to specific material that qualifies 1 only those parts of material, documents, items, or oral or written communications that 2 qualify so that other portions of the material, documents, items, or communications 3 for which protection is not warranted are not swept unjustifiably within the ambit of 4 this Order. 5 Mass, indiscriminate, or routinized designations are prohibited. Designations 6 that are shown to be clearly unjustified or that have been made for an improper 7 purpose (e.g., to unnecessarily encumber the case development process or to impose 8 unnecessary expenses and burdens on other parties) may expose the Designating Party 9 to sanctions. 10 If it comes to a Designating Party’s attention that information or items that it 11 designated for protection do not qualify for protection, that Designating Party must 12 promptly notify all other Parties that it is withdrawing the inapplicable designation. 13 5.2 Manner and Timing of Designations. Except as otherwise provided in 14 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 15 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 16 under this Order must be clearly so designated before the material is disclosed or 17 produced. 18 Designation in conformity with this Order requires: 19 (a) for information in documentary form (e.g., paper or electronic 20 documents, but excluding transcripts of depositions or other pretrial or trial 21 proceedings), that the Producing Party affix at a minimum, the legend 22 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 23 contains protected material. If only a portion or portions of the material on a page 24 qualifies for protection, the Producing Party also must clearly identify the protected 25 portion(s) (e.g., by making appropriate markings in the margins). 26 A Party or Non-Party that makes original documents available for inspection 27 need not designate them for protection until after the inspecting Party has indicated 1 the designation, all of the material made available for inspection shall be deemed 2 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 3 copied and produced, the Producing Party must determine which documents, or 4 portions thereof, qualify for protection under this Order. Then, before producing the 5 specified documents, the Producing Party must affix the “CONFIDENTIAL legend” 6 to each page that contains Protected Material. If only a portion or portions of the 7 material on a page qualifies for protection, the Producing Party also must clearly 8 identify the protected portion(s) (e.g., by making appropriate markings in the 9 margins). 10 (b) for testimony given in depositions that the Designating Party 11 identify the Disclosure or Discovery Material on the record, before the close of the 12 deposition all protected testimony. 13 (c) for information produced in some form other than documentary 14 and for any other tangible items, that the Producing Party affix in a prominent place 15 on the exterior of the container or containers in which the information is stored the 16 legend “CONFIDENTIAL.” If only a portion or portions of the information warrants 17 protection, the Producing Party, to the extent practicable, shall identify the protected 18 portion(s). 19 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 20 failure to designate qualified information or items does not, standing alone, waive the 21 Designating Party’s right to secure protection under this Order for such material. 22 Upon timely correction of a designation, the Receiving Party must make reasonable 23 efforts to assure that the material is treated in accordance with the provisions of this 24 Order. 25 26 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 27 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 1 Scheduling Order. 2 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 3 resolution process under Local Rule 37.1 et seq. 4 6.3 The burden of persuasion in any such challenge proceeding shall be on 5 the Designating Party. Frivolous challenges, and those made for an improper purpose 6 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 7 expose the Challenging Party to sanctions. Unless the Designating Party has waived 8 or withdrawn the confidentiality designation, all parties shall continue to afford the 9 material in question the level of protection to which it is entitled under the Producing 10 Party’s designation until the Court rules on the challenge. 11 12 7. ACCESS TO AND USE OF PROTECTED MATERIAL 13 7.1 Basic Principles. A Receiving Party may use Protected Material that is 14 disclosed or produced by another Party or by a Non-Party in connection with this 15 Action only for prosecuting, defending, or attempting to settle this Action. Such 16 Protected Material may be disclosed only to the categories of persons and under the 17 conditions described in this Order. When the Action has been terminated, a Receiving 18 Party must comply with the provisions of section 13 below (FINAL DISPOSITION). 19 Protected Material must be stored and maintained by a Receiving Party at a 20 location and in a secure manner that ensures that access is limited to the persons 21 authorized under this Order. 22 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 23 otherwise ordered by the court or permitted in writing by the Designating Party, a 24 Receiving Party may disclose any information or item designated “CONFIDENTIAL” 25 only to: 26 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 27 well as employees of said Outside Counsel of Record to whom it is reasonably 1 (b) the officers, directors, and employees (including House Counsel) 2 of the Receiving Party to whom disclosure is reasonably necessary for this Action; 3 (c) Experts (as defined in this Order) of the Receiving Party to whom 4 disclosure is reasonably necessary for this Action and who have signed the 5 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 6 (d) the court and its personnel; 7 (e) court reporters and their staff; 8 (f) professional jury or trial consultants, mock jurors, and Professional 9 Vendors to whom disclosure is reasonably necessary for this Action and who have 10 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 11 (g) the author or recipient of a document containing the information or 12 a custodian or other person who otherwise possessed or knew the information; 13 (h) during their depositions, witnesses, and attorneys for witnesses, in 14 the Action to whom disclosure is reasonably necessary provided: (1) the deposing 15 party requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they 16 will not be permitted to keep any confidential information unless they sign the 17 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed 18 by the Designating Party or ordered by the court. Pages of transcribed deposition 19 testimony or exhibits to depositions that reveal Protected Material may be separately 20 bound by the court reporter and may not be disclosed to anyone except as permitted 21 under this Stipulated Protective Order; and 22 (i) any mediator or settlement officer, and their supporting personnel, 23 mutually agreed upon by any of the parties engaged in settlement discussions. 24 25 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 26 OTHER LITIGATION 27 If a Party is served with a subpoena or a court order issued in other litigation 1 “CONFIDENTIAL,” that Party must: 2 (a) promptly notify in writing the Designating Party. Such notification 3 shall include a copy of the subpoena or court order; 4 (b) promptly notify in writing the party who caused the subpoena or 5 order to issue in the other litigation that some or all of the material covered by the 6 subpoena or order is subject to this Protective Order. Such notification shall include a 7 copy of this Stipulated Protective Order; and 8 (c) cooperate with respect to all reasonable procedures sought to be 9 pursued by the Designating Party whose Protected Material may be affected. 10 If the Designating Party timely seeks a protective order, the Party served 11 with the subpoena or court order shall not produce any information designated in this 12 action as “CONFIDENTIAL” before a determination by the court from which the 13 subpoena or order issued, unless the Party has obtained the Designating Party’s 14 permission. The Designating Party shall bear the burden and expense of seeking 15 protection in that court of its confidential material and nothing in these provisions 16 should be construed as authorizing or encouraging a Receiving Party in this Action to 17 disobey a lawful directive from another court. 18 19 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 20 PRODUCED IN THIS LITIGATION 21 (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 23 produced by Non-Parties in connection with this litigation is protected by the 24 remedies and relief provided by this Order. Nothing in these provisions should be 25 construed as prohibiting a Non-Party from seeking additional protections. 26 (b) In the event that a Party is required, by a valid discovery request, to 27 produce a Non-Party’s confidential information in its possession, and the Party is 1 information, then the Party shall: 2 (1) promptly notify in writing the Requesting Party and the Non-Party 3 that some or all of the information requested is subject to a confidentiality agreement 4 with a Non-Party; 5 (2) promptly provide the Non-Party with a copy of the Stipulated 6 Protective Order in this Action, the relevant discovery request(s), and a reasonably 7 specific description of the information requested; and 8 (3) make the information requested available for inspection by the 9 Non-Party, if requested. 10 (c) If the Non-Party fails to seek a protective order from this court within 14 11 days of receiving the notice and accompanying information, the Receiving Party may 12 produce the Non-Party’s confidential information responsive to the discovery request. 13 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce 14 any information in its possession or control that is subject to the confidentiality 15 agreement with the Non-Party before a determination by the court. Absent a court 16 order to the contrary, the Non-Party shall bear the burden and expense of seeking 17 protection in this court of its Protected Material. 18 19 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 20 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 21 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 23 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 24 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 25 persons to whom unauthorized disclosures were made of all the terms of this Order, 26 and (d) request such person or persons to execute the “Acknowledgment and 27 Agreement to Be Bound” that is attached hereto as Exhibit A. 1 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 2 PROTECTED MATERIAL 3 When a Producing Party gives notice to Receiving Parties that certain 4 inadvertently produced material is subject to a claim of privilege or other protection, 5 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 6 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 7 may be established in an e-discovery order that provides for production without prior 8 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 9 parties reach an agreement on the effect of disclosure of a communication or 10 information covered by the attorney-client privilege or work product protection, the 11 parties may incorporate their agreement in the stipulated protective order submitted to 12 the court. 13 14 12. MISCELLANEOUS 15 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 16 person to seek its modification by the Court in the future. 17 12.2 Right to Assert Other Objections. By stipulating to the entry of this 18 Protective Order no Party waives any right it otherwise would have to object to 19 disclosing or producing any information or item on any ground not addressed in this 20 Stipulated Protective Order. Similarly, no Party waives any right to object on any 21 ground to use in evidence of any of the material covered by this Protective Order. 22 12.3 Filing Protected Material. A Party that seeks to file under seal any 23 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 24 only be filed under seal pursuant to a court order authorizing the sealing of the 25 specific Protected Material at issue. If a Party's request to file Protected Material 26 under seal is denied by the court, then the Receiving Party may file the information in 27 the public record unless otherwise instructed by the court. 1 13. FINAL DISPOSITION 2 After the final disposition of this Action, as defined in paragraph 4, within 60 3 days of a written request by the Designating Party, each Receiving Party must return 4 all Protected Material to the Producing Party or destroy such material. As used in this 5 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 6 summaries, and any other format reproducing or capturing any of the Protected 7 Material. Whether the Protected Material is returned or destroyed, the Receiving Party 8 must submit a written certification to the Producing Party (and, if not the same person 9 or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by 10 category, where appropriate) all the Protected Material that was returned or destroyed 11 and (2)affirms that the Receiving Party has not retained any copies, abstracts, 12 compilations, summaries or any other format reproducing or capturing any of the 13 Protected Material. Notwithstanding this provision, Counsel are entitled to retain an 14 archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, 15 legal memoranda, correspondence, deposition and trial exhibits, expert reports, 16 attorney work product, and consultant and expert work product, even if such materials 17 contain Protected Material. Any such archival copies that contain or constitute 18 Protected Material remain subject to this Protective Order as set forth in Section 4 19 (DURATION). 20 / / / 21 / / / 22 / / / 23 / / / 24 / / / 25 / / / 26 / / / 27 / / / 1 |}14. | Any violation of this Order may be punished by any and all appropriate 2 ||measures including, without limitation, contempt proceedings and/or monetary 3 || sanctions. 4 5 || IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 6 7 ||DATED: July 10, 2023 8 9 ~ Z—> 10 Attorney for Plaintiffs 11 12 ||DATED: July 12, 2023 13 || 15 || Attorneys for Defendants 16 17 18 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 19 20 DATED: July 14, 2023 21 Lo » Patiuar Marna hue 3 Patricia Donahue . United States Magistrate Judge 24 25 26 27 28 1G

1 EXHIBIT A ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 2

3 I, ________________________ [print or type full name], of 4 ________________ [print or type full address], declare under penalty of perjury 5 that I have read in its entirety and understand the Stipulated Protective Order that 6 was issued by the United States District Court for the Central District of California 7 on [date] in the case of Norma Segovia, et al. v. City of Los Angeles, et al., Case 8 No.: 2:23-cv-00415-JLS-PD. I agree to comply with and to be bound by all the 9 terms of this Stipulated Protective Order and I understand and acknowledge that 10 failure to so comply could expose me to sanctions and punishment in the nature of 11 contempt. I solemnly promise that I will not disclose in any manner any information 12 or item that is subject to this Stipulated Protective Order to any person or entity 13 except in strict compliance with the provisions of this Order. 14 I further agree to submit to the jurisdiction of the United States District Court 15 for the Central District of California for the purpose of enforcing the terms of this 16 Stipulated Protective Order, even if such enforcement proceedings occur after 17 termination of this action. I hereby appoint ________________________ [print or 18 type full name] of _________ [print or type full address and telephone 19 number] as my California agent for service of process in connection with this 20 action or any proceedings related to enforcement of this Stipulated Protective 21 Order. 22

23 Date: __________________________ 24 City and State where sworn and signed: _____________________________ 25

26 Printed name: ____________________________________ 27