Sandy Sedlick v. City of Redlands

• Court: District Court, C.D. California
• Decided: July 5, 2023
• Docket: 5:23-cv-00457
• Status: Unknown

Opinion

11 THE SEHAT LAW FIRM, PLC

Cameron Sehat, Esq. (SBN 256535) 22 5100 Campus Drive, Suite 200 33 Newport Beach, CA 92612

Telephone: (949) 825-5200 44 Facsimile: (949) 313-5001 55 Email: Cameron@sehatlaw.com

66 Attorney for Plaintiffs, SANDY SEDLICK and 77 JOSEPH SEDLICK

88 JONES MAYER 99 James R. Touchstone, SBN 184584

1100 jrt@jones-mayer.com Danielle J. Williams, SBN 317229 1111 djw@jones-mayer.com

1122 3777 N. Harbor Blvd. Fullerton, CA 92835 1133 Telephone: (714) 446-1400

1144 Facsimile: (714) 446-1448

1155 Attorneys for Defendants, CITY OF REDLANDS,

1166 YESSENIA BLEVENS, TYLER FRISCH, TYLER SIMONSEN, AND ISAAC SPIEGEL 1177

1188 UNITED STATES DISTRICT COURT

1199 CENTRAL DISTRICT OF CALIFORNIA

2211 SANDY SEDLICK and JOSEPH Case No: 5:23-cv-00457-JGB-KK

2222 SEDLICK, individually and as Judge: Hon. Jesus G. Bernal successors-in-interest Of the Estate of Magistrate Judge: Hon. Kenly Kiya Kato 2233 the deceased ROBERT SAUL

2244 JUAREZ IV,

2255 [PROPOSED] STIPULATED

2266 Plaintiff, PROTECTIVE ORDER

2277 v. 11 CITY OF REDLANDS, YESSENIA

BLEVENS, TYLER FRISCH, TYLER 22 SIMONSEN, ISAAC SPIEGEL, and 33 DOES 1-10 inclusive,

44 Defendants. 55

66 [PROPOSED] STIPULATED PROTECTIVE ORDER

77 Pursuant to Federal Rule of Civil Procedure 26(c), Defendants, CITY OF

88 REDLANDS, YESSENIA BLEVENS, TYLER FRISCH, TYLER SIMONSEN,

99 ISAAC SPIEGEL, and Plaintiffs SANDY SEDLICK and JOSEPH SEDLICK

1100 (collectively "the Parties"), by their undersigned counsel, agree to be bound to the

1111 terms of the following Protective Order. The Parties represent that pre-trial

1122 discovery in this case is likely to include the production of information and/or

1133 documents that are confidential and/or privileged including the production of peace

1144 officer personnel file information and/or documents which the Parties agree

1155 includes: (1) Personal data, including marital status, family members, educational

1166 and employment history, home addresses, or similar information; (2) Medical

1177 history; (3) Election of employee benefits; (4) Employee advancement, appraisal,

1188 or discipline; and (5) Complaints, or investigations of complaints, concerning an

1199 event or transaction in which a peace officer participated, or which a peace officer

2200 perceived, and pertaining to the manner in which the peace officer performed his or

2211 her duties including compelled statements by peace officers unless specifically

2222 denoted as “not confidential” pursuant to Penal Code section 832.7. Defendants

2233 contend that such information is privileged as official information. Sanchez v. City

2244 of Santa Ana, 936 F.2d 1027, 1033 (9th Cir. Cal. 1990); see also Kerr v. United

2255 States Dist. Ct. for N.D. Cal., 511 F.2d 192, 198 (9th Cir.1975), aff'd, 426 U.S. 394,

2266 96 S.Ct. 2119, 48 L.Ed.2d 725 (1976). Further, discovery may require the

2277 production of certain Redlands Police Department’s Office Policies and Procedures 11 safety, raise security issues, and/or impede investigations. Peace officer personnel 22 file information and/or documents and security-sensitive policies and procedures 33 are hereinafter referred to as "Confidential Information". 44 Defendants contend that that public disclosure of such material poses a 55 substantial risk of embarrassment, oppression and/or physical harm to peace 66 officers whose Confidential Information is disclosed. The Parties further agree that 77 the risk of harm to peace officers is greater than with other government employees 88 due to the nature of their profession. Finally, Defendants contend that the benefit of 99 public disclosure of Confidential Information is minimal while the potential 1100 disadvantages are great. 1111 Accordingly, good cause exists for entry of this Protective Order to 1122 facilitate pre-trial disclosure while assuring the safety of these sensitive 1133 disclosures. See Fed. R. Civ. Proc. 26(c). 1144

1155 IT IS SO STIPULATED. 1166

1177 Respectfully submitted, 1188

1199 Dated: June 29, 2023 THE SEHAT LAW FIRM, PLC

2211 By: /s/ Cameron Sehat Cameron Sehat 2222 Attorney for Plaintiffs, 2233 SANDY SEDLICK and JOSEPH SEDLICK

2255 Dated: June 29, 2023 JONES MAYER

2277 By:__/s/ Danielle J. Williams___________ JAMES R. TOUCHSTONE 11 DANIELLE J. WILLIAMS

Attorneys for Defendants, 22 CITY OF REDLANDS, YESSENIA 33 BLEVENS, TYLER FRISCH, TYLER

SIMONSEN, and ISAAC SPIEGEL 44

55 [PROPOSED] STIPULATED PROTECTIVE ORDER 66 PER THE STIPULATION OF THE PARTIES AND GOOD CAUSE 77 APPEARING, IT IS HEREBY ORDERED that the terms and conditions of this 88 Protective Order shall govern the handling of Discovery Materials containing 99 Confidential Information in matter of Sandy Sedlick, et al. v. City of Redlands, et 1100 al., Case No.: 5:23-cv-00457-JGB-KK ("the Litigation"): 1111 1. A. PURPOSES AND LIMITATIONS 1122 Discovery in this action is likely to involve production of confidential,

1133 proprietary, or private information for which special protection from public

1144 disclosure and from use for any purpose other than prosecuting this litigation may

1155 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to

1166 enter the following Stipulated Protective Order. The parties acknowledge that this

1177 Order does not confer blanket protections on all disclosures or responses to

1188 discovery and that the protection it affords from public disclosure and use extends

1199 only to the limited information or items that are entitled to confidential treatment

2200 under the applicable legal principles. The parties further acknowledge, as set forth

2211 in Section 12.3, below, that this Stipulated Protective Order does not entitle them

to file confidential information under seal; Civil Local Rule 79-5 sets forth the 2222 procedures that must be followed and the standards that will be applied when a party 2233 seeks permission from the court to file material under seal. 2244 B. GOOD CAUSE STATEMENT 2255 Pursuant to Federal Rule of Civil Procedure 26(c), the Court recognizes that 2266 pre-trial discovery in this case is likely to include the production of information 2277 and/or documents that are confidential and/or privileged including the production 11 of peace officer personnel file information and/or documents which the Court 22 agrees includes: (1) Personal data, including marital status, family members,

33 educational and employment history, home addresses, or similar information; (2)

44 Medical history; (3) Election of employee benefits; (4) Employee advancement,

55 appraisal, or discipline; and (5) Complaints, or investigations of complaints,

66 concerning an event or transaction in which a peace officer participated, or which a

77 peace officer perceived, and pertaining to the manner in which the peace officer

88 performed his or her duties including compelled statements by peace officers except

99 such information as is deemed “not confidential” pursuant to Penal Code section

1100 832.7. Such information is privileged as official information. Sanchez v. City of

Santa Ana, 936 F.2d 1027, 1033 (9th Cir. Cal. 1990); see also Kerr v. United States 1111

Dist. Ct. for N.D. Cal., 511 F.2d 192, 198 (9th Cir.1975), aff'd, 426 U.S. 394, 96 1122 S.Ct. 2119, 48 L.Ed.2d 725 (1976). Further, the Court recognizes that discovery 1133 may require the production of certain Redlands Police Department Policies and 1144 Procedures not available to the public and the public disclosure of which could 1155 comprise officer safety, raise security issues, and/or impede investigations. Peace 1166 officer personnel file information and/or documents and security-sensitive policies 1177 and procedures are hereinafter referred to as "Confidential Information" or 1188 “Protected Material”. 1199 Public disclosure of such material poses a substantial risk of embarrassment, 2200 oppression and/or physical harm to peace officers whose Confidential Information

2211 is disclosed. Additionally, the risk of harm to peace officers is greater than with

2222 other government employees due to the nature of their profession. Finally, the

2233 benefit of public disclosure of Confidential Information is minimal while the

2244 potential disadvantages are great. Accordingly, good cause exists for entry of this

2255 Protective Order to facilitate pre-trial disclosure while assuring the safety of these

2266 sensitive disclosures. See Fed. R. Civ. Proc. 26(c).

2277 2. DEFINITIONS

2.1 Action: Sandy Sedlick, et al. v. City of Redlands, et al., Case No.: 11 5:23-cv-00457-JGB-KK, pending before the United States District Court, Central 22 District of California.

33 2.2 Challenging Party: a Party or Non-Party that challenges the

44 designation of information or items under this Order.

55 2.3 “CONFIDENTIAL” Information or Items: information

66 (regardless of how it is generated, stored or maintained) or tangible things that

77 qualify for protection under Federal Rule of Civil Procedure 26(c), and as specified

88 above in the Good Cause Statement.

99 2.4 Counsel: Outside Counsel of Record and House Counsel (as well

1100 as their support staff).

2.5 Designating Party: a Party or Non-Party that designates 1111

information or items that it produces in disclosures or in responses to discovery as 1122 “CONFIDENTIAL.” 1133 2.6 Disclosure or Discovery Material: all items or information, 1144 regardless of the medium or manner in which it is generated, stored, or maintained 1155 (including, among other things, testimony, transcripts, and tangible things), that are 1166 produced or generated in disclosures or responses to discovery in this matter. 1177 2.7 Expert: a person with specialized knowledge or experience in a 1188 matter pertinent to the litigation who has been retained by a Party or its counsel to 1199 serve as an expert witness or as a consultant in this Action. 2200 2.8 House Counsel: attorneys who are employees of a party to this

2211 Action. House Counsel does not include Outside Counsel of Record or any other

2222 outside counsel.

2233 2.9 Non-Party: any natural person, partnership, corporation,

2244 association, or other legal entity not named as a Party to this action.

2255 2.10 Outside Counsel of Record: attorneys who are not employees of

2266 a party to this Action but are retained to represent or advise a party to this Action

2277 and have appeared in this Action on behalf of that party or are affiliated with a law

firm which has appeared on behalf of that party, and includes support staff. 11 2.11 Party: any party to this Action, including all of its officers, 22 directors, employees, consultants, retained experts, and Outside Counsel of Record

33 (and their support staffs).

44 2.12 Producing Party: a Party or Non-Party that produces Disclosure

55 or Discovery Material in this Action.

66 2.13 Professional Vendors: persons or entities that provide litigation

77 support services (e.g., photocopying, videotaping, translating, preparing exhibits or

88 demonstrations, and organizing, storing, or retrieving data in any form or medium)

99 and their employees and subcontractors.

1100 2.14 Protected Material: any Disclosure or Discovery Material that is

designated as “CONFIDENTIAL.” 1111

2.15 Receiving Party: a Party that receives Disclosure or Discovery 1122 Material from a Producing Party. 1133 3. SCOPE 1144 The protections conferred by this Stipulation and Order cover not only 1155 Protected Material (as defined above), but also (1) any information copied or 1166 extracted from Protected Material; (2) all copies, excerpts, summaries, or 1177 compilations of Protected Material; and (3) any testimony, conversations, or 1188 presentations by Parties or their Counsel that might reveal Protected Material. Any 1199 use of Protected Material at trial shall be governed by the orders of the trial judge. 2200 This Order does not govern the use of Protected Material at trial. 2211 4. DURATION 2222 Even after final disposition of this litigation, the confidentiality obligations 2233 imposed by this Order will remain in effect until a Designating Party agrees 2244 otherwise in writing or a court order otherwise directs. Final disposition is the later 2255 of (1) dismissal of all claims and defenses in this Action, with or without prejudice, 2266 or (2) final judgment after the completion and exhaustion of all appeals, rehearings, 2277 remands, trials, or reviews of this Action, including the time limits for filing any 11 motions or applications for extension of time under applicable law. 22 5. DESIGNATING PROTECTED MATERIAL 33 5.1 Each Party or Nonparty that designates information or items for 44 protection under this Order must take care to limit any such designation to specific 55 material that qualifies under the appropriate standards. The Designating Party must 66 designate for protection only those parts of material, documents, items, or oral or 77 written communications that qualify so that other portions of the material, 88 documents, items, or communications for which protection is not warranted are not 99 swept unjustifiably within the ambit of this Order. 1100 Mass, indiscriminate, or routinized designations are prohibited. Designations 1111 that are shown to be clearly unjustified or that have been made for an improper 1122 purpose (for example, to unnecessarily encumber the case-development process or 1133 to impose unnecessary expenses and burdens on other parties) may expose the 1144 Designating Party to sanctions. 1155 If it comes to a Designating Party’s attention that information or items it 1166 designated for protection do not qualify for that level of protection, that Designating 1177 Party must promptly notify all other Parties that it is withdrawing the inapplicable 1188 designation. 1199 5.2 Except as otherwise provided in this Order, Disclosure or 2200 Discovery Material that qualifies for protection under this Order must be clearly so 2211 designated before the material is disclosed or produced. Designation in conformity 2222 with this Order requires the following: 2233 (a) for information in documentary form (for example, paper or electronic 2244 documents but excluding transcripts of depositions or other pretrial or trial 2255 proceedings), the Producing Party must affix at a minimum the legend 2266 “CONFIDENTIAL” to each page that contains Protected Material. If only a portion 2277 or portions of the material on a page qualify for protection, the Producing Party 11 must clearly identify the protected portion(s) (for example, by making appropriate 22 markings in the margins). 33 A Party or Nonparty that makes original documents available for inspection 44 need not designate them for protection until after the inspecting Party has indicated 55 which documents it would like copied and produced. During the inspection and 66 before the designation, all material made available for inspection must be treated as 77 “CONFIDENTIAL.” After the inspecting Party has identified the documents it 88 wants copied and produced, the Producing Party must determine which documents, 99 or portions thereof, qualify for protection under this Order. Then, before producing 1100 the specified documents, the Producing Party must affix the “CONFIDENTIAL” 1111 legend to each page that contains Protected Material. If only a portion or portions 1122 of the material on a page qualify for protection, the Producing Party also must 1133 clearly identify the protected portion(s) (for example, by making appropriate 1144 markings in the margins). 1155 (b) for testimony given in depositions, the Designating Party must identify 1166 the Disclosure or Discovery Material that is protected on the record, before the close 1177 of the deposition. 1188 (c) for information produced in some form other than documentary and for 1199 any other tangible items, the Producing Party must affix in a prominent place on the 2200 exterior of the container or containers in which the information is stored the legend 2211 “CONFIDENTIAL.” If only a portion or portions of the information warrant 2222 protection, the Producing Party, to the extent practicable, must identify the 2233 protected portion(s). 2244 5.3 If timely corrected, an inadvertent failure to designate qualified 2255 information or items does not, standing alone, waive the Designating Party’s right 2266 to secure protection under this Order for that material. On timely correction of a 2277 designation, the Receiving Party must make reasonable efforts to assure that the 11 material is treated in accordance with the provisions of this Order. 22 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 33 6.1 Any Party or Nonparty may challenge a designation of 44 confidentiality at any time consistent with the Court’s scheduling order. 55 6.2 The Challenging Party must initiate the dispute-resolution 66 process (and, if necessary, file a discovery motion) under Local Rule 37. 77 6.3 The burden of persuasion in any such proceeding is on the 88 Designating Party. Frivolous challenges, and those made for an improper purpose 99 (for example, to harass or impose unnecessary expenses and burdens on other 1100 parties), may expose the Challenging Party to sanctions. Unless the Designating 1111 Party has waived or withdrawn the confidentiality designation, all parties must 1122 continue to afford the material in question the level of protection to which it is 1133 entitled under the Producing Party’s designation until the Court rules on the 1144 challenge. 1155 7. ACCESS TO AND USE OF PROTECTED MATERIAL 1166 7.1 A Receiving Party may use Protected Material that is disclosed 1177 or produced by another Party or by a Nonparty in connection with this Action only 1188 for prosecuting, defending, or attempting to settle this Action. Such Protected 1199 Material may be disclosed only to the categories of people and under the conditions 2200 described in this Order. When the Action has been terminated, a Receiving Party 2211 must comply with the provisions of Section 13 below (FINAL DISPOSITION). 2222 Protected Material must be stored and maintained by a Receiving Party at a 2233 location and in a manner sufficiently secure to ensure that access is limited to the 2244 people authorized under this Order. 2255 7.2 Unless otherwise ordered by the Court or permitted in writing 2266 by the Designating Party, a Receiving Party may disclose any information or item 2277 designated “CONFIDENTIAL” only to the following people: 11 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 22 as employees of that Outside Counsel of Record to whom it is reasonably necessary 33 to disclose the information for this Action; 44 (b) the officers, directors, and employees (including House Counsel) of the 55 Receiving Party to whom disclosure is reasonably necessary for this Action; 66 (c) Experts (as defined in this Order) of the Receiving Party to whom 77 disclosure is reasonably necessary for this Action and who have signed the 88 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 99 (d) the Court and its personnel; 1100 (e) court reporters and their staff; 1111 (f) professional jury or trial consultants, mock jurors, and Professional 1122 Vendors to whom disclosure is reasonably necessary for this Action and who have 1133 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 1144 (g) the author or recipient of a document containing the information or a 1155 custodian or other person who otherwise possessed or knew the information; 1166 (h) during their depositions, witnesses and attorneys for witnesses to whom 1177 disclosure is reasonably necessary, provided that the deposing party requests that 1188 the witness sign the form attached as Exhibit A hereto and the witnesses will not be 1199 permitted to keep any confidential information unless they sign the form, unless 2200 otherwise agreed by the Designating Party or ordered by the Court. Pages of 2211 transcribed deposition testimony or exhibits to depositions that reveal Protected 2222 Material may be separately bound by the court reporter and may not be disclosed to 2233 anyone except as permitted under this Order; and 2244 (i) any mediator or settlement officer, and their supporting personnel, 2255 mutually agreed on by any of the Parties engaged in settlement discussions or 2266 appointed by the Court. 2277 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 11 PRODUCED IN OTHER LITIGATION 22 If a Party is served with a subpoena or a court order issued in other litigation 33 that compels disclosure of any information or items designated in this Action as 44 “CONFIDENTIAL,” that Party must: 55 (a) promptly notify in writing the Designating Party. Such notification must 66 include a copy of the subpoena or court order unless prohibited by law; 77 (b) promptly notify in writing the party who caused the subpoena or order to 88 issue in the other litigation that some or all of the material covered by the subpoena 99 or order is subject to this Protective Order. Such notification must include a copy 1100 of this Order; and 1111 (c) cooperate with respect to all reasonable procedures sought to be pursued 1122 by the Designating Party whose Protected Material may be affected. 1133 If the Designating Party timely seeks a protective order, the Party served with 1144 the subpoena or court order should not produce any information designated in this 1155 action as “CONFIDENTIAL” before a determination on the protective-order 1166 request by the relevant court unless the Party has obtained the Designating Party’s 1177 permission. The Designating Party bears the burden and expense of seeking 1188 protection of its Confidential Material, and nothing in these provisions should be 1199 construed as authorizing or encouraging a Receiving Party in this Action to disobey 2200 a lawful directive from another court. 2211 9. A NONPARTY’S PROTECTED MATERIAL SOUGHT TO BE 2222 PRODUCED IN THIS LITIGATION 2233 (a) The terms of this Order are applicable to information produced by a 2244 Nonparty in this Action and designated as “CONFIDENTIAL.” Such information 2255 is protected by the remedies and relief provided by this Order. Nothing in these 2266 provisions should be construed as prohibiting a Nonparty from seeking additional 2277 protections. 11 (b) In the event that a Party is required by a valid discovery request to 22 produce a Nonparty’s Confidential Information in its possession and the Party is 33 subject to an agreement with the Nonparty not to produce the Nonparty’s 44 Confidential Information, then the Party must: 55 (1) promptly notify in writing the Requesting Party and the Nonparty 66 that some or all of the information requested is subject to a 77 confidentiality agreement with a Nonparty; 88 (2) promptly provide the Nonparty with a copy of this Order, the 99 relevant discovery request(s), and a reasonably specific description of 1100 the information requested; and 1111 (3) make the information requested available for inspection by the 1122 Nonparty, if requested. 1133 (c) If the Nonparty fails to seek a protective order within 21 days of receiving 1144 the notice and accompanying information, the Receiving Party may produce the 1155 Nonparty’s Confidential Information responsive to the discovery request. If the 1166 Nonparty timely seeks a protective order, the Receiving Party must not produce any 1177 information in its possession or control that is subject to the confidentiality 1188 agreement with the Nonparty before a ruling on the protective-order request. 1199 Absent a court order to the contrary, the Nonparty must bear the burden and expense 2200 of seeking protection of its Protected Material. 2211 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 2222 If a Receiving Party learns that by inadvertence or otherwise, it has disclosed 2233 Protected Material to any person or in any circumstance not authorized under this 2244 Order, the Receiving Party must immediately notify the Designating Party in 2255 writing of the unauthorized disclosures, use its best efforts to retrieve all 2266 unauthorized copies of the Protected Material, inform the person or people to whom 2277 unauthorized disclosures were made of the terms of this Order, and ask that person 11 or people to execute the “Acknowledgment and Agreement to Be Bound” that is 22 attached hereto as Exhibit A. 33 11. INADVERTENT PRODUCTION OF PRIVILEGED OR 44 OTHERWISE PROTECTED MATERIAL 55 When a Producing Party gives notice to Receiving Parties that certain 66 inadvertently produced material is subject to a claim of privilege or other protection, 77 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 88 Procedure 26(b)(5)(B). 99 12. MISCELLANEOUS 1100 12.1 Nothing in this Order abridges the right of any person to seek its 1111 modification by the Court. 1122 12.2 Under this Order, no Party waives any right it otherwise would 1133 have to object to disclosing or producing any information or item on any ground 1144 not addressed in this Order. Similarly, no Party waives any right to object on any 1155 ground to use in evidence of any of the material covered by this Order. 1166 12.3 A Party that seeks to file under seal any Protected Material must 1177 comply with Civil Local Rule 79-5. Protected Material may be filed under seal only 1188 pursuant to a court order authorizing the sealing of the specific Protected Material 1199 at issue. If a Party's request to file Protected Material under seal is denied, then the 2200 Receiving Party may file the information in the public record unless otherwise 2211 instructed by the Court. 2222 13. FINAL DISPOSITION 2233 After the final disposition of this Action, as defined in paragraph 4, within 60 2244 days of a written request by the Designating Party, each Receiving Party must return 2255 all Protected Material to the Producing Party or destroy such material. As used in 2266 this subdivision, “all Protected Material” includes all copies, abstracts, 2277 compilations, summaries, and any other format reproducing or capturing any of the Protected Material. Whether the Protected Material is returned or destroyed, the Receiving Party must submit a written certification to the Producing Party (and, if not the same person or entity, to the Designating Party) by the 60-day deadline that identifies (by category, when appropriate) all the Protected Material that was ° returned or destroyed and affirms that the Receiving Party has not retained any 6 copies, abstracts, compilations, summaries, or any other format reproducing or ’ capturing any of the Protected Material. Notwithstanding this provision, Counsel are entitled to retain an archival copy of all pleadings; motion papers; trial, ° deposition, and hearing transcripts; legal memoranda; correspondence; deposition and trial exhibits; expert reports; attorney work product; and consultant and expert work product even if such materials contain Protected Material. Any such archival "2 copies that contain or constitute Protected Material remain subject to this Order as 8 set forth in Section 4 (DURATION). 4 14. SANCTIONS Any willful violation of this Order may be punished by civil or criminal contempt, financial or evidentiary sanctions, reference to disciplinary authorities, or other appropriate action at the discretion of the Court. 18 19 20 IT IS SO ORDERED. 21 | Dated: July 05, 2023 23 24

*6 UNITED | TATES MAGISTRATE JUDGE 27 28

11 EXHIBIT "A" TO STIPULATED PROTECTIVE ORDER 22

UNITED STATES DISTRICT COURT 33 CENTRAL DISTRICT OF CALIFORNIA 44

55 SANDY SEDLICK and JOSEPH Case No: 5:23-cv-00457-JGB-KK 66 SEDLICK, individually and as successors-in-interest Of the Estate 77 of the deceased, ROBERT SAUL AGREEMENT CONCERNING 88 JUAREZ IV, INFORMATION COVERED BY STIPULATED PROTECTIVE 99 Plaintiffs, ORDER 1100

vs. 1111

1122 CITY OF REDLANDS, YESSENIA

BLEVENS, TYLER FRISCH, 1133 TYLER SIMONSEN, ISAAC 1144 SPIEGEL, and DOES 1-10 inclusive,

1155 Defendants. 1166

1188 1. I, __________________________________, hereby acknowledge

1199 that I have received a copy of the Stipulated Protective Order entered in this

2200 Litigation [Case No: 5:23-cv-00457-JGB-KK] by the United States District Court

2211 for the Central District of California (hereinafter, “the Protective Order”).

2222 2. I have either read the Protective Order or have had the terms of the

2233 Protective Order explained to me by my attorney.

2244 3. I understand the terms of the Protective Order and agree to comply

2255 with and to be bound by such terms.

2266 4. If I receive documents or information designated as Confidential

2277 Information (as that term is defined in the Protective Order), I understand that 11 such Information is provided to me pursuant to the terms and restrictions of the 22 Protective Order. 33 5. I agree to hold in confidence and not further disclose or use for any 44 purpose (other than is permitted by the Protective Order) any Confidential 55 Information disclosed to me pursuant to the terms of the Protective Order. 66 6. I hereby submit myself to the jurisdiction of the United States 77 District Court for the Central District of California for resolution of any matters 88 pertaining to the Protective Order. 99

1100 My address is:____________________________________ 1111

1122 My present employer is: ________________________________ 1133

1144 Dated: ______________ 1155

1177 Signed: _________________________ 1188