Sarah Jafari v. County of Los Angeles

• Court: District Court, C.D. California
• Decided: May 12, 2022
• Docket: 2:22-cv-00305
• Status: Unknown

Opinion

Case □□□□□□□□□□□□□□□□□□□□□□ Document 32 Filed 05/12/22 Page1of17 Page ID#:177 46 8 UNITED STATES DISTRICT COURT 3 ze 9 CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION qESs z g5e 11 || SARAH JAFARI, Case No. 2:22-cv-00305-DSF (GJSx) [888 12 Plaintiff, PROPOSED) STIPULATED a pad ‘6 ROTECTIVE ORDER Soe Assigned to Hon. Dale S. Fischer, = unicipal entity: RONRAD THIEME, | “ou” "7 15 || an Individual, DOES 1-10, inclusive, 16 Defendants. WW 18 19. A. PURPOSES AND LIMITATIONS 20 Discovery in this action is likely to involve production of confidential, 21 || proprietary or private information for which special protection from public 22 || disclosure and from use for any purpose other than prosecuting this litigation may 23 ||be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 24 || enter the following Stipulated Protective Order. The parties acknowledge that this 25 ae This Stipulated Protective Order is substantially based on the model protective 27 || order provided under Magistrate Judge Gail J. Standish’s Procedures. 28

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1 || Order does not confer blanket protections on all disclosures or responses to 2 || discovery and that the protection it affords from public disclosure and use extends 3 || only to the limited information or items that are entitled to confidential treatment 4 || under the applicable legal principles. 5 B. GOOD CAUSE STATEMENT 6 This action is likely to involve confidential information pertaining to 7 || personnel records and institutional procedures within the institution and other 8 || materials subject to privacy protections for which special protection from public g 9 || disclosure and from use for any purpose other than prosecution of this action is 4 bee 10 || warranted. Defendants contend that limiting disclosure of these documents to the : 5: 11 || context of this litigation as provided herein will, accordingly, further important law G ecu 12 || enforcement objectives and interests, including the safety of law enforcement 3 ou 13 || personnel, institutional safety as a whole, and the public, as well as individual 14 || privacy rights of Plaintiff, Defendants, and third parties. Defendants further contend 15 || that such confidential materials and information consist of, among other things, 16 || materials entitled to privileges and/or protections under the following: the United 17 || States Constitution, First Amendment; the California Constitution, Article I, Section 18 || 1; California Penal Code §§ 832.5, 832.7, and 832.8; California Evidence Code §8§ 19 || 1040 and 1043 et seq.; the Privacy Act of 1974, 5 U.S.C. § 552a; the right to 20 || privacy; decisional law relating to such provisions; and information otherwise 21 || generally unavailable to the public, or which may be privileged or otherwise 22 || protected from disclosure under state or federal statutes, court rules, case decisions, 23 ||or common law. Defendants also maintain that such confidential materials and 24 || information consist of materials entitled to the Official Information Privilege. 25 Confidential information with respect to the Defendants may include: 26 || personnel files; internal institutional procedures and policy, investigative files and 27 || documents; email and written correspondence records; and policies and procedures 28 || that are kept from the public in the ordinary course of business, as well as other

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items subject to the Official Information Privilege and other privileges. The Parties 2 || reserve the right to challenge a designation of confidentiality pursuant to the terms 3 || set forth under Paragraph 6 of this Stipulated Protective Order. 4 Accordingly, to expedite the flow of information, to facilitate the prompt 5 || resolution of disputes over confidentiality of discovery materials, to adequately 6 || protect information the parties are entitled to keep confidential, to ensure that the 7 || parties are permitted to reasonable necessary uses of such material in preparation for 8 || and in conduct of trial, to address their handling at the end of the litigation, and 4 2 9 || serve the ends of justice, a protective order for such information is justified in this a He 10 || matter. It is the intent of the parties that information will not be designated as est 11 || confidential for tactical reasons and that nothing be so designated without a good 5 12 || faith belief that it has been maintained in a confidential, non-public manner, and 3 oa 13 || there is good cause why it should not be part of the public record of this case. = 14 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 15 The parties further acknowledge, as set forth in Section 12.3, below, that this 16 || Stipulated Protective Order does not entitle them to file confidential information 17 || under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed 18 || and the standards that will be applied when a party seeks permission from the court 19 || to file material under seal. 20 There is a strong presumption that the public has a right of access to judicial 21 || proceedings and records in civil cases. In connection with non-dispositive motions, 22 || good cause must be shown to support a filing under seal. See Kamakana v. City and 23 || County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors 24 || Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, 25 || Jnc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders 26 || require good cause showing), and a specific showing of good cause or compelling 27 || reasons with proper evidentiary support and legal justification, must be made with 28 || respect to Protected Material that a party seeks to file under seal. The parties’ mere

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1 || designation of Disclosure or Discovery Material as CONFIDENTIAL does not— 2 || without the submission of competent evidence by declaration, establishing that the 3 || material sought to be filed under seal qualifies as confidential, privileged, or 4 || otherwise protectable—constitute good cause. 5 Further, if a party requests sealing related to a dispositive motion or trial, then 6 || compelling reasons, not only good cause, for the sealing must be shown, and the 7 || relief sought shall be narrowly tailored to serve the specific interest to be protected. 8 || See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For 2 9 || each item or type of information, document, or thing sought to be filed or introduced 4 BBs 10 || under seal in connection with a dispositive motion or trial, the party seeking : 3: 11 || protection must articulate compelling reasons, supported by specific facts and legal 5 203 12 || justification, for the requested sealing order. Again, competent evidence supporting zh 13 || the application to file documents under seal must be provided by declaration. = 14 Any document that is not confidential, privileged, or otherwise protectable in 15 || its entirety will not be filed under seal if the confidential portions can be redacted. 16 || If documents can be redacted, then a redacted version for public viewing, omitting 17 || only the confidential, privileged, or otherwise protectable portions of the document, 18 || shall be filed. Any application that seeks to file documents under seal in their 19 || entirety should include an explanation of why redaction is not feasible. 20 |} 2. DEFINITIONS 21 2.1 Action: this pending federal lawsuit in the United States District Court 22 || for the Central District of California titled Sarah Jafari v. County of Los Angeles, et 23 || al., Case No.:2:22-cv-00305-DSF (GJSx). 24 2.2 Challenging Party: a Party or Non-Party that challenges the designation 25 || of information or items under this Order. 26 2.3. “CONFIDENTIAL” Information or Items: information (regardless of 27 || how it is generated, stored or maintained) or tangible things that qualify for 28 || protection under Federal Rule of Civil Procedure 26(c), and as specified above in

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1 || the Good Cause Statement. 2 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 3 || their support staff). 4 2.5 Designating Party: a Party or Non-Party that designates information or 5 || items that it produces in disclosures or in responses to discovery as 6 || “CONFIDENTIAL.” 7 2.6 Disclosure or Discovery Material: all items or information, regardless 8 || of the medium or manner in which it is generated, stored, or maintained (including, 9 || among other things, testimony, transcripts, and tangible things), that are produced or a ie 10 || generated in disclosures or responses to discovery in this matter. 56 11 2.7 Expert: a person with specialized knowledge or experience in a matter S oy 12 || pertinent to the litigation who has been retained by a Party or its counsel to serve as 5 ou 13 || an expert witness or as a consultant in this Action. se 14 2.8 House Counsel: attorneys who are employees of a party to this Action. 7 15 || House Counsel does not include Outside Counsel of Record or any other outside 16 || counsel. 17 2.9 Non-Party: any natural person, partnership, corporation, association or 18 || other legal entity not named as a Party to this action. 19 2.10 Qutside Counsel of Record: attorneys who are not employees of a party 20 || to this Action but are retained to represent or advise a party to this Action and have 21 || appeared in this Action on behalf of that party or are affiliated with a law firm that 22 || has appeared on behalf of that party, and includes support staff. 23 2.11 Party: any party to this Action, including all of its officers, directors, 24 || employees, consultants, retained experts, and Outside Counsel of Record (and their 25 || support staffs). 26 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 27 || Discovery Material in this Action. 28 2.13 Professional Vendors: persons or entities that provide litigation support

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1 |) services (e.g., photocopying, videotaping, translating, preparing exhibits or 2 || demonstrations, and organizing, storing, or retrieving data in any form or medium) 3 || and their employees and subcontractors. 4 2.14 Protected Material: any Disclosure or Discovery Material that is 5 || designated as “CONFIDENTIAL.” 6 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 7 || from a Producing Party. 8]/3. SCOPE g 9 The protections conferred by this Stipulation and Order cover not only 4 EBs 10 || Protected Material (as defined above), but also (1) any information copied or sf 11 || extracted from Protected Material; (2) all copies, excerpts, summaries, or 5 ne 12 || compilations of Protected Material; and (3) any testimony, conversations, or a zou 13 || presentations by Parties or their Counsel that might reveal Protected Material. a 14 Any use of Protected Material at trial shall be governed by the orders of the 15 || trial judge. This Order does not govern the use of Protected Material at trial. 16)|4.. DURATION 17 FINAL DISPOSITION of the action is defined as the conclusion of any 18 || appellate proceedings, or, if no appeal is taken, when the time for filing of an appeal i9 ||has run. Except as set forth below, the terms of this protective order apply through 20 || FINAL DISPOSITION of the action. The parties may stipulate that they will be 21 || contractually bound by the terms of this agreement beyond FINAL DISPOSITION, 22 || but will have to file a separate action for enforcement of the agreement once all 23 || proceedings in this case are complete. 24 Once a case proceeds to trial, information that was designated as 25 || CONFIDENTIAL or maintained pursuant to this protective order used or introduced 26 || as an exhibit at trial becomes public and will be presumptively available to all 27} members of the public, including the press, unless compelling reasons supported by 28 || specific factual findings to proceed otherwise are made to the trial judge in advance

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1 || of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” □

2 || showing for sealing documents produced in discovery from “compelling reasons” 3 || standard when merits-related documents are part of court record). Accordingly, for 4 || such materials, the terms of this protective order do not extend beyond the 5 || commencement of the trial. 6||5. | DESIGNATING PROTECTED MATERIAL 7 5.1 Exercise of Restraint and Care in Designating Material for Protection. 8 || Each Party or Non-Party that designates information or items for protection under = 9 || this Order must take care to limit any such designation to specific material that 4 ei 10 || qualifies under the appropriate standards. The Designating Party must designate for set 11 || protection only those parts of material, documents, items or oral or written SG 12 || communications that qualify so that other portions of the material, documents, items a oa 13 || or communications for which protection is not warranted are not swept unjustifiably = 82° 14|| within the ambit of this Order. 15 Mass, indiscriminate or routinized designations are prohibited. Designations 16 || that are shown to be clearly unjustified or that have been made for an improper 17 || purpose (e.g., to unnecessarily encumber the case development process or to impose 18 || unnecessary expenses and burdens on other parties) may expose the Designating 19 || Party to sanctions. 20 If it comes to a Designating Party’s attention that information or items that it 21 || designated for protection do not qualify for protection, that Designating Party must 22 || promptly notify all other Parties that it is withdrawing the inapplicable designation. 23 5.2. Manner and Timing of Designations. Except as otherwise provided in 24 || this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 25 || stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 26 || under this Order must be clearly so designated before the material is disclosed or 27 || produced. 28 Designation in conformity with this Order requires:

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1 (a) for information in documentary form (e.g., paper or electronic documents, 2 || but excluding transcripts of depositions or other pretrial or trial proceedings), that 3 || the Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 4 ||“CONFIDENTIAL legend”), to each page that contains protected material. If only a 5 || portion of the material on a page qualifies for protection, the Producing Party also 6 || must clearly identify the protected portion(s) (e.g., by making appropriate markings 7 the margins). 8 A Party or Non-Party that makes original documents available for inspection 4 8 9 ||need not designate them for protection until after the inspecting Party has indicated 4 bag 10 || which documents it would like copied and produced. During the inspection and ag! 11 || before the designation, all of the material made available for inspection shall be 5 aoe 12 || deemed “CONFIDENTIAL.” After the inspecting Party has identified the 3 ou 13 || documents it wants copied and produced, the Producing Party must determine which 14 || documents, or portions thereof, qualify for protection under this Order. Then, 15 || before producing the specified documents, the Producing Party must affix the 16 || “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 17 || portion of the material on a page qualifies for protection, the Producing Party also 18 || must clearly identify the protected portion(s) (e.g., by making appropriate markings 19 || in the margins). 20 (b) for testimony given in depositions that the Designating Party identifies 21 || the Disclosure or Discovery Material on the record, before the close of the 22 || deposition all protected testimony. 23 (c) for information produced in some form other than documentary and for 24 || any other tangible items, that the Producing Party affix in a prominent place on the 25 || exterior of the container or containers in which the information is stored the legend 26 || “CONFIDENTIAL.” If only a portion or portions of the information warrants 27 || protection, the Producing Party, to the extent practicable, shall identify the protected 28 || portion(s).

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1 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 2 || failure to designate qualified information or items does not, standing alone, waive 3 || the Designating Party’s right to secure protection under this Order for such material. 4 || Upon timely correction of a designation, the Receiving Party must make reasonable 5 || efforts to assure that the material is treated in accordance with the provisions of this 6 || Order. 7\;}6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 8 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 2 9 || designation of confidentiality at any time that is consistent with the Court’s #8g 10]| Scheduling Order. =! 11 6.2 Meet and Confer. The Challenging Party shall initiate the dispute S acy 12 || resolution process under Local Rule 37.1 et seq. 3 a 13 6.3. The burden of persuasion in any such challenge proceeding shall be on = 37 14 || the Designating Party. Frivolous challenges, and those made for an improper = 15 || purpose (e.g., to harass or impose unnecessary expenses and burdens on other 16 || parties) may expose the Challenging Party to sanctions. Unless the Designating 17 || Party has waived or withdrawn the confidentiality designation, all parties shall 18 || continue to afford the material in question the level of protection to which it is 19 || entitled under the Producing Party’s designation until the Court rules on the 20 || challenge. 21||7. ACCESS TO AND USE OF PROTECTED MATERIAL 22 7.1 Basic Principles. A Receiving Party may use Protected Material that is 23 || disclosed or produced by another Party or by a Non-Party in connection with this 24 || Action only for prosecuting, defending or attempting to settle this Action. Such 25 || Protected Material may be disclosed only to the categories of persons and under the 26 || conditions described in this Order. When the Action has been terminated, a 27 || Receiving Party must comply with the provisions of section 13 below (FINAL 28 || DISPOSITION).

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1 Protected Material must be stored and maintained by a Receiving Party at a 2 || location and in a secure manner that ensures that access is limited to the persons 3 || authorized under this Order. 4 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 5 || otherwise ordered by the court or permitted in writing by the Designating Party, a 6 || Receiving Party may disclose any information or item designated 7 \|“CONFIDENTIAL” only to: 8 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 3 9 || as employees of said Outside Counsel of Record to whom it is reasonably necessary 4 vee 10 || to disclose the information for this Action; ae 11 (b) the officers, directors, and employees (including House Counsel) of the S 12 || Receiving Party to whom disclosure is reasonably necessary for this Action; 3 13 (c) Experts (as defined in this Order) of the Receiving Party to whom Ss a7 14 || disclosure is reasonably necessary for this Action and who have signed the 15 || “Acknowledgment and Agreement to Be Bound” (Exhibit A); 16 (d) the court and its personnel; 17 (e) court reporters and their staff; 18 (f) professional jury or trial consultants, mock jurors, and Professional 19 || Vendors to whoin disclosure is reasonably necessary for this Action and who have 20 || signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 21 (g) the author or recipient of a document containing the information or a 22 || custodian or other person who otherwise possessed or knew the information; 23 (h) during their depositions, witnesses, and attorneys for witnesses, in the 24 || Action to whom disclosure is reasonably necessary provided: (1) the deposing party 25 || requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will 26 || not be permitted to keep any confidential information unless they sign the 27 ||““Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 28 || agreed by the Designating Party or ordered by the court. Pages of transcribed

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1 testimony or exhibits to depositions that reveal Protected Material may 2 || be separately bound by the court reporter and may not be disclosed to anyone except 3 || as permitted under this Stipulated Protective Order; and 4 (i) any mediator or settlement officer, and their supporting personnel, 5 || mutually agreed upon by any of the parties engaged in settlement discussions. 6|/8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER LITIGATION 8 If a Party is served with a subpoena or a court order issued in other litigation g 9 || that compels disclosure of any information or items designated in this Action as 328s ||“CONFIDENTIAL,” that Party must: : sg: 11 (a) promptly notify in writing the Designating Party. Such notification shall 5 12 || include a copy of the subpoena or court order; 3 13 (b) promptly notify in writing the party who caused the subpoena or order to 2" 14 || issue in the other litigation that some or all of the material covered by the subpoena 15 || or order is subject to this Protective Order. Such notification shall include a copy of 16 || this Stipulated Protective Order; and 17 (c) cooperate with respect to all reasonable procedures sought to be pursued 18 || by the Designating Party whose Protected Material may be affected. 19 If the Designating Party timely seeks a protective order, the Party served with 20 || the subpoena or court order shall not produce any information designated in this 21 || action as “CONFIDENTIAL” before a determination by the court from which the 22 || subpoena or order issued, unless the Party has obtained the Designating Party’s 23 || permission. The Designating Party shall bear the burden and expense of seeking 24 || protection in that court of its confidential material and nothing in these provisions 25 || should be construed as authorizing or encouraging a Receiving Party in this Action 26 || to disobey a lawful directive from another court. 27 \|/// 28 || ///

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1)/9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE ! 2 PRODUCED IN THIS LITIGATION 3 (a) The terms of this Order are applicable to information produced by a Non- 4 || Party in this Action and designated as “CONFIDENTIAL.” Such information 5 || produced by Non-Parties in connection with this litigation is protected by the 6 || remedies and relief provided by this Order. Nothing in these provisions should be 7 || construed as prohibiting a Non-Party from seeking additional protections. 8 (b) In the event that a Party is required, by a valid discovery request, to A g 9 || produce a Non-Party’s confidential information in its possession, and the Party is 4 Be 10 || subject to an agreement with the Non-Party not to produce the Non-Party’s □ se: 11 || confidential information, then the Party shall: 5 12 (1) promptly notify in writing the Requesting Party and the Non-Party rou 13 || that some or all of the information requested is subject to a confidentiality fs ee" 14 || agreement with a Non-Party; 15 (2) promptly provide the Non-Party with a copy of the Stipulated 16 || Protective Order in this Action, the relevant discovery request(s), and a reasonably 17 || specific description of the information requested; and 18 (3) make the information requested available for inspection by the 19 || Non-Party, if requested. 20 (c) If the Non-Party fails to seek a protective order from this court within 14 21 || days of receiving the notice and accompanying information, the Receiving Party 22 || may produce the Non-Party’s confidential information responsive to the discovery 23 || request. If the Non-Party timely seeks a protective order, the Receiving Party shall 24 || not produce any information in its possession or control that is subject to the 25 || confidentiality agreement with the Non-Party before a determination by the court. 26 || Absent a court order to the contrary, the Non-Party shall bear the burden and 27 || expense of seeking protection in this court of its Protected Material. 28 ||///

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1)/}10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 2 Ifa Receiving Party learns that, by inadvertence or otherwise, it has disclosed 3 || Protected Material to any person or in any circumstance not authorized under this 4 || Stipulated Protective Order, the Receiving Party must immediately (a) notify in 5 || writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 6 || to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 7 || persons to whom unauthorized disclosures were made of all the terms of this Order, 8 || and (d) request such person or persons to execute the “Acknowledgment and A g 9 || Agreement to Be Bound” that is attached hereto as Exhibit A. a BB g 10\|}11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE : af: 11 PROTECTED MATERIAL 5 acy 12 When a Producing Party gives notice to Receiving Parties that certain 5 He 13 || inadvertently produced material is subject to a claim of privilege or other protection, a7 14 || the obligations of the Receiving Parties are those set forth in Federal Rule of Civil = 15 || Procedure 26(b)(5)(B). This provision is not intended to modify whatever 16 || procedure may be established in an e-discovery order that provides for production 17 || without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and 18 || (e), insofar as the parties reach an agreement on the effect of disclosure of a 19 |) communication or information covered by the attorney-client privilege or work 20 || product protection, the parties may incorporate their agreement in the stipulated 21 || protective order submitted to the court. 22|}12. MISCELLANEOUS 23 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 24 || person to seek its modification by the Court in the future. 25 12.2 Right to Assert Other Objections. By stipulating to the entry of this 26 || Protective Order, no Party waives any right it otherwise would have to object to 27 || disclosing or producing any information or item on any ground not addressed in this 28 || Stipulated Protective Order. Similarly, no Party waives any right to object on any

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1 || ground to use in evidence of any of the material covered by this Protective Order. 2 12.3 Filing Protected Material. A Party that seeks to file under seal any 3 || Protected Material must comply with Local Civil Rule 79-5. Protected Material 4 || may only be filed under seal pursuant to a court order authorizing the sealing of the 5 || specific Protected Material at issue. Ifa Party’s request to file Protected Material 6 || under seal is denied by the court, then the Receiving Party may file the information 7 ||in the public record unless otherwise instructed by the court. 8|\13. FINAL DISPOSITION 4 8 9 After the final disposition of this Action, as defined in paragraph 4, within 60 4 eee 10 || days of a written request by the Designating Party, each Receiving Party must return : sp! 11 || all Protected Material to the Producing Party or destroy such material. As used in 5 Sy 12 || this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 5 He 13 ||summaries, and any other format reproducing or capturing any of the Protected BS 27 14 || Material. Whether the Protected Material is returned or destroyed, the Receiving = 15 || Party must submit a written certification to the Producing Party (and, if not the same 16 || person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 17 || (by category, where appropriate) all the Protected Material that was returned or 18 || destroyed and (2) affirms that the Receiving Party has not retained any copies, 19 || abstracts, compilations, summaries or any other format reproducing or capturing any 20 || of the Protected Material. Notwithstanding this provision, Counsel are entitled to 21 || retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 22 || transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 23 || reports, attorney work product, and consultant and expert work product, even if such 24 || materials contain Protected Material. Any such archival copies that contain or 25 || constitute Protected Material remain subject to this Protective Order as set forth in 26 || Section 4 (DURATION). 27:14. VIOLATION 28 Any violation of this Order may be punished by appropriate measures

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1 || including, without limitation, contempt proceedings and/or monetary sanctions. 2 ITT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 4 || DATED: May 9, 2022 5 || THE LAW OFFICES OF VINCENT MILLER 6 /s/ Vincent Miller 7 VINCENT MILLER 8 || NICK SAGE 9 Attorneys for Plaintiff Sarah Jafari els ml 5 Ese 10 a oss eB 11 □ ese DATED: May 9, 2022 0 $22 |? THURRELL CANTRALL LLP oh ose /s/ Anahit Isaghulyan 14 ~ s a 15 THOMAS C. HURRELL FARID A. SHARABY 16 | ANAHIT ISAGHULYAN 17 Attorneys for Defendant County of Los Angeles 18 19 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 20 3 DATE May 12, 2022

23 || ——— HON. (GAIL J. STANDISH 24 || United’States Magistrate Judge 25 26 ad 28

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1 SIGNATURE CERTIFICATION 2 Pursuant to L.R. 5-4.3.4, I hereby certify that all other signatories listed, on 3 || whose behalf the filing is submitted, concur in the filing’s content and have 4 || authorized the filing. 6 || DATED: May 9, 2022 HURRELL CANTRALL LLP -

py By: ag 9 THOMAS C. HURRELL Ese 10 FARID A. SHARABY Ruee ay ANAHIT ISAGHULYAN Z ake Attorneys for Defendant, COUNTY OF 12 LOS ANGELES

5g 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

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1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 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 7 || was issued by the United States District Court for the Central District of California 8 || on [date] in the case of Sarah Jafari v. County of Los Angeles, et g 9 || al., Case No.:2:22-cv-00305-DSF (GJSx). I agree to comply with and to be bound 4 EBs 10||by all the terms of this Stipulated Protective Order and I understand and se: 11 || acknowledge that failure to so comply could expose me to sanctions and punishment 5 a8 12 || in the nature of contempt. I solemnly promise that I will not disclose in any manner a 13 ||any information or item that is subject to this Stipulated Protective Order to any ag 14 || person or entity except in strict compliance with the provisions of this Order. = 15 I further agree to submit to the jurisdiction of the United States District Court 16 || for the Central District of California for enforcing the terms of this Stipulated 17 || Protective Order, even if such enforcement proceedings occur after termination of 18 |/this action. I hereby appoint [print or type full 19 || name] of [print or type full address 20 || and telephone number] as my California agent for service of process in connection 21 || with this action or any proceedings related to enforcement of this Stipulated 22 || Protective Order. 23 24 || Date: 25 || City and State where sworn and signed: 26 || Printed name: 27 || Signature: □ 28

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