Zeeshan H. Khan v. City of Los Angeles et al

Filing 45

STIPULATED PROTECTIVE ORDER by Magistrate Judge Margo A. Rocconi re Stipulation for Protective Order 44 . [See order for details.] (es)

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1 Office of the Los Angeles City Attorney DENISE C. MILLS, Deputy City Attorney (SBN 191992) 2 denise.mills@lacity.org 200 North Main Street, 6th Floor, City Hall East 3 Los Angeles, California 90012 Phone: 213-978-6954 4 DANIEL S. ROBERTS, Bar No. 205535 5 droberts@colehuber.com NICOLE R. ROGGEVEEN, Bar No. 252587 6 nroggeveen@colehuber.com ADRIAN VERDUZCO, Bar No. 336027 7 averduzco@colehuber.com COLE HUBER LLP 8 3401 Centrelake Drive, Suite 670 Ontario, California 91761 9 Telephone: (909) 230-4209 Facsimile: (909) 937-2034 10 Attorneys for Defendants City of Los 11 Angeles, Los Angeles Police Department, and Chief Michel Moore 12 UNITED STATES DISTRICT COURT 13 CENTRAL DISTRICT OF CALIFORNIA 14 15 ZEESHAN H. KHAN, CHRISTINA 16 ASTORGA, and RINGO CHIU, Plaintiffs, 17 18 v. 19 CITY OF LOS ANGELES, LOS ANGELES POLICE DEPARTMENT, ; 20 CHIEF MICHEL MOORE, OFFICER AARON GREEN, and DOES 1-10, 21 Defendants. 22 A. Case No. 2:21-cv-03289 CAS (MARx) STIPULATED PROTECTIVE ORDER Referred for Discovery Purposes to the Honorable Margo A. Rocconi 23 1. PURPOSES AND LIMITATIONS 24 Discovery in this action is likely to involve production of confidential, 25 proprietary, or private information for which special protection from public 26 disclosure and from use for any purpose other than prosecuting this litigation may 27 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 28 enter the following Stipulated Protective Order. The parties acknowledge that this 00082680.2 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. The parties further acknowledge, as set forth in 5 Section 12.3, below, that this Stipulated Protective Order does not entitle them to 6 file confidential information under seal; Civil Local Rule 79-5 sets forth the 7 procedures that must be followed and the standards that will be applied when a party 8 seeks permission from the court to file material under seal. 9 10 B. GOOD CAUSE STATEMENT This action involves the City of Los Angeles and members of the Los Angeles COLE HUBER LLP 3401 CENTRELAKE DRIVE, SUITE 670 ONTARIO, CALIFORNIA 91761 11 Police Department on the one side and on the other side Plaintiffs Zeeshan Khan, 12 Christina Astorga, and Ringo Chiu ("Plaintiffs"), private citizens, who are claiming 13 damages from the City and its police officer for past and future medical expenses, 14 loss of earnings, emotional distress, mental suffering, and other unspecified general 15 damages allegedly caused by Defendants. Defendants will seek in this action 16 discovery of various information relating to Plaintiffs' damages claims, including 17 employment and medical information that may be very personal, private, and 18 potentially embarrassing to them if it were to be unnecessarily disseminated. 19 Plaintiffs are seeking materials and information that Defendant the City of Los 20 Angeles (including its Police Department) maintains as confidential, such as 21 personnel files of police officers, Internal Affairs materials and information, Force 22 Investigation Division materials and information and other administrative materials 23 and information currently in the possession of the City and which the City believes 24 need special protection from public disclosure and from use for any purpose other 25 than prosecuting this litigation. Some of this information may also implicate the 26 privacy rights of persons not party to this lawsuit. Plaintiff is also seeking official 27 information contained in the personnel files of the police officers involved in the 28 subject incident, which the City maintains as strictly confidential and which the City 00082680.2 2 1 believes needs special protection from public disclosure and from use for any 2 purpose other than prosecuting this litigation. 3 The parties therefore stipulate that some of the information into which 4 discovery will be sought in this case is protected by various parties' and (third 5 parties') privacy rights under state and federal law. In addition, the confidentiality 6 of the materials and information sought by Plaintiff is recognized by California and 7 federal law. The City has not publicly released such materials except under 8 protective order or pursuant to a court order, if at all. These materials and 9 information are of the type that has been used to initiate disciplinary action against 10 Los Angeles Police Department ("LAPD") officers, and has been used as evidence COLE HUBER LLP 3401 CENTRELAKE DRIVE, SUITE 670 ONTARIO, CALIFORNIA 91761 11 in disciplinary proceedings, where the officers' conduct was considered to be 12 contrary to LAPD policy. 13 THIS STIPULATED PROTECTIVE ORDER EXPRESSLY EXCLUDES 14 RECORDINGS FROM OFFICERS' BODY-WORN CAMERAS UNLESS 15 OTHERWISE SPECIFICALLY AGREED BY THE PARTIES IN A SEPARATE 16 WRITING, OR AS OTHERWISE ORDERED BY THE COURT. 17 Absent a protective order delineating the responsibilities of nondisclosure on 18 the part of the parties hereto, there is a specific risk of unnecessary and undue 19 disclosure by one or more of the many attorneys, secretaries, law clerks, paralegals 20 and expert witnesses involved in this case, as well as the corollary risk of 21 embarrassment, harassment and professional and legal harm on the part of Plaintiffs, 22 Defendants, other LAPD officers, and non-party civilians who may be referenced in 23 the materials and information. Accordingly, to expedite the flow of information, to facilitate the prompt 24 25 resolution of disputes over confidentiality of discovery materials, to adequately 26 protect information the parties are entitled to keep confidential, to ensure that the 27 parties are permitted reasonable necessary uses of such material in preparation for 28 and in the conduct of trial, to address their handling at the end of the litigation, and 00082680.2 3 1 serve the ends of justice, a protective order for such information is justified in this 2 matter. It is the intent of the parties that information will not be designated as 3 confidential for tactical reasons and that nothing be so designated without a good 4 faith belief that it has been maintained in a confidential, non-public manner, and 5 there is good cause why it should not be part of the public record of this case. 6 7 2. DEFINITIONS 8 2.1 Action: The above-captioned suit. 9 2.2 Challenging Party: a Party or Non-Party that challenges the designation of 10 COLE HUBER LLP 3401 CENTRELAKE DRIVE, SUITE 670 ONTARIO, CALIFORNIA 91761 11 information or items under this Order. 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how 12 it is generated, stored or maintained) or tangible things that qualify for 13 protection under Federal Rule of Civil Procedure 26(c), and as specified 14 above in the Good Cause Statement. 15 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 16 support staff). 17 2.5 Designating Party: a Party or Non-Party that designates information or 18 items that it produces in disclosures or in responses to discovery as 19 “CONFIDENTIAL.” 20 2.6 Disclosure or Discovery Material: all items or information, regardless of 21 the medium or manner in which it is generated, stored, or maintained 22 (including, among other things, testimony, transcripts, and tangible 23 things), that are produced or generated in disclosures or responses to 24 discovery in this matter. 25 2.7 Expert: a person with specialized knowledge or experience in a matter 26 pertinent to the litigation who has been retained by a Party or its counsel 27 to serve as an expert witness or as a consultant in this Action. 28 00082680.2 4 1 2.8 House Counsel: attorneys who are employees of a party to this Action. 2 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, association, or 5 6 other legal entity not named as a Party to this action. 2.10 Outside Counsel of Record: attorneys who are not employees of a party 7 to this Action but are retained to represent or advise a party to this Action 8 and have appeared in this Action on behalf of that party or are affiliated 9 with a law firm which has appeared on behalf of that party, and includes support staff. 10 COLE HUBER LLP 3401 CENTRELAKE DRIVE, SUITE 670 ONTARIO, CALIFORNIA 91761 11 2.11 Party: any party to this Action, including all of its officers, directors, 12 employees, consultants, retained experts, and Outside Counsel of Record 13 (and their support staffs). 14 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 15 16 Discovery Material in this Action. 2.13 Professional Vendors: persons or entities that provide litigation support 17 services (e.g., photocopying, videotaping, translating, preparing exhibits 18 or demonstrations, and organizing, storing, or retrieving data in any form 19 or medium) and their employees and subcontractors. 20 2.14 Protected Material: any Disclosure or Discovery Material that is 21 22 designated as “CONFIDENTIAL.” 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 23 from a Producing Party. 24 25 3. 26 The protections conferred by this Stipulation and Order cover not only SCOPE 27 Protected Material (as defined above), but also (1) any information copied or 28 extracted from Protected Material; (2) all copies, excerpts, summaries, or 00082680.2 5 1 compilations of Protected Material; and (3) any testimony, conversations, or 2 presentations by Parties or their Counsel that might reveal Protected Material. Any use of Protected Material at trial shall be governed by the orders of the 3 4 trial judge. This Order does not govern the use of Protected Material at trial. 5 6 4. DURATION 7 Once trial commences in this action, all of the information that was 8 designated as CONFIDENTIAL or maintained pursuant to this protective order and 9 that is introduced or admitted at trial becomes public and will be presumptively 10 available to all members of the public, including the press, unless compelling COLE HUBER LLP 3401 CENTRELAKE DRIVE, SUITE 670 ONTARIO, CALIFORNIA 91761 11 reasons supported by specific factual findings to proceed otherwise are made to the 12 trial judge in advance of the trial. See Kamakana v. City and County of Honolulu, 13 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing "good cause" showing for 14 sealing documents produced in discovery from "compelling reasons" standard when 15 merits-related documents are part of court record). Accordingly, the terms of this 16 protective order do not extend beyond the commencement of the trial as to the 17 CONFIDENTIAL information and materials introduced or admitted as an exhibit at 18 trial. 19 20 21 5. DESIGNATING PROTECTED MATERIAL 5.1 Exercise of Restraint and Care in Designating Material for Protection. 22 Each Party or Non-Party that designates information or items for protection under 23 this Order must take care to limit any such designation to specific material that 24 qualifies under the appropriate standards. The Designating Party must designate for 25 protection only those parts of material, documents, items, or oral or written 26 communications that qualify so that other portions of the material, documents, 27 items, or communications for which protection is not warranted are not swept 28 unjustifiably within the ambit of this Order. 00082680.2 6 1 Mass, indiscriminate, or routinized designations are prohibited. Designations 2 that are shown to be clearly unjustified or that have been made for an improper 3 purpose (e.g., to unnecessarily encumber the case development process or to impose 4 unnecessary expenses and burdens on other parties) may expose the Designating 5 Party to sanctions. 6 If it comes to a Designating Party's attention that information or items that it 7 designated for protection do not qualify for protection, that Designating Party must 8 promptly notify all other Parties that it is withdrawing the inapplicable designation. 9 5.2 Manner and Timing of Designations. Except as otherwise provided in this 10 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise COLE HUBER LLP 3401 CENTRELAKE DRIVE, SUITE 670 ONTARIO, CALIFORNIA 91761 11 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 12 under this Order must be clearly so designated before the material is disclosed or 13 produced. 14 15 Designation in conformity with this Order requires: 16 (a) for information in documentary form (e.g., paper or electronic documents, 17 but excluding transcripts of depositions or other pretrial or trial proceedings), that 18 the Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 19 “CONFIDENTIAL legend”), to each page that contains protected material. If only a 20 portion or portions of the material on a page qualifies for protection, the Producing 21 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 22 markings in the margins). Any such designation should not obscure the text or 23 image on the item being produced. 24 25 A Party or Non-Party that makes original documents available for inspection 26 need not designate them for protection until after the inspecting Party has indicated 27 which documents it would like copied and produced. During the inspection and 28 before the designation, all of the material made available for inspection shall be 00082680.2 7 1 deemed "CONFIDENTIAL." After the inspecting Party has identified the 2 documents it wants copied and produced, the Producing Party must determine which 3 documents, or portions thereof, qualify for protection under this Order. Then, before 4 producing the specified documents, the Producing Party must affix the 5 "CONFIDENTIAL legend" to each page that contains Protected Material. If only a 6 portion or portions of the material on a page qualifies for protection, the Producing 7 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 8 markings in the margins). 9 (b) for testimony given in depositions that the Designating Party identify 10 the Disclosure or Discovery Material on the record, before the close of the COLE HUBER LLP 3401 CENTRELAKE DRIVE, SUITE 670 ONTARIO, CALIFORNIA 91761 11 deposition all protected testimony. 12 (c) for information produced in some form other than documentary and for 13 any other tangible items, that the Producing Party affix in a prominent place on the 14 exterior of the container or containers in which the information is stored the legend 15 "CONFIDENTIAL." If only a portion or portions of the information warrants 16 protection, the Producing Party, to the extent practicable, shall identify the protected 17 portion(s). Any such designation should not obscure the text or image on the item 18 being produced. 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 21 the 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 27 28 00082680.2 8 1 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 2 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 3 designation of confidentiality at any time that is consistent with the Court's 4 Scheduling Order. 5 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 6 resolution process under Local Rule 37.1 et seq. 7 6.3 The burden of persuasion in any such challenge proceeding shall be on the 8 Designating Party. Frivolous challenges, and those made for an improper purpose 9 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 10 expose the Challenging Party to sanctions. Unless the Designating Party has waived COLE HUBER LLP 3401 CENTRELAKE DRIVE, SUITE 670 ONTARIO, CALIFORNIA 91761 11 or withdrawn the confidentiality designation, all parties shall continue to afford the 12 material in question the level of protection to which it is entitled under the 13 Producing Party’s designation until the Court rules on the challenge. 14 15 7. ACCESS TO AND USE OF PROTECTED MATERIAL 16 7.1 Basic Principles. A Receiving Party may use Protected Material that is 17 disclosed or produced by another Party or by a Non-Party in connection with this 18 Action only for prosecuting, defending, or attempting to settle this Action. Such 19 Protected Material may be disclosed only to the categories of persons and under the 20 conditions described in this Order. When the Action has been terminated, a 21 Receiving Party must comply with the provisions of section 13 below (FINAL 22 DISPOSITION). 23 Protected Material must be stored and maintained by a Receiving Party at a 24 location and in a secure manner that ensures that access is limited to the persons 25 authorized under this Order. 26 7.2 Disclosure of "CONFIDENTIAL" Information or Items. Unless otherwise 27 ordered by the court or permitted in writing by the Designating Party, a Receiving 28 Party may disclose any information or item designated "CONFIDENTIAL" only to: 00082680.2 9 1 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as 2 employees of said Outside Counsel of Record to whom it is reasonably necessary to 3 disclose the information for this Action; 4 (b) the officers, directors, and employees (including House Counsel) of the 5 Receiving Party to whom disclosure is reasonably necessary for this Action; 6 (c) Experts (as defined in this Order) of the Receiving Party to whom 7 disclosure is reasonably necessary for this Action and who have signed the 8 "Acknowledgment and Agreement to Be Bound" (Exhibit A); 9 (d) the court and its personnel; (e) court reporters and their staff; 11 COLE HUBER LLP 3401 CENTRELAKE DRIVE, SUITE 670 ONTARIO, CALIFORNIA 91761 10 (f) professional jury or trial consultants, mock jurors, and Professional 12 Vendors to whom disclosure is reasonably necessary for this Action and who have 13 signed the "Acknowledgment and Agreement to Be Bound" (Exhibit A); 14 (g) the author or recipient of a document containing the information or a 15 custodian or other person who otherwise possessed or knew the information; 16 (h) during their depositions, witnesses, and attorneys for witnesses, in the 17 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 18 requests that the witness sign the form attached as Exhibit A hereto; and (2) they 19 will not be permitted to keep any confidential information unless they sign the 20 "Acknowledgment and Agreement to Be Bound" (Exhibit A), unless otherwise 21 agreed by the Designating Party or ordered by the court. Pages of transcribed 22 deposition testimony or exhibits to depositions that reveal Protected Material may 23 be separately bound by the court reporter and may not be disclosed to anyone except 24 as permitted under this Stipulated Protective Order; and 25 (i) any mediator or settlement officer, and their supporting personnel, 26 mutually agreed upon by any of the parties engaged in settlement discussions. 27 28 00082680.2 10 1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 2 OTHER LITIGATION 3 If a Party is served with a subpoena or a court order issued in other litigation 4 that compels disclosure of any information or items designated in this Action as 5 "CONFIDENTIAL," that Party must: (a) promptly notify in writing the Designating Party. Such notification shall 6 7 include a copy of the subpoena or court order; (b) promptly notify in writing the party who caused the subpoena or order to 8 9 issue in the other litigation that some or all of the material covered by the subpoena 10 or order is subject to this Protective Order. Such notification shall include a copy of COLE HUBER LLP 3401 CENTRELAKE DRIVE, SUITE 670 ONTARIO, CALIFORNIA 91761 11 this Stipulated Protective Order; and (c) cooperate with respect to all reasonable procedures sought to be pursued 12 13 by the Designating Party whose Protected Material may be affected. 14 If the Designating Party timely seeks a protective order, the Party served with the 15 subpoena or court order shall not produce any information designated in this action 16 as "CONFIDENTIAL" before a determination by the court from which the 17 subpoena or order issued, unless the Party has obtained the Designating Party’s 18 permission. The Designating Party shall bear the burden and expense of seeking 19 protection in that court of its confidential material and nothing in these provisions 20 should be construed as authorizing or encouraging a Receiving Party in this Action 21 to disobey a lawful directive from another court. 22 23 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 24 PRODUCED IN THIS LITIGATION 25 (a) The terms of this Order are applicable to information produced by a Non- 26 Party in this Action and designated as "CONFIDENTIAL." Such information 27 produced by Non-Parties in connection with this litigation is protected by the 28 00082680.2 11 1 remedies and relief provided by this Order. Nothing in these provisions should be 2 construed as prohibiting a Non-Party from seeking additional protections. (b) In the event that a Party is required, by a valid discovery request, to 3 4 produce a Non-Party's confidential information in its possession, and the Party is 5 subject to an agreement with the Non-Party not to produce the Non-Party's 6 confidential information, then the Party shall: (1) promptly notify in writing the Requesting Party and the Non-Party that 7 8 some or all of the information requested is subject to a confidentiality agreement 9 with a Non-Party; (2) promptly provide the Non-Party with a copy of the Stipulated Protective 10 COLE HUBER LLP 3401 CENTRELAKE DRIVE, SUITE 670 ONTARIO, CALIFORNIA 91761 11 Order in this Action, the relevant discovery request(s), and a reasonably specific 12 description of the information requested; and (3) make the information requested available for inspection by the Non-Party, 13 14 if requested. (c) If the Non-Party fails to seek a protective order from this court within 14 15 16 days of receiving the notice and accompanying information, the Receiving Party 17 may produce the Non-Party’s confidential information responsive to the discovery 18 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 19 not produce any information in its possession or control that is subject to the 20 confidentiality agreement with the Non-Party before a determination by the court. 21 Absent a court order to the contrary, the Non-Party shall bear the burden and 22 expense of seeking protection in this court of its Protected Material. 23 24 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 25 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 26 Protected Material to any person or in any circumstance not authorized under this 27 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 28 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 00082680.2 12 1 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 2 persons to whom unauthorized disclosures were made of all the terms of this Order, 3 and (d) request such person or persons to execute the "Acknowledgment and 4 Agreement to Be Bound" that is attached hereto as Exhibit A. 5 6 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 7 PROTECTED MATERIAL 8 When a Producing Party gives notice to Receiving Parties that certain 9 inadvertently produced material is subject to a claim of privilege or other protection, 10 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil COLE HUBER LLP 3401 CENTRELAKE DRIVE, SUITE 670 ONTARIO, CALIFORNIA 91761 11 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 12 may be established in an e-discovery order that provides for production without 13 prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar 14 as the parties reach an agreement on the effect of disclosure of a communication or 15 information covered by the attorney-client privilege or work product protection, the 16 parties may incorporate their agreement in the stipulated protective order submitted 17 to the court. 18 19 12. MISCELLANEOUS 20 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 21 22 person to seek its modification by the Court in the future. 12.2 Right to Assert Other Objections. By stipulating to the entry of this 23 Protective Order no Party waives any right it otherwise would have to object to 24 disclosing or producing any information or item on any ground not addressed in this 25 Stipulated Protective Order. Similarly, no Party waives any right to object on any 26 ground to use in evidence of any of the material covered by this Protective Order. 27 12.3 Filing Protected Material. A Party that seeks to file under seal any 28 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 00082680.2 13 1 only be filed under seal pursuant to a court order authorizing the sealing of the 2 specific Protected Material at issue. If a Party's request to file Protected Material 3 under seal is denied by the court, then the Receiving Party may file the information 4 in the public record unless otherwise instructed by the court. 5 6 13. FINAL DISPOSITION 7 After the final disposition of this Action, as defined in paragraph 4, within 60 8 days of a written request by the Designating Party, each Receiving Party must return 9 all Protected Material to the Producing Party or destroy such material. As used in 10 this subdivision, "all Protected Material" includes all copies, abstracts, compilations, COLE HUBER LLP 3401 CENTRELAKE DRIVE, SUITE 670 ONTARIO, CALIFORNIA 91761 11 summaries, and any other format reproducing or capturing any of the Protected 12 Material. Whether the Protected Material is returned or destroyed, the Receiving 13 Party must submit a written certification to the Producing Party (and, if not the same 14 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 15 (by category, where appropriate) all the Protected Material that was returned or 16 destroyed and (2) affirms that the Receiving Party has not retained any copies, 17 abstracts, compilations, summaries or any other format reproducing or capturing any 18 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 19 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 20 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 21 reports, attorney work product, and consultant and expert work product, even if such 22 materials contain Protected Material. Any such archival copies that contain or 23 constitute Protected Material remain subject to this Protective Order as set forth in 24 Section 4 (DURATION). 25 26 27 / / / 28 / / / 00082680.2 14 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 Dated: December 29, 2021 7 8 THE LAW OFFICES OF JOHN BURTON THE LAW OFFICE OF THOMAS C. SEABAUGH By: 9 COLE HUBER LLP 3401 CENTRELAKE DRIVE, SUITE 670 ONTARIO, CALIFORNIA 91761 10 /s/ John Burton John Burton Attorneys for Plaintiffs 11 Dated: Jaunary 3, 2022 12 COLE HUBER LLP 13 By: 14 15 16 17 Dated: December 30, 2021 /s/ Daniel S. Roberts Daniel S. Roberts Attorneys for Defendants City of Los Angeles, Los Angeles Police Department, and Chief Michel Moore STONE BUSAILAH, LLP 18 19 By: 20 21 /s/ Muna Busailah Muna Busailah Attorneys for Defendant Aaron Green 22 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. January 7, 2022 23 DATED: ________________________ ____________ _ 24 _____________________________________ 25 Honorable Margo A. Rocconi United States Magistrate Judge 26 27 28 00082680.2 15 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 I, _____________________________ [print or type full name], of 5 _________________ [print or type full address], declare under penalty of perjury 6 that I have read in its entirety and understand the Stipulated Protective Order that 7 was issued by the United States District Court for the Central District of California 8 on [date] in the case of Zeeshan Khan, et al. v. City of Los Angeles, et al., Central 9 District of California Case No. 2:21-cv-3289 CAS (MARx). I agree to comply with 10 and to be bound by all the terms of this Stipulated Protective Order and I understand COLE HUBER LLP 3401 CENTRELAKE DRIVE, SUITE 670 ONTARIO, CALIFORNIA 91761 11 and acknowledge that failure to so comply could expose me to sanctions and 12 punishment in the nature of contempt. I solemnly promise that I will not disclose in 13 any manner any information or item that is subject to this Stipulated Protective 14 Order to any person or entity except in strict compliance with the provisions of this 15 Order. 16 I further agree to submit to the jurisdiction of the United States District Court for the 17 Central District of California for the purpose of enforcing the terms of this 18 Stipulated Protective Order, even if such enforcement proceedings occur after 19 termination of this action. I hereby appoint __________________________ [print or 20 type full name] of _______________________________________ [print or type 21 full address and telephone number] as my California agent for service of process in 22 connection with this action or any proceedings related to enforcement of this 23 Stipulated Protective Order. 24 Date: ______________________________________ 25 City and State where sworn and signed: ________________________________ 26 27 Printed name: _______________________________ 28 Signature: __________________________________ 00082680.2 16

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