Jefrick Barrios v. City of Los Angeles et al

Filing 28

STIPULATED PROTECTIVE ORDER by Magistrate Judge Maria A. Audero re Stipulation for Protective Order 27 . See document for details. (es)

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1 2 3 4 5 6 7 8 9 10 11 12 UNITED STATES DISTRICT COURT 13 CENTRAL DISTRICT OF CALIFORNIA 14 15 16 Case No. 2:24-cv-01914- MAA JEFRICK BARRIOS 17 Plaintiff, 18 19 20 21 v. CITY OF LOS ANGELES; and DOES 1-10, identities unknown, 22 Defendant(s). 23 24 25 26 27 28 Revised 10/27/21 Hon. Mag. Judge Maria A. Audero, Ctrm. 880, Roybal [PROPOSED] STIPULATED PROTECTIVE ORDER 1 1. PURPOSES AND LIMITATIONS 2 Plaintiff Jefrick Barrios filed suit on March 8, 2024, against the City of Los 3 Angeles (“CITY”) for an incident occurring on August 5, 2023, in which Plaintiff alleges 4 a Los Angeles Police Department (“LAPD”) K9 bit his hand incident to a search for a 5 suspect to a criminal offense. Discovery in this action is likely to involve production of 6 confidential, proprietary, or private information for which special protection from public 7 disclosure and from use for any purpose other than prosecuting this litigation may be 8 warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter the 9 following Stipulated Protective Order. The parties acknowledge that this Stipulated 10 Protective Order does not confer blanket protections on all disclosures or responses to 11 discovery and that the protection it affords from public disclosure and use extends only to 12 the limited information or items that are entitled to confidential treatment under the 13 applicable legal principles. The parties further acknowledge, a set forth in Section 13.3 14 below, that this Stipulated Protective Order does not entitle them to file confidential 15 information under seal; Local Rule 79-5 sets forth the procedures that must be followed 16 and the standards that will be applied when a party seeks permission from the Court to 17 file material under seal. 18 19 20 2. GOOD CAUSE STATEMENT This action involves the City of Los Angeles (the “City”) through members of the 21 City’s Los Angeles Police Department (“LAPD”). The City contends that the nature of 22 the incident that gives rise to Plaintiff’s suit and Plaintiff’s claims and allegations will 23 result in discovery production that includes police reports and evidence; investigation 24 reports and evidence; peace officer personnel materials; information implicating the 25 rights of third parties (i.e. bystander witnesses, emergency personnel information); and 26 other private and confidential materials for which require special protection from public 27 disclosure. 28 Revised 10/27/21 1 Specifically, Plaintiff is seeking materials and information that Defendant City 2 contends that it maintains as confidential such as personnel files of the police and/or 3 sworn officers involved in this incident, Internal Affairs materials and information, 4 video recordings, audio recordings, photographs, Force Investigation Division materials 5 and information and other administrative materials and information currently in the 6 possession of Defendant and which Defendant believes need special protection from 7 public disclosure and from use for any purpose other than prosecuting this litigation. 8 Plaintiff may also seek official information contained in the personnel files of the police 9 and/or sworn officers involved in the subject incident, which Defendant contends that it 10 maintains as strictly confidential and which Defendant believes needs special protection 11 form public disclosure and from use for any purpose other than prosecuting this 12 litigation. 13 Defendant asserts that the confidentiality of the materials and information sought 14 by Plaintiff is recognized by California and federal law, as evidenced inter alia by 15 California Penal Code section 832.7 and Kerr v. United States Dist. Ct. forN.D. Cal., 16 511 F.2d 192, 198 (9 th Cir. 1975), aff’d, 426 U.S. 394 (1976). Defendant City contends 17 that it has not publicly released the materials and information referenced above except 18 under protective order or pursuant to a court order, if at all. Personnel materials and 19 information are of the type that has been used to initiate disciplinary proceedings, where 20 the employee conduct was considered to contrary to policy. 21 Defendant contends that absent a protective order delineating the responsibilities 22 of nondisclosure on the part of the parties hereto, there is a specific risk of unnecessary 23 and undue disclosure by one or more of the many attorneys, secretaries, law clerks, 24 paralegals and expert witnesses involved in this case, as well as the corollary risk of 25 embarrassment, harassment and professional and legal harm on the part of the City’s 26 employees referenced in the materials and information. 27 Defendant also contends that the unfettered disclosure of the materials and 28 information, absent a protective order, would allow the media to share this information Revised 10/27/21 1 with potential jurors in the area, impacting the rights of Defendant herein to receive a 2 fair trial. 3 Accordingly, to expedite the flow of information, to facilitate the prompt 4 resolution of disputes over confidentiality of discovery materials, to adequately protect 5 information the parties are entitled to keep confidential, to ensure that the parties are 6 permitted reasonable necessary uses of such material in preparation for and in the 7 conduct of trial, to address their handling at the end of the litigation, and to serve the 8 ends of justice, a protective order for such information is justified in this matter. It is the 9 intent of the parties that information will not be designated as confidential for tactical 10 reasons and that nothing be so designated without a good faith belief that it has been 11 maintained in a confidential, non-public manner, and there is good cause why it should 12 not be part of the public record of this case. 13 Without conceding any of Defendant’s contentions as to the confidentiality of the 14 referenced materials in general, or the confidentiality of any particular information or 15 documents, Plaintiff agrees that there is good cause for this protective order, which 16 would streamline discovery and facilitate the exchange of materials without prejudice to 17 either party’s rights with respect the assertion of confidentiality. 18 The parties therefore stipulate that there is good cause for the entry of this 19 proposed protective order regarding confidential documents consistent with the terms 20 and provisions of this Stipulation. However, the parties recognize that the entry of a 21 Protective Order by the Court pursuant to this Stipulation shall not be construed as any 22 ruling by the Court on the aforementioned legal statements or privilege claims in this 23 section, nor shall this section be construed as part of any such Court Order. 24 3. 25 DEFINITIONS 3.1. 26 27 28 Action: refers to Jefrick Barrios v. City of Los Angeles et al. 2:24-cv01914- MAA, and any appeals through FINAL DISPOSITION. 3.2. Challenging Party: A Party or Nonparty that challenges the designation of information or items under this Stipulated Protective Order. Revised 10/27/21 1 3.3. “CONFIDENTIAL” Information or Items: Information (regardless of 2 howit is generated, stored or maintained) or tangible things that qualify for 3 protection under Federal Rule of Civil Procedure 26(c), and as specified 4 above in the Good Cause Statement. 5 3.4. 6 7 Counsel: Outside Counsel of Record and In-House Counsel (as well as their support staff). 3.5. Designating Party: A Party or Nonparty that designates information or 8 items that it produces in disclosures or in responses to discovery as 9 “CONFIDENTIAL.” 10 3.6. Disclosure or Discovery Material: All items or information, regardless of 11 the medium or manner in which it is generated, stored, or maintained 12 (including, among other things, testimony, transcripts, and tangible things), 13 that is produced or generated in disclosures or responses to discovery in 14 this matter. 15 3.7. Expert: A person with specialized knowledge or experience in a matter 16 pertinent to the litigation who has been retained by a Party or its counsel to 17 serve as an expert witness or as a consultant in this Action. 18 3.8. In-House Counsel: Attorneys who are employees of a party to this Action. 19 In-House Counsel does not include Outside Counsel of Record or any 20 other outside counsel. 21 22 3.9. Nonparty: Any natural person, partnership, corporation, association, or other legal entity not named as a Party to this action. 23 3.10. Outside Counsel of Record: Attorneys who are not employees of a party to 24 this Action but are retained to represent or advise a party to this Action and 25 have appeared in this Action on behalf of that party or are affiliated with a 26 law firm which has appeared on behalf of that party, and includes support 27 staff. 28 Revised 10/27/21 1 3.11. Party: Any party to this Action, including all of its officers, directors, 2 employees, consultants, retained experts, In-House Counsel, and Outside 3 Counsel of Record (and their support staffs). 4 3.12. Producing Party: A Party or Nonparty that produces Disclosure or 5 Discovery Material in this Action. 6 3.13. Professional Vendors: Persons or entities that provide litigation support 7 services (e.g., photocopying, videotaping, translating, preparing exhibits or 8 demonstrations, and organizing, storing, or retrieving data in any form or 9 medium) and their employees and subcontractors. 10 3.14. Protected Material: Any Disclosure or Discovery Material that is 11 designated as “CONFIDENTIAL.” 12 3.15. Receiving Party: A Party that receives Disclosure or Discovery Material 13 from a Producing Party. 14 15 4. SCOPE 16 The protections conferred by this Stipulated Protective Order cover not only 17 Protected Material, but also (1) any information copied or extracted from Protected 18 Material; (2) all copies, excerpts, summaries, or compilations of Protected Material; and 19 (3) any testimony, conversations, or presentations by Parties or their Counsel that might 20 reveal Protected Material. 21 Any use of Protected Material at trial shall be governed by the orders of the trial 22 judge. This Stipulated Protective Order does not govern the use of Protected Material at 23 trial. 24 25 26 5. DURATION Even after final disposition of this litigation, the confidentiality obligations 27 imposed by this Stipulated Protective Order shall remain in effect until a Designating 28 Party agrees otherwise in writing or a court order otherwise directs. Final disposition Revised 10/27/21 1 shall be deemed to be the later of (1) dismissal of all claims and defenses in this Action, 2 with or without prejudice; and (2) final judgment herein after the completion and 3 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 4 including the time limits for filing any motions or applications for extension of time 5 pursuant to applicable law. 6 7 8 6. DESIGNATING PROTECTED MATERIAL 6.1. Exercise of Restraint and Care in Designating Material for Protection. 9 Each Party or Nonparty that designates information or items for 10 protection under this Stipulated Protective Order must take care to limit 11 any such designation to specific material that qualifies under the 12 appropriate standards. The Designating Party must designate for protection 13 only those parts of material, documents, items, or oral or written 14 communications that qualify so that other portions of the material, 15 documents, items, or communications for which protection is not 16 warranted are not swept unjustifiably within the ambit of this Stipulated 17 Protective Order. 18 Mass, indiscriminate, or routinized designations are prohibited. 19 Designations that are shown to be clearly unjustified or that have been 20 made for an improper purpose (e.g., to unnecessarily encumber the case 21 development process or to impose unnecessary expenses and burdens on 22 other parties) may expose the Designating Party to sanctions. 23 6.2. Manner and Timing of Designations. 24 Except as otherwise provided in this Stipulated Protective Order 25 (see, e.g., Section 6.2(a)), or as otherwise stipulated or ordered, Disclosure 26 or Discovery Material that qualifies for protection under this Stipulated 27 Protective Order must be clearly so designated before the material is 28 disclosed or produced. Revised 10/27/21 1 Designation in conformity with this Stipulated Protective Order 2 requires the following: 3 (a) For information in documentary form (e.g., paper or electronic 4 documents, but excluding transcripts of depositions or other pretrial 5 or trial proceedings), that the Producing Party affix at a minimum, 6 the legend “CONFIDENTIAL” to each page that contains protected 7 material. If only a portion or portions of the material on a page 8 qualifies for protection, the Producing Party also must clearly 9 identify the protected portion(s) (e.g., by making appropriate 10 markings in the margins). 11 A Party or Nonparty that makes original documents available 12 for inspection need not designate them for protection until after the 13 inspecting Party has indicated which documents it would like copied 14 and produced. During the inspection and before the designation, all 15 of the material made available for inspection shall be deemed 16 “CONFIDENTIAL.” After the inspecting Party has identified the 17 documents it wants copied and produced, the Producing Party must 18 determine which documents, or portions thereof, qualify for 19 protection under this Stipulated Protective Order. Then, before 20 producing the specified documents, the Producing Party must affix 21 the legend “CONFIDENTIAL” to each page that contains Protected 22 Material. If only a portion or portions of the material on a page 23 qualifies for protection, the Producing Party also must clearly 24 identify the protected portion(s) (e.g., by making appropriate 25 markings in the margins). 26 (b) For testimony given in depositions, that the Designating Party 27 identify the Disclosure or Discovery Material on the record, 28 before the close of the deposition, all protected testimony. Revised 10/27/21 1 (c) For information produced in nondocumentary form, and for any 2 other tangible items, that the Producing Party affix in a prominent 3 place on the exterior of the container or containers in which the 4 information is stored the legend “CONFIDENTIAL.” If only a 5 portion or portions of the information warrants protection, the 6 Producing Party, to the extent practicable, shall identify the 7 protected portion(s). 8 6.3. Inadvertent Failure to Designate. 9 If timely corrected, an inadvertent failure to designate qualified 10 information or items does not, standing alone, waive the Designating 11 Party’s right to secure protection under this Stipulated Protective Order for 12 such material. Upon timely correction of a designation, the Receiving Party 13 must make reasonable efforts to assure that the material is treated in 14 accordance with the provisions of this Stipulated Protective Order. 15 16 7. CHALLENGING CONFIDENTIALITY DESIGNATIONS 17 7.1. Timing of Challenges. 18 Any Party or Nonparty may challenge a designation of 19 confidentiality at any time that is consistent with the Court’s Scheduling 20 Order. 21 7.2. Meet and Confer. 22 The Challenging Party shall initiate the dispute resolution process, 23 which shall comply with Local Rule 37.1 et seq., and with Section 4 of 24 Judge Audero’s Procedures (“Mandatory Telephonic Conference for 25 Discovery Disputes”).1 26 27 28 1 Judge Audero’s Procedures are available at https://www.cacd.uscourts.gov/honorable-maria-audero. Revised 10/27/21 1 7.3. Burden of Persuasion. 2 The burden of persuasion in any such challenge proceeding shall be 3 on the Designating Party. Frivolous challenges, and those made for an 4 improper purpose (e.g., to harass or impose unnecessary expenses and 5 burdens on other parties) may expose the Challenging Party to sanctions. 6 Unless the Designating Party has waived or withdrawn the confidentiality 7 designation, all parties shall continue to afford the material in question the 8 level of protection to which it is entitled under the Producing Party’s 9 designation until the Court rules on the challenge. 10 11 12 8. ACCESS TO AND USE OF PROTECTED MATERIALS 8.1. Basic Principles. 13 A Receiving Party may use Protected Material that is disclosed or 14 produced by another Party or by a Nonparty in connection with this Action 15 only for prosecuting, defending, or attempting to settle this Action. Such 16 Protected Material may be disclosed only to the categories of persons and 17 under the conditions described in this Stipulated Protective Order. When 18 the Action reaches a final disposition, a Receiving Party must comply with 19 the provisions of Section 14 below. 20 Protected Material must be stored and maintained by a Receiving 21 Party at a location and in a secure manner that ensures that access is 22 limited to the persons authorized under this Stipulated Protective Order. 23 8.2. Disclosure of “CONFIDENTIAL” Information or Items. 24 Unless otherwise ordered by the Court or permitted in writing by the 25 Designating Party, a Receiving Party may disclose any information or item 26 designated “CONFIDENTIAL” only to: 27 28 Revised 10/27/21 1 (a) The Receiving Party’s Outside Counsel of Record, as well as 2 employees of said Outside Counsel of Record to whom it is 3 reasonably necessary to disclose the information for this Action; 4 (b) The officers, directors, and employees (including In-House Counsel) 5 of the Receiving Party to whom disclosure is reasonably necessary 6 for this Action; 7 (c) Experts of the Receiving Party to whom disclosure is reasonably 8 necessary for this Action and who have signed the 9 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 10 (d) The Court and its personnel; 11 (e) Court reporters and their staff; 12 (f) Professional jury or trial consultants, mock jurors, and Professional 13 Vendors to whom disclosure is reasonably necessary or this Action 14 and who have signed the “Acknowledgment and Agreement to be 15 Bound” (Exhibit A); 16 (g) The author or recipient of a document containing the information or 17 a custodian or other person who otherwise possessed or knew the 18 information; 19 (h) During their depositions, witnesses, and attorneys for witnesses, in 20 the Action to whom disclosure is reasonably necessary provided: (i) 21 the deposing party requests that the witness sign the 22 “Acknowledgment and Agreement to Be Bound” (Exhibit A); and 23 (ii) the witness will not be permitted to keep any confidential 24 information unless they sign the “Acknowledgment and Agreement 25 to Be Bound,” unless otherwise agreed by the Designating Party or 26 ordered by the Court. Pages of transcribed deposition testimony or 27 exhibits to depositions that reveal Protected Material may be 28 separately bound by the court reporter and may not be disclosed to Revised 10/27/21 1 anyone except as permitted under this Stipulated Protective Order; 2 and 3 (i) Any mediator or settlement officer, and their supporting personnel, 4 mutually agreed upon by any of the parties engaged in settlement 5 discussions. 6 7 9. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 8 IN OTHER LITIGATION 9 If a Party is served with a subpoena or a court order issued in other litigation that 10 compels disclosure of any information or items designated in this Action as 11 “CONFIDENTIAL,” that Party must: 12 (a) 13 14 Promptly notify in writing the Designating Party. Such notification shall include a copy of the subpoena or court order; (b) Promptly notify in writing the party who caused the subpoena or order to 15 issue in the other litigation that some or all of the material covered by the 16 subpoena or order is subject to this Stipulated Protective Order. Such 17 notification shall include a copy of this Stipulated Protective Order; and 18 (c) Cooperate with respect to all reasonable procedures sought to be pursued 19 by the Designating Party whose Protected Material may be affected. 20 If the Designating Party timely seeks a protective order, the Party served with the 21 subpoena or court order shall not produce any information designated in this action as 22 “CONFIDENTIAL” before a determination by the Court from which the subpoena or 23 order issued, unless the Party has obtained the Designating Party’s permission. The 24 Designating Party shall bear the burden and expense of seeking protection in that court 25 of its confidential material and nothing in these provisions should be construed as 26 authorizing or encouraging a Receiving Party in this Action to disobey a lawful 27 directive from another court. 28 Revised 10/27/21 1 10. A NONPARTY’S PROTECTED MATERIAL SOUGHT TO BE 2 PRODUCED IN THIS LITIGATION 3 10.1. Application. 4 The terms of this Stipulated Protective Order are applicable to 5 information produced by a Nonparty in this Action and designated as 6 “CONFIDENTIAL.” Such information produced by Nonparties in 7 connection with this litigation is protected by the remedies and relief 8 provided by this Stipulated Protective Order. Nothing in these provisions 9 should be construed as prohibiting a Nonparty from seeking additional 10 11 protections. 10.2. Notification. 12 In the event that a Party is required, by a valid discovery request, to 13 produce a Nonparty’s confidential information in its possession, and the 14 Party is subject to an agreement with the Nonparty not to produce the 15 Nonparty’s confidential information, then the Party shall: 16 (a) Promptly notify in writing the Requesting Party and the Nonparty 17 that some or all of the information requested is subject to a 18 confidentiality agreement with a Nonparty; 19 (b) Promptly provide the Nonparty with a copy of the Stipulated 20 Protective Order in this Action, the relevant discovery request(s), 21 and a reasonably specific description of the information requested; 22 and 23 (c) 24 25 Make the information requested available for inspection by the Nonparty, if requested. 10.3. Conditions of Production. 26 If the Nonparty fails to seek a protective order from this Court 27 within fourteen (14) days after receiving the notice and accompanying 28 information, the Receiving Party may produce the Nonparty’s confidential Revised 10/27/21 1 information responsive to the discovery request. If the Nonparty timely 2 seeks a protective order, the Receiving Party shall not produce any 3 information in its possession or control that is subject to the confidentiality 4 agreement with the Nonparty before a determination by the Court. Absent 5 a court order to the contrary, the Nonparty shall bear the burden and 6 expense of seeking protection in this Court of its Protected Material. 7 8 11. 9 UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 10 Protected Material to any person or in any circumstance not authorized under this 11 Stipulated Protective Order, the Receiving Party immediately must (1) notify in writing 12 the Designating Party of the unauthorized disclosures, (2) use its best efforts to retrieve 13 all unauthorized copies of the Protected Material, (3) inform the person or persons to 14 whom unauthorized disclosures were made of all the terms of this Stipulated Protective 15 Order, and (4) request such person or persons to execute the “Acknowledgment and 16 Agreement to be Bound” (Exhibit A). 17 18 12. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 19 PROTECTED MATERIAL 20 When a Producing Party gives notice to Receiving Parties that certain 21 inadvertently produced material is subject to a claim of privilege or other protection, the 22 obligations of the Receiving Parties are those set forth in Federal Rule of Civil 23 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 24 may be established in an e-discovery order that provides for production without prior 25 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 26 parties reach an agreement on the effect of disclosure of a communication or 27 information covered by the attorney-client privilege or work product protection, the 28 Revised 10/27/21 1 parties may incorporate their agreement in the Stipulated Protective Order submitted to 2 the Court. 3 4 13. 5 MISCELLANEOUS 13.1. Right to Further Relief. 6 Nothing in this Stipulated Protective Order abridges the right of any 7 person to seek its modification by the Court in the future. 8 13.2. Right to Assert Other Objections. 9 By stipulating to the entry of this Stipulated Protective Order, no 10 Party waives any right it otherwise would have to object to disclosing or 11 producing any information or item on any ground not addressed in this 12 Stipulated Protective Order. Similarly, no Party waives any right to object 13 on any ground to use in evidence of any of the material covered by this 14 Stipulated Protective Order. 15 13.3. Filing Protected Material. 16 A Party that seeks to file under seal any Protected Material must 17 comply with Local Rule 79-5. Protected Material may only be filed under 18 seal pursuant to a court order authorizing the sealing of the specific 19 Protected Material at issue. If a Party's request to file Protected Material 20 under seal is denied by the Court, then the Receiving Party may file the 21 information in the public record unless otherwise instructed by the Court. 22 23 24 14. FINAL DISPOSITION After the final disposition of this Action, as defined in paragraph 5, within sixty 25 (60) days of a written request by the Designating Party, each Receiving Party must 26 return all Protected Material to the Producing Party or destroy such material. As used in 27 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 28 summaries, and any other format reproducing or capturing any of the Protected Revised 10/27/21 1 Material. Whether the Protected Material is returned or destroyed, the Receiving Party 2 must submit a written certification to the Producing Party (and, if not the same person 3 or entity, to the Designating Party) by the 60-day deadline that (1) identifies (by 4 category, where appropriate) all the Protected Material that was returned or destroyed 5 and (2) affirms that the Receiving Party has not retained any copies, abstracts, 6 compilations, summaries or any other format reproducing or capturing any of the 7 Protected Material. Notwithstanding this provision, Counsel is entitled to retain an 8 archival copy of all pleadings; motion papers; trial, deposition, and hearing transcripts; 9 legal memoranda; correspondence; deposition and trial exhibits; expert reports; attorney 10 work product; and consultant and expert work product, even if such materials contain 11 Protected Material. Any such archival copies that contain or constitute Protected 12 Material remain subject to this Stipulated Protective Order as set forth in Section 5. 13 14 15. 15 VIOLATION Any violation of this Stipulated Order may be punished by any and all 16 appropriate measures including, without limitation, contempt proceedings and/or 17 monetary sanctions. 18 19 /// 20 21 /// 22 23 /// 24 25 /// 26 27 /// 28 Revised 10/27/21 1 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 2 3 Dated: July 2, 2024 4 By: 5 6 7 LAW OFFICE OF THOMAS S. SEABAUGH Dated: July 2, 2024 8 9 /s/ Thomas S. Seabaugh Attorney for Plaintiff HYDEE FELDSTEIN SOTO, City Attorney DENISE C. MILLS, Chief Deputy City Attorney KATHLEEN KENEALY, Chief Asst. City Atty. CORY M. BRENTE, Senior Asst. City Attorney By: ftá{t bA _tétÜxä|v{ SASHA O. LAZAREVICH2, Deputy City Atty. Attorneys for Defendant, CITY OF LOS ANGELES 10 11 12 13 14 15 16 17 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. Dated: July 3, 2024 Honorable Maria A. Audero United States Magistrate Judge 18 19 20 21 22 23 24 25 26 27 28 2 Pursuant to Local rule 5 5-4.3.4(a)(2)(i), I attest that the other signatories listed, and on whose behalf the filing is submitted, concur in the filing’s content and have authorized the filing. Revised 10/27/21 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, 4 [full name], of [address], declare under penalty of perjury that I have read in its entirety 5 and understand the Stipulated Protective Order that was issued by the United States 6 District Court for the Central District of California on 7 the case of Jefrick Barrios v. City of Los Angeles et al.; 2:24-cv-01914- 8 DDP-MAA, and any appeals through FINAL DISPOSITION. I agree to comply with 9 and to be bound by all the terms of this Stipulated Protective Order, and I understand [date] in 10 and acknowledge that failure to so comply could expose me to sanctions and 11 punishment in the nature of contempt. I solemnly promise that I will not disclose in any 12 manner any information or item that is subject to this Stipulated Protective Order to any 13 person or entity except in strict compliance with the provisions of this Stipulated 14 Protective Order. 15 I further agree to submit to the jurisdiction of the United States District Court for 16 the Central District of California for the purpose of enforcing the terms of this 17 Stipulated Protective Order, even if such enforcement proceedings occur after 18 termination of this action. I hereby appoint [full name] of 19 [address and telephone 20 number] as my California agent for service of process in connection with this action or 21 any proceedings related to enforcement of this Stipulated Protective Order. 22 23 Signature: 24 Printed Name: 25 Date: 26 City and State Where Sworn and Signed: 27 28 18

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