The opinion
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8 UNITED STATES DISTRICT COURT
9 CENTRAL DISTRICT OF CALIFORNIA
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11 JOSEPH WARD-WALLACE, an CASE NO. 2:25-cv-03662-WLH-MAR
individual
Hon. John F. Walter – Ctrm. 7A
12
Hon. Margo A. Rocconi – Ctrm. 790
13 Plaintiff(s),
STIPULATED PROTECTIVE
14 v.
ORDER
15 LOS ANGELES POLICE
DEPARTMENT, public entity; CITY
16 OF LOS ANGELES, a public enity;
JOSHUA SPORTIELLO, an individual;
17 EDWARD PEDROZA, an individual,
18 Defendant(s).
19
20
21 1. INTRODUCTION
22 1.1 PURPOSES AND LIMITATIONS
23 Discovery in this action is likely to involve production of confidential, proprietary,
24 or private information for which special protection from public disclosure and from use
25 for any purpose other than prosecuting this litigation may be warranted. Accordingly, the
26 parties hereby stipulate to and petition the Court to enter the following Stipulated
27 Protective Order. The parties acknowledge that this Order does not confer blanket
1 from public disclosure and use extends only to the limited information or items that are
2 entitled to confidential treatment under the applicable legal principles. The parties further
3 acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective Order
4 does not entitle them to file confidential information under seal; Civil Local Rule 79-5
5 sets forth the procedures that must be followed and the standards that will be applied
6 when a party seeks permission from the court to file material under seal.
7 1.2 GOOD CAUSE STATEMENT
8 This action involves employees of the City of Los Angeles (the “City”) which
9 include members of the City’s Los Angeles Police Department (“LAPD”) which include
10 at least one named defendant (collectively “Defendants”). The nature of the incident that
11 gives rise to Plaintiff’s suit and Plaintiff’s claims and allegations, will result in discovery
12 production that includes: police reports and evidence; investigation reports and evidence;
13 peace officer personnel materials; information implicating the privacy rights of third
14 parties (i.e., bystander witnesses, emergency personnel information); and other private
15 and confidential materials for which require special protection from public disclosure.
16 Specifically, Plaintiff is seeking materials and information that Defendant(s)
17 employer/the City maintains as confidential such as personnel files of the police and/or
18 sworn officers involved in this incident, Internal Affairs materials and information, video
19 recordings, audio recordings, photographs, and information and other administrative
20 materials and information currently in the possession of the City and which Defendants’
21 employer believes need special protection from public disclosure and from use for any
22 purpose other than prosecuting this litigation. Plaintiff may also seek official information
23 contained in the personnel files of the police and/or sworn officers involved in the subject
24 incident, which are maintained as strictly confidential and which Defendants believe need
25 special protection from public disclosure and from use for any purpose other than
26 prosecuting this litigation.
27 Defendants assert that the confidentiality of the materials and information sought
1 California Penal Code section 832.7 and Kerr v. United States Dist. Ct. for N.D. Cal., 511
2 F.2d 192, 198 (9th Cir. 1975), aff'd, 426 U.S. 394 (1976). Defendants have not publicly
3 released the materials and information referenced above except under protective order or
4 pursuant to a court order, if at all. The personnel materials and information are of the type
5 that has been used to initiate disciplinary action against the City’s respective employees,
6 and has been used as evidence in disciplinary proceedings, where the employee conduct
7 was considered to be contrary to policy.
8 Defendants contend that absent a protective order delineating the responsibilities
9 of nondisclosure on the part of the parties hereto, there is a specific risk of unnecessary
10 and undue disclosure by one or more of the many attorneys, secretaries, law clerks,
11 paralegals and expert witnesses involved in this case, as well as the corollary risk of
12 embarrassment, harassment and professional and legal harm on the part of the City’s
13 employees referenced in the materials and information.
14 Defendants also contend that the unfettered disclosure of the materials and
15 information, absent a protective order, would allow the media to share this information
16 with potential jurors in the area, impacting the rights of Defendants herein to receive a
17 fair trial.
18 Accordingly, to expedite the flow of information, to facilitate the prompt resolution
19 of disputes over confidentiality of discovery materials, to adequately protect information
20 the parties are entitled to keep confidential, to ensure that the parties are permitted
21 reasonable necessary uses of such material in preparation for and in the conduct of trial,
22 to address their handling at the end of the litigation, and serve the ends of justice, a
23 protective order for such information is justified in this matter. It is the intent of the
24 parties that information will not be designated as confidential for tactical reasons and that
25 nothing be so designated without a good faith belief that it has been maintained in a
26 confidential, non-public manner, and there is good cause why it should not be part of the
27 public record of this case.
1 Plaintiff does not agree with and does not stipulate to Defendants’ contentions as
2 set forth above. Nothing in this Stipulation or its associated Order shall resolve the
3 parties’ disagreement, or bind them, concerning the legal statements and claimed
4 privileges set forth above. However, Plaintiff agrees that there is Good Cause for a
5 Protective Order so as to preserve the respective interests of the parties while streamlining
6 the process of resolving any disagreements. Specifically, Plaintiff contends that, absent
7 this Stipulation and its associated Protective Order, the parties’ respective privilege
8 interests may be impaired or harmed, and that this Stipulation and its associated
9 Protective Order may avoid such harm by permitting the parties to facilitate discovery
10 with reduced risk that privileged and/or sensitive/confidential information will become
11 matters of public record.
12 The parties therefore stipulate that there is Good Cause for, and hereby jointly
13 request that the honorable Court issue a Protective Order regarding confidential
14 documents consistent with the terms and provisions of this Stipulation. However, the
15 entry of a Protective Order by the Court pursuant to this Stipulation shall not be construed
16 as any ruling by the Court on the aforementioned legal statements or privilege claims in
17 this section.
18
19 2. DEFINITIONS
20 2.1 Action: Ward-Wallace v. City of Los Angeles, et al., case no. 2:25-cv-03662-
21 WLH-MAR.
22 2.2 Challenging Party: a Party or Non-Party that challenges the designation of
23 information or items under this Order.
24 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how
25 it is generated, stored or maintained) or tangible things that qualify for protection under
26 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause
27 Statement.
1 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their
2 support staff).
3 2.5 Designating Party: a Party or Non-Party that designates information or items
4 that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.”
5 2.6 Disclosure or Discovery Material: all items or information, regardless of the
6 medium or manner in which it is generated, stored, or maintained (including, among other
7 things, testimony, transcripts, and tangible things), that are produced or generated in
8 disclosures or responses to discovery in this matter.
9 2.7 Expert: a person with specialized knowledge or experience in a matter
10 pertinent to the litigation who has been retained by a Party or its counsel to serve as an
11 expert witness or as a consultant in this Action.
12 2.8 House Counsel: attorneys who are employees of a party to this Action.
13 House Counsel does not include Outside Counsel of Record or any other outside counsel.
14 2.9 Non-Party: any natural person, partnership, corporation, association, or
15 other legal entity not named as a Party to this action.
16 2.10 Outside Counsel of Record: attorneys who are not employees of a party to
17 this Action but are retained to represent or advise a party to this Action and have
18 appeared in this Action on behalf of that party or are affiliated with a law firm which has
19 appeared on behalf of that party, and includes support staff.
20 2.11 Party: any party to this Action, including all of its officers, directors,
21 employees, consultants, retained experts, and Outside Counsel of Record (and their
22 support staffs).
23 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
24 Discovery Material in this Action.
25 2.13 Professional Vendors: persons or entities that provide litigation support
26 services (e.g., photocopying, videotaping, translating, preparing exhibits or
27 demonstrations, and organizing, storing, or retrieving data in any form or medium) and
1 2.14 Protected Material: any Disclosure or Discovery Material that is designated
2 as “CONFIDENTIAL.”
3 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material from
4 a Producing Party.
5
6 3. SCOPE
7 The protections conferred by this Stipulation and Order cover not only Protected
8 Material (as defined above), but also (1) any information copied or extracted from
9 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected
10 Material; and (3) any testimony, conversations, or presentations by Parties or their
11 Counsel that might reveal Protected Material.
12 Any use of Protected Material at trial will be governed by the orders of the trial
13 judge. This Order does not govern the use of Protected Material at trial.
14 4. DURATION
15 Once a case proceeds to trial, all of the information that was designated as
16 confidential or maintained pursuant to this protective order becomes public and will be
17 presumptively available to all members of the public, including the press, unless
18 compelling reasons supported by specific factual findings to proceed otherwise are made
19 to the trial judge in advance of the trial. See Kamakana v. City and County of Honolulu,
20 447 F.3d 1172, 1180–81 (9th Cir. 2006) (distinguishing “good cause” showing for sealing
21 documents produced in discovery from “compelling reasons” standard when merits-
22 related documents are part of court record). Accordingly, the terms of this protective
23 order do not extend beyond the commencement of the trial.
24 If the case does not proceed to trial, the confidentiality obligations imposed by this
25 Order will remain in effect until a Designating Party agrees otherwise in writing or upon
26 final disposition of the case, whichever occurs first. Final disposition will be deemed to
27 be the later of (1) dismissal of all claims and defenses in this Action, with or without
1 appeals, rehearings, remands, trials, or reviews of this Action, including the time limits
2 for filing any motions or applications for extension of time pursuant to applicable law.
3
4 5. DESIGNATING PROTECTED MATERIAL
5 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each
6 Party or Non-Party that designates information or items for protection under this Order
7 must take care to limit any such designation to specific material that qualifies under the
8 appropriate standards. The Designating Party must designate for protection only those
9 parts of material, documents, items, or oral or written communications that qualify so that
10 other portions of the material, documents, items, or communications for which protection
11 is not warranted are not swept unjustifiably within the ambit of this Order.
12 Mass, indiscriminate, or routinized designations are prohibited. Designations that
13 are shown to be clearly unjustified or that have been made for an improper purpose (e.g.,
14 to unnecessarily encumber the case development process or to impose unnecessary
15 expenses and burdens on other parties) may expose the Designating Party to sanctions.
16 If it comes to a Designating Party’s attention that information or items that it
17 designated for protection do not qualify for protection, that Designating Party must
18 promptly notify all other Parties that it is withdrawing the inapplicable designation.
19 5.2 Manner and Timing of Designations. Except as otherwise provided in this
20 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or
21 ordered, Disclosure or Discovery Material that qualifies for protection under this Order
22 must be clearly so designated before the material is disclosed or produced.
23 Designation in conformity with this Order requires:
24 (a) for information in documentary form (e.g., paper or electronic
25 documents, but excluding transcripts of depositions or other pretrial or trial proceedings),
26 that the Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter
27 “CONFIDENTIAL legend”), to each page that contains protected material. If only a
1 also must clearly identify the protected portion(s) (e.g., by making appropriate markings
2 in the margins).
3 A Party or Non-Party that makes original documents available for inspection need
4 not designate them for protection until after the inspecting Party has indicated which
5 documents it would like copied and produced. During the inspection and before the
6 designation, all of the material made available for inspection will be deemed
7 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants
8 copied and produced, the Producing Party must determine which documents, or portions
9 thereof, qualify for protection under this Order. Then, before producing the specified
10 documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page
11 that contains Protected Material. If only a portion or portions of the material on a page
12 qualifies for protection, the Producing Party also must clearly identify the protected
13 portion(s) (e.g., by making appropriate markings in the margins).
14 (b) for testimony given in depositions that the Designating Party identify
15 the Disclosure or Discovery Material on the record, before the close of the deposition all
16 protected testimony.
17 (c) for information produced in some form other than documentary and
18 for any other tangible items, that the Producing Party affix in a prominent place on the
19 exterior of the container or containers in which the information is stored the legend
20 “CONFIDENTIAL.” If only a portion or portions of the information warrants protection,
21 the Producing Party, to the extent practicable, will identify the protected portion(s).
22 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure
23 to designate qualified information or items does not, standing alone, waive the
24 Designating Party’s right to secure protection under this Order for such material. Upon
25 timely correction of a designation, the Receiving Party must make reasonable efforts to
26 assure that the material is treated in accordance with the provisions of this Order.
27
1 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation
2 of confidentiality at any time that is consistent with the Court’s Scheduling Order.
3 6.2 Meet and Confer. The Challenging Party will initiate the dispute resolution
4 process under Local Rule 37.1 et seq.
5 6.3 The burden of persuasion in any such challenge proceeding will be on the
6 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g.,
7 to harass or impose unnecessary expenses and burdens on other parties) may expose the
8 Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn
9 the confidentiality designation, all parties will continue to afford the material in question
10 the level of protection to which it is entitled under the Producing Party’s designation until
11 the Court rules on the challenge.
12
13 7. ACCESS TO AND USE OF PROTECTED MATERIAL
14 7.1 Basic Principles. A Receiving Party may use Protected Material that is
15 disclosed or produced by another Party or by a Non-Party in connection with this Action
16 only for prosecuting, defending, or attempting to settle this Action. Such Protected
17 Material may be disclosed only to the categories of persons and under the conditions
18 described in this Order. When the Action has been terminated, a Receiving Party must
19 comply with the provisions of section 13 below (FINAL DISPOSITION).
20 Protected Material must be stored and maintained by a Receiving Party at a
21 location and in a secure manner that ensures that access is limited to the persons
22 authorized under this Order.
23 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise
24 ordered by the court or permitted in writing by the Designating Party, a Receiving Party
25 may disclose any information or item designated “CONFIDENTIAL” only to:
26 (a) the Receiving Party’s Outside Counsel of Record in this Action, as
27 well as employees of said Outside Counsel of Record to whom it is reasonably necessary
1 (b) the officers, directors, and employees (including House Counsel) of
2 the Receiving Party to whom disclosure is reasonably necessary for this Action;
3 (c) Experts (as defined in this Order) of the Receiving Party to whom
4 disclosure is reasonably necessary for this Action and who have signed the
5 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
6 (d) the Court and its personnel;
7 (e) court reporters and their staff;
8 (f) professional jury or trial consultants, mock jurors, and Professional
9 Vendors to whom disclosure is reasonably necessary for this Action and who have signed
10 the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
11 (g) the author or recipient of a document containing the information or a
12 custodian or other person who otherwise possessed or knew the information;
13 (h) during their depositions, witnesses, and attorneys for witnesses, in the
14 Action to whom disclosure is reasonably necessary provided: (1) the deposing party
15 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will not
16 be permitted to keep any confidential information unless they sign the “Acknowledgment
17 and Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating
18 Party or ordered by the court. Pages of transcribed deposition testimony or exhibits to
19 depositions that reveal Protected Material may be separately bound by the court reporter
20 and may not be disclosed to anyone except as permitted under this Stipulated Protective
21 Order; and
22 (i) any mediator or settlement officer, and their supporting personnel,
23 mutually agreed upon by any of the parties engaged in settlement discussions.
24 / / /
25 / / /
26 / / /
27 / / /
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 that
4 compels disclosure of any information or items designated in this Action as
5 “CONFIDENTIAL,” that Party must:
6 (a) promptly notify in writing the Designating Party. Such notification
7 will include a copy of the subpoena or court order;
8 (b) promptly notify in writing the party who caused the subpoena or order
9 to issue in the other litigation that some or all of the material covered by the subpoena or
10 order is subject to this Protective Order. Such notification will include a copy of this
11 Stipulated Protective Order; and
12 (c) cooperate with respect to all reasonable procedures sought to be
13 pursued by the Designating Party whose Protected Material may be affected. If the
14 Designating Party timely seeks a protective order, the Party served with the subpoena or
15 court order will not produce any information designated in this action as
16 “CONFIDENTIAL” before a determination by the court from which the subpoena or
17 order issued, unless the Party has obtained the Designating Party’s permission. The
18 Designating Party will bear the burden and expense of seeking protection in that court of
19 its confidential material and nothing in these provisions should be construed as
20 authorizing or encouraging a Receiving Party in this Action to disobey a lawful directive
21 from another court.
22
23 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED
24 IN THIS LITIGATION
25 (a) The terms of this Order are applicable to information produced by a
26 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
27 produced by Non-Parties in connection with this litigation is protected by the remedies
1 and relief provided by this Order. Nothing in these provisions should be construed as
2 prohibiting a Non-Party from seeking additional protections.
3 (b) In the event that a Party is required, by a valid discovery request, to
4 produce a Non-Party’s confidential information in its possession, and the Party is subject
5 to an agreement with the Non-Party not to produce the Non-Party’s confidential
6 information, then the Party will:
7 (1) promptly notify in writing the Requesting Party and the Non-Party
8 that some or all of the information requested is subject to a confidentiality agreement with
9 a Non-Party;
10 (2) promptly provide the Non-Party with a copy of the Stipulated
11 Protective Order in this Action, the relevant discovery request(s), and a reasonably
12 specific description of the information requested; and
13 (3) make the information requested available for inspection by the Non-
14 Party, if requested.
15 (c) If the Non-Party fails to seek a protective order from this court within
16 14 days of receiving the notice and accompanying information, the Receiving Party may
17 produce the Non-Party’s confidential information responsive to the discovery request. If
18 the Non-Party timely seeks a protective order, the Receiving Party shall not produce any
19 information in its possession or control that is subject to the confidentiality agreement
20 with the Non-Party before a determination by the court. Absent a court order to the
21 contrary, the Non-Party shall bear the burden and expense of seeking protection in this
22 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 writing
1 all unauthorized copies of the Protected Material, (c) inform the person or persons to
2 whom unauthorized disclosures were made of all the terms of this Order, and (d) request
3 such person or persons to execute the “Acknowledgment and Agreement to Be Bound”
4 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 inadvertently
9 produced material is subject to a claim of privilege or other protection, the obligations of
10 the Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B).
11 This provision is not intended to modify whatever procedure may be established in an e-
12 discovery order that provides for production without prior privilege review. Pursuant to
13 Federal Rule of Evidence 502(d) and (e), insofar as the parties reach an agreement on the
14 effect of disclosure of a communication or information covered by the attorney-client
15 privilege or work product protection, the parties may incorporate their agreement in the
16 stipulated protective order submitted to the court.
17
18 12. MISCELLANEOUS
19 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
20 person to seek its modification by the Court in the future.
21 12.2 Right to Assert Other Objections. By stipulating to the entry of this
22 Protective Order no Party waives any right it otherwise would have to object to disclosing
23 or producing any information or item on any ground not addressed in this Stipulated
24 Protective Order. Similarly, no Party waives any right to object on any ground to use in
25 evidence of any of the material covered by this Protective Order.
26 12.3 Filing Protected Material. A Party that seeks to file under seal any Protected
27 Material must comply with Civil Local Rule 79-5. Protected Material may only be filed
1 Material at issue. If a Party’s request to file Protected Material under seal is denied by the
2 court, then the Receiving Party may file the information in the public record unless
3 otherwise instructed by the court.
4
5 13. FINAL DISPOSITION
6 After the final disposition of this Action, as defined in paragraph 4, within 60 days
7 of a written request by the Designating Party, each Receiving Party must return all
8 Protected Material to the Producing Party or destroy such material. As used in this
9 subdivision, “all Protected Material” includes all copies, abstracts, compilations,
10 summaries, and any other format reproducing or capturing any of the Protected Material.
11 Whether the Protected Material is returned or destroyed, the Receiving Party must submit
12 a written certification to the Producing Party (and, if not the same person or entity, to the
13 Designating Party) by the 60 day deadline that (1) identifies (by category, where
14 appropriate) all the Protected Material that was returned or destroyed and (2) affirms that
15 the Receiving Party has not retained any copies, abstracts, compilations, summaries or
16 any other format reproducing or capturing any of the Protected Material. Notwithstanding
17 this provision, Counsel are entitled to retain an archival copy of all pleadings, motion
18 papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence,
19 deposition and trial exhibits, expert reports, attorney work product, and consultant and
20 expert work product, even if such materials contain Protected Material. Any such archival
21 copies that contain or constitute Protected Material remain subject to this Protective Order
22 as set forth in Section 4 (DURATION).
23 / / /
24 / / /
25 / / /
26 / / /
27 / / /
1 Any willful violation of this Order may be punished by civil or criminal contempt
proceedings, financial or evidentiary sanctions, reference to disciplinary authorities, or
3 other appropriate action at the discretion of the Court.
4 IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
5 || Dated: October 27, 2025 LAW OFFICES OF CHRISTIAN CONTRERAS
6 A PROFESSIONAL LAW CORPORATION
By: /s/ Christian Contreras
7 Christian Contreras, Esq.
g Attorneys for Plaintiff, JOSEPH WARD-WALLACE
9 Dated: October 27, 2025 HYDEE FELDSTEIN SOTO, City Attorney
DENISE C. MILLS, Chief Deputy City Attorney
10 KATHLEEN KENEALY, Chief Assistant City Attorne
12 REBECCA E. HUNTER, Deputy City Attorney
dizorneys [or Defendants. LOS ANGELES POLIC
13 DEPARTMENT, CITY OF LOS ANGELES, JOSHUA
SPORTIELLO and EDWARD PEDROZA
14
15 ATTESTATION
16 Pursuant to L.R. 5-4.3.4(a)(2)(), I hereby attest that Thomas C. Seabaugh, counsel
7 for Plaintiff Boston Moreland, concur in the content of this filing and has authorized this
12 filing.
19 Dated: October 27, 2025 HYDEE FELDSTEIN SOTO, City Attorney
DENISE C. MILLS, Chief Deputy City Attorney
0 KATHLEEN KENEALY, Chief Assistant City Attorne
REBECCA E. HUNTER, Deputy City Attomey
22 Attorneys for Defendants, LOS ANGELES POLIC
DEPARTMENT, CITY OF LOS ANGELES, JOSHUA
23 SPORTIELLO and EDWARD PEDROZA
24
35 FOR GOOD CAUSE SHOWN, IT IS SO 108
26 || DATED: 11/20/2025
HON. MARGO A. ROCCONI
38 United States Magistrate Judge
1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3 I, _____________________________ [print or type full name], of
4 _________________ [print or type full address], declare under penalty of perjury that I
5 have read in its entirety and understand the Stipulated Protective Order that was issued
6 by the United States District Court for the Central District of California on _________
7 [date] in the case of Ward-Wallace v. City of Los Angeles, et al., case no. 2:25-cv-03662-
8 WLH-MAR. I agree to comply with and to be bound by all the terms of this Stipulated
9 Protective Order and I understand and acknowledge that failure to so comply could
10 expose me to sanctions and punishment in the nature of contempt. I solemnly promise
11 that I will not disclose in any manner any information or item that is subject to this
12 Stipulated Protective Order to any person or entity except in strict compliance with the
13 provisions of this Order.
14 I further agree to submit to the jurisdiction of the United States District Court for
15 the Central District of California for the purpose of enforcing the terms of this Stipulated
16 Protective Order, even if such enforcement proceedings occur after termination of this
17 action. I hereby appoint __________________________ [print or type full name] of
18 _______________________________________ [print or type full address and telephone
19 number] as my California agent for service of process in connection with this action or
20 any proceedings related to enforcement of this Stipulated Protective Order.
21 Date: ______________________________________
22 City and State where signed: _________________________________
23
24 Printed name: _______________________________
25
26 Signature: __________________________________
27