The opinion
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UNITED STATES DISTRICT COURT
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CENTRAL DISTRICT OF CALIFORNIA
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11 NEHEMIAH DAVIDSON CASE NO. 2:25-cv-07865-ODW-(RAOx)
Hon. Otis D. Wright – Ctrm. 5D, 1st St
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Hon. Rozella A. Oliver – Ctrm. 590. Roybal
13 Plaintiff(s),
14 v.
STIPULATED PROTECTIVE ORDER
15 CITY OF LOS ANGELES; DENNIS
EAMES; JAMES SPELLMAN; PIERRE
16 OLEGA; SERGENT CRUZ; and DOES
1 through 10, inclusive,
17
Defendant(s).
18
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20 1. A. PURPOSES AND LIMITATIONS
21 Discovery in this action is likely to involve production of confidential,
22 proprietary or private information for which special protection from public disclosure
23 and from use for any purpose other than prosecuting this litigation may be warranted.
24 Accordingly, the parties hereby stipulate to and petition the Court to enter the following
25 Stipulated Protective Order. The parties acknowledge that this Order does not confer
26 blanket protections on all disclosures or responses to discovery and that the protection it
27 affords from public disclosure and use extends only to the limited information or items
1 B. GOOD CAUSE STATEMENT
2 This action involves employees of the City of Los Angeles (the “City”) which
3 include members of the City’s Los Angeles Police Department (“LAPD”). The nature of
4 the incident that gives rise to Plaintiff’s suit and Plaintiff’s claims and allegations, will
5 result in discovery production that includes: police reports and evidence; investigation
6 reports and evidence; potentially peace officer personnel materials; information
7 implicating the privacy rights of third parties (i.e., bystander witnesses, emergency
8 personnel information); and other private and confidential materials for which require
9 special protection from public disclosure.
10 Specifically, Plaintiff is seeking materials and information that Defendant
11 maintains as confidential such as personnel files of the police and/or sworn officers
12 involved in this incident, Internal Affairs materials and information, video recordings,
13 audio recordings, photographs, and information and other administrative materials and
14 information currently in the possession of the City and which Defendant believes need
15 special protection from public disclosure and from use for any purpose other than
16 prosecuting this litigation. Plaintiff may also seek official information contained in the
17 personnel files of the police and/or sworn officers involved in the subject incident, which
18 are maintained as strictly confidential and which Defendants believe need special
19 protection from public disclosure and from use for any purpose other than prosecuting
20 this litigation.
21 Defendant asserts that the confidentiality of the materials and information sought
22 by Plaintiff is recognized by California and federal law, as evidenced inter alia by
23 California Penal Code section 832.7 and Kerr v. United States Dist. Ct. for N.D. Cal.,
24 511 F.2d 192, 198 (9th Cir. 1975), aff'd, 426 U.S. 394 (1976). Defendant has not publicly
25 released the materials and information referenced above except under protective order or
26 pursuant to a court order, if at all. The personnel materials and information are of the type
27 that has been used to initiate disciplinary action against the City’s respective employees,
1 and has been used as evidence in disciplinary proceedings, where the employee conduct
2 was considered to be contrary to policy.
3 Defendant contends that absent a protective order delineating the responsibilities
4 of nondisclosure on the part of the parties hereto, there is a specific risk of unnecessary
5 and undue disclosure by one or more of the many attorneys, secretaries, law clerks,
6 paralegals and expert witnesses involved in this case, as well as the corollary risk of
7 embarrassment, harassment and professional and legal harm on the part of the City’s
8 employees referenced in the materials and information.
9 Defendant also contends that the unfettered disclosure of the materials and
10 information, absent a protective order, would allow the media to share this information
11 with potential jurors in the area, impacting the rights of Defendant herein to receive a fair
12 trial.
13 Accordingly, to expedite the flow of information, to facilitate the prompt resolution
14 of disputes over confidentiality of discovery materials, to adequately protect information
15 the parties are entitled to keep confidential, to ensure that the parties are permitted
16 reasonable necessary uses of such material in preparation for and in the conduct of trial,
17 to address their handling at the end of the litigation, and serve the ends of justice, a
18 protective order for such information is justified in this matter. It is the intent of the
19 parties that information will not be designated as confidential for tactical reasons and that
20 nothing be so designated without a good faith belief that it has been maintained in a
21 confidential, non-public manner, and there is good cause why it should not be part of the
22 public record of this case.
23 Plaintiff agrees that there is Good Cause for a Protective Order so as to preserve
24 the respective interests of the parties while streamlining the process of resolving any
25 disagreements.
26 The parties therefore stipulate that there is Good Cause for, and hereby jointly
27 request that the honorable Court issue a Protective Order regarding confidential
1 entry of a Protective Order by the Court pursuant to this Stipulation shall not be construed
2 as any ruling by the Court on the aforementioned legal statements or privilege claims in
3 this section, no shall this section be construed as part of any such Court Order.
4 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL
5 The parties further acknowledge, as set forth in Section 12.3, below, that this
6 Stipulated Protective Order does not entitle them to file confidential information under
7 seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the
8 standards that will be applied when a party seeks permission from the court to file
9 material under seal.
10 There is a strong presumption that the public has a right of access to judicial
11 proceedings and records in civil cases. In connection with non-dispositive motions,
12 good cause must be shown to support a filing under seal. See Kamakana v. City and
13 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006); Phillips v. Gen. Motors
14 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002); Makar-Welbon v. Sony Electrics, Inc.,
15 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require good
16 cause showing), and a specific showing of good cause or compelling reasons with
17 proper evidentiary support and legal justification, must be made with respect to
18 Protected Material that a party seeks to file under seal. The parties’ mere designation of
19 Disclosure or Discovery Material as CONFIDENTIAL does not—without the
20 submission of competent evidence by declaration, establishing that the material sought
21 to be filed under seal qualifies as confidential, privileged, or otherwise protectable—
22 constitute good cause.
23 Further, if a party requests sealing related to a dispositive motion or trial, then
24 compelling reasons, not only good cause, for the sealing must be shown, and the relief
25 sought shall be narrowly tailored to serve the specific interest to be protected. See
26 Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For each item
27 or type of information, document, or thing sought to be filed or introduced under seal in
1 articulate compelling reasons, supported by specific facts and legal justification, for the
2 requested sealing order. Again, competent evidence supporting the application to file
3 documents under seal must be provided by declaration.
4 Any document that is not confidential, privileged, or otherwise protectable in its
5 entirety will not be filed under seal if the confidential portions can be redacted. If
6 documents can be redacted, then a redacted version for public viewing, omitting only
7 the confidential, privileged, or otherwise protectable portions of the document shall be
8 filed. Any application that seeks to file documents under seal in their entirety should
9 include an explanation of why redaction is not feasible.
10 2. DEFINITIONS
11 2.1 Action: Davidson v. City of Los Angeles, et al., case no. 2:25-cv-07865-
12 ODW-(RAO)
13 2.2 Challenging Party: a Party or Non-Party that challenges the designation of
14 information or items under this Order.
15 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how
16 it is generated, stored or maintained) or tangible things that qualify for protection under
17 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause
18 Statement.
19 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their
20 support staff).
21 2.5 Designating Party: a Party or Non-Party that designates information or
22 items that it produces in disclosures or in responses to discovery as
23 “CONFIDENTIAL.”
24 2.6 Disclosure or Discovery Material: all items or information, regardless of
25 the medium or manner in which it is generated, stored, or maintained (including, among
26 other things, testimony, transcripts, and tangible things) that are produced or generated
27 in disclosures or responses to discovery in this matter.
1 pertinent to the litigation who has been retained by a Party or its counsel to serve as an
2 expert witness or as a consultant in this Action.
3 2.8 House Counsel: attorneys who are employees of a party to this Action.
4 House Counsel does not include Outside Counsel of Record or any other outside
5 counsel.
6 2.9 Non-Party: any natural person, partnership, corporation, association or
7 other legal entity not named as a Party to this action.
8 2.10 Outside Counsel of Record: attorneys who are not employees of a party to
9 this Action but are retained to represent or advise a party to this Action and have
10 appeared in this Action on behalf of that party or are affiliated with a law firm that has
11 appeared on behalf of that party, and includes support staff.
12 2.11 Party: any party to this Action, including all of its officers, directors,
13 employees, consultants, retained experts, and Outside Counsel of Record (and their
14 support staffs).
15 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
16 Discovery Material in this Action.
17 2.13 Professional Vendors: persons or entities that provide litigation support
18 services (e.g., photocopying, videotaping, translating, preparing exhibits or
19 demonstrations, and organizing, storing, or retrieving data in any form or medium) and
20 their employees and subcontractors.
21 2.14 Protected Material: any Disclosure or Discovery Material that is
22 designated as “CONFIDENTIAL.”
23 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material
24 from a Producing Party.
25 3. SCOPE
26 The protections conferred by this Stipulation and Order cover not only Protected
27 Material (as defined above), but also (1) any information copied or extracted from
1 Material not admitted at trial; and (3) any testimony, conversations, or presentations by
2 Parties or their Counsel that might reveal Protected Material.
3 Any use of Protected Material at trial shall be governed by the orders of the trial
4 judge. This Order does not govern the use of Protected Material at trial.
5 4. DURATION
6 Once a case proceeds to trial, information that was designated as
7 CONFIDENTIAL or maintained pursuant to this protective order used or introduced as
8 an exhibit at trial becomes public and will be presumptively available to all members of
9 the public, including the press, unless compelling reasons supported by specific factual
10 findings to proceed otherwise are made to the trial judge in advance of the trial. See
11 Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” showing for sealing
12 documents produced in discovery from “compelling reasons” standard when merits-
13 related documents are part of court record). Accordingly, the terms of this protective
14 order do not extend beyond the commencement of the trial.
15 After final disposition of this litigation, the confidentiality obligations imposed
16 by this Stipulated Protective Order shall remain in effect for items not entered into
17 evidence at trial and the Parties shall comply with Section 13 of this Order.
18 5. DESIGNATING PROTECTED MATERIAL
19 5.1 Exercise of Restraint and Care in Designating Material for Protection.
20 Each Party or Non-Party that designates information or items for protection under this
21 Order must take care to limit any such designation to specific material that qualifies
22 under the appropriate standards. The Designating Party must designate for protection
23 only those parts of material, documents, items or oral or written communications that
24 qualify so that other portions of the material, documents, items or communications for
25 which protection is not warranted are not swept unjustifiably within the ambit of this
26 Order.
27 Mass, indiscriminate or routinized designations are prohibited. Designations that
1 (e.g., to unnecessarily encumber the case development process or to impose
2 unnecessary expenses and burdens on other parties) may expose the Designating Party
3 to sanctions.
4 If it comes to a Designating Party’s attention that information or items that it
5 designated for protection do not qualify for protection, that Designating Party must
6 promptly notify all other Parties that it is withdrawing the inapplicable designation.
7 5.2 Manner and Timing of Designations. Except as otherwise provided in this
8 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or
9 ordered, Disclosure or Discovery Material that qualifies for protection under this Order
10 must be clearly so designated before the material is disclosed or produced.
11 Designation in conformity with this Order requires:
12 (a) for information in documentary form (e.g., paper or electronic documents,
13 but excluding transcripts of depositions or other pretrial or trial proceedings), that the
14 Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter
15 “CONFIDENTIAL legend”), to each page that contains protected material. If only a
16 portion of the material on a page qualifies for protection, the Producing Party also must
17 clearly identify the protected portion(s) (e.g., by making appropriate markings in the
18 margins).
19 A Party or Non-Party that makes original documents available for inspection
20 need not designate them for protection until after the inspecting Party has indicated
21 which documents it would like copied and produced. During the inspection and before
22 the designation, all of the material made available for inspection shall be deemed
23 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants
24 copied and produced, the Producing Party must determine which documents, or portions
25 thereof, qualify for protection under this Order. Then, before producing the specified
26 documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page
27 that contains Protected Material. If only a portion of the material on a page qualifies for
1 by making appropriate markings in the margins).
2 (b) for testimony given in depositions that the Designating Party identifies the
3 Disclosure or Discovery Material on the record, before the close of the deposition all
4 protected testimony.
5 (c) for information produced in some form other than documentary and for
6 any other tangible items, that the Producing Party affix in a prominent place on the
7 exterior of the container or containers in which the information is stored the legend
8 “CONFIDENTIAL.” If only a portion or portions of the information warrants
9 protection, the Producing Party, to the extent practicable, shall identify the protected
10 portion(s).
11 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
12 failure to designate qualified information or items does not, standing alone, waive the
13 Designating Party’s right to secure protection under this Order for such material. Upon
14 timely correction of a designation, the Receiving Party must make reasonable efforts to
15 assure that the material is treated in accordance with the provisions of this Order.
16 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
17 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
18 designation of confidentiality at any time that is consistent with the Court’s Scheduling
19 Order.
20 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
21 resolution process under Local Rule 37.1 et seq.
22 6.3 The burden of persuasion in any such challenge proceeding shall be on the
23 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g.,
24 to harass or impose unnecessary expenses and burdens on other parties) may expose the
25 Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn
26 the confidentiality designation, all parties shall continue to afford the material in
27 question the level of protection to which it is entitled under the Producing Party’s
1 7. ACCESS TO AND USE OF PROTECTED MATERIAL
2 7.1 Basic Principles. A Receiving Party may use Protected Material that is
3 disclosed or produced by another Party or by a Non-Party in connection with this
4 Action only for prosecuting, defending or attempting to settle this Action. Such
5 Protected Material may be disclosed only to the categories of persons and under the
6 conditions described in this Order. When the Action has been terminated, a Receiving
7 Party must comply with the provisions of section 13 below (FINAL DISPOSITION).
8 Protected Material must be stored and maintained by a Receiving Party at a
9 location and in a secure manner that ensures that access is limited to the persons
10 authorized under this Order.
11 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise
12 ordered by the court or permitted in writing by the Designating Party, a Receiving Party
13 may disclose any information or item designated “CONFIDENTIAL” only to:
14 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as
15 employees of said Outside Counsel of Record to whom it is reasonably necessary to
16 disclose the information for this Action;
17 (b) the officers, directors, and employees (including House Counsel) of the
18 Receiving Party to whom disclosure is reasonably necessary for this Action;
19 (c) Experts (as defined in this Order) of the Receiving Party to whom
20 disclosure is reasonably necessary for this Action and who have signed the
21 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
22 (d) the court and its personnel;
23 (e) court reporters and their staff;
24 (f) professional jury or trial consultants, mock jurors, and Professional
25 Vendors to whom disclosure is reasonably necessary for this Action and who have
26 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
27 (g) the author or recipient of a document containing the information or a
1 (h) during their depositions, witnesses, and attorneys for witnesses, in the
2 Action to whom disclosure is reasonably necessary provided: (1) the deposing party
3 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will
4 not be permitted to keep any confidential information unless they sign the
5 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed
6 by the Designating Party or ordered by the court. Pages of transcribed deposition
7 testimony or exhibits to depositions that reveal Protected Material may be separately
8 bound by the court reporter and may not be disclosed to anyone except as permitted
9 under this Stipulated Protective Order; and
10 (i) any mediator or settlement officer, and their supporting personnel,
11 mutually agreed upon by any of the parties engaged in settlement discussions.
12 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN
13 OTHER LITIGATION
14 If a Party is served with a subpoena or a court order issued in other litigation that
15 compels disclosure of any information or items designated in this Action as
16 “CONFIDENTIAL,” that Party must:
17 (a) promptly notify in writing the Designating Party. Such notification shall
18 include a copy of the subpoena or court order;
19 (b) promptly notify in writing the party who caused the subpoena or order to
20 issue in the other litigation that some or all of the material covered by the subpoena or
21 order is subject to this Protective Order. Such notification shall include a copy of this
22 Stipulated Protective Order; and
23 (c) cooperate with respect to all reasonable procedures sought to be pursued
24 by the Designating Party whose Protected Material may be affected.
25 If the Designating Party timely seeks a protective order, the Party served with the
26 subpoena or court order shall not produce any information designated in this action as
27 “CONFIDENTIAL” before a determination by the court from which the subpoena or
1 Designating Party shall bear the burden and expense of seeking protection in that court
2 of its confidential material and nothing in these provisions should be construed as
3 authorizing or encouraging a Receiving Party in this Action to disobey a lawful
4 directive from another court.
5 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED
6 IN THIS LITIGATION
7 (a) The terms of this Order are applicable to information produced by a Non-
8 Party in this Action and designated as “CONFIDENTIAL.” Such information produced
9 by Non-Parties in connection with this litigation is protected by the remedies and relief
10 provided by this Order. Nothing in these provisions should be construed as prohibiting
11 a Non-Party from seeking additional protections.
12 (b) In the event that a Party is required, by a valid discovery request, to
13 produce a Non-Party’s confidential information in its possession, and the Party is
14 subject to an agreement with the Non-Party not to produce the Non-Party’s confidential
15 information, then the Party shall:
16 (1) promptly notify in writing the Requesting Party and the Non-Party that
17 some or all of the information requested is subject to a confidentiality agreement with a
18 Non-Party;
19 (2) promptly provide the Non-Party with a copy of the Stipulated
20 Protective Order in this Action, the relevant discovery request(s), and a reasonably
21 specific description of the information requested; and
22 (3) make the information requested available for inspection by the Non-
23 Party, if requested.
24 (c) If the Non-Party fails to seek a protective order from this court within 14
25 days of receiving the notice and accompanying information, the Receiving Party may
26 produce the Non-Party’s confidential information responsive to the discovery request.
27 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce
1 agreement with the Non-Party before a determination by the court. Absent a court order
2 to the contrary, the Non-Party shall bear the burden and expense of seeking protection
3 in this court of its Protected Material.
4 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
5 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
6 Protected Material to any person or in any circumstance not authorized under this
7 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing
8 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve
9 all unauthorized copies of the Protected Material, (c) inform the person or persons to
10 whom unauthorized disclosures were made of all the terms of this Order, and (d)
11 request such person or persons to execute the “Acknowledgment and Agreement to Be
12 Bound” that is attached hereto as Exhibit A.
13 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
14 PROTECTED MATERIAL
15 When a Producing Party gives notice to Receiving Parties that certain
16 inadvertently produced material is subject to a claim of privilege or other protection, the
17 obligations of the Receiving Parties are those set forth in Federal Rule of Civil
18 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
19 may be established in an e-discovery order that provides for production without prior
20 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
21 parties reach an agreement on the effect of disclosure of a communication or
22 information covered by the attorney-client privilege or work product protection, the
23 parties may incorporate their agreement in the stipulated protective order submitted to
24 the court.
25 12. MISCELLANEOUS
26 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
27 person to seek its modification by the Court in the future.
1 12.2 Right to Assert Other Objections. By stipulating to the entry of this
2 Protective Order, no Party waives any right it otherwise would have to object to
3 disclosing or producing any information or item on any ground not addressed in this
4 Stipulated Protective Order. Similarly, no Party waives any right to object on any
5 ground to use in evidence of any of the material covered by this Protective Order.
6 12.3 Filing Protected Material. A Party that seeks to file under seal any
7 Protected Material must comply with Local Civil Rule 79-5. Protected Material may
8 only be filed under seal pursuant to a court order authorizing the sealing of the specific
9 Protected Material at issue. If a Party’s request to file Protected Material under seal is
10 denied by the court, then the Receiving Party may file the information in the public
11 record unless otherwise instructed by the court.
12 13. FINAL DISPOSITION
13 After the final disposition of this Action, as defined in paragraph 4, within 60
14 days of a written request by the Designating Party, each Receiving Party must return all
15 Protected Material to the Producing Party or destroy such material. As used in this
16 subdivision, “all Protected Material” includes all copies, abstracts, compilations,
17 summaries, and any other format reproducing or capturing any of the Protected
18 Material. Whether the Protected Material is returned or destroyed, the Receiving Party
19 must submit a written certification to the Producing Party (and, if not the same person
20 or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by
21 category, where appropriate) all the Protected Material that was returned or destroyed
22 and (2) affirms that the Receiving Party has not retained any copies, abstracts,
23 compilations, summaries or any other format reproducing or capturing any of the
24 Protected Material. Notwithstanding this provision, Counsel are entitled to retain an
25 archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts,
26 legal memoranda, correspondence, deposition and trial exhibits, expert reports, attorney
27 work product, and consultant and expert work product, even if such materials contain
1 || Material remain subject to this Protective Order as set forth in Section 4 (DURATION).
2 VIOLATION
3 || Any violation of this Order may be punished by appropriate measures including,
4 || without limitation, contempt proceedings and/or monetary sanctions.
5
6 |} IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
7
8 Dated: March 11, 2026 LAW OFFICE OF GREGORY PEACOCK
9 By: __/s/ Gregory Peacock
Gregory Peacock, Esq.
10 Attorney for Plaintiff, Nehemiah Davidson
11
12 |! Dated: March 11, 2026 HYDEE FELDSTEIN SOTO, City Attorney
13 DENISE C. MILLS, Chief Deputy City Attorney
KATHLEEN KENEALY, Chief Assistant City Attorne
14 CHRISTIAN R. BOJORQUEZ, Deputy City Attorney
15
16 Cf. Ce OY
By: /s/ Rebowu C. Hunter
17 REBECCA E. HUNTER, Deputy City Attorney
18 Attorneys for Defendants, CITY OF LOS ANGELES,
JAMES SPELLMAN, PIERRE OLEGA, and
19 SERGEANT CRUZ
20
21 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
22
93 || DATED:__ 3/12/2026
24 .
25 Rayel Oy, OC
HON.SROZELLA A. OLIVER
26 || United States Magistrate Judge
27
28
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 that I have read in its
6 entirety and understand the Stipulated Protective Order that was issued by the United
7 States District Court for the Central District of California on [date] in the case of
8 ___________ Nehemiah Davidson v. City of Los Angeles, et al. 2:25-cv-07865-ODW-
9 RAOx. I agree to comply with and to be bound by all the terms of this Stipulated
10 Protective Order and I understand and acknowledge that failure to so comply could
11 expose me to sanctions and punishment in the nature of contempt. I solemnly promise
12 that I will not disclose in any manner any information or item that is subject to this
13 Stipulated Protective Order to any person or entity except in strict compliance with the
14 provisions of this Order.
15 I further agree to submit to the jurisdiction of the United States District Court for the
16 Central District of California for enforcing the terms of this Stipulated Protective Order,
17 even if such enforcement proceedings occur after termination of this action. I hereby
18 appoint __________________________ [print or type full name] of
19 _______________________________________ [print or type full address and
20 telephone number] as my California agent for service of process in connection with this
21 action or any proceedings related to enforcement of this Stipulated Protective Order.
22 Date: ______________________________________
23 City and State where sworn and signed: _________________________________
24
25 Printed name: _______________________________
26
27 Signature: __________________________________