Opinion

Opinion

Court
District Court, C.D. California
Filed
Apr 2, 2026
Cited by
0 cases
Authority
More cited than 41.4%

The opinion

1 | JONES MAYER

James R. Touchstone Esq., SBN 184584

2 pid jones mayer com

elen O. Kim., SBN 254560

3 ferkie Jones Con)

Thurgood M. Wynn, SBN 345199

4 uma jones-mayer.com

3777 North Harbor Boulevard

5 | Fullerton, CA 92835

Telephone: a 446-1400

6 | Facsimile: (714) 446-1448

7 | Attorneys for Defendant,

CITY OF REDLANDS, REDLANDS POLICE

8 | DEPARTMENT and JAMES RAGAN

9 UNITED STATES DISTRICT COURT

10 CENTRAL DISTRICT OF CALIFORNIA

1]

12 | ANTONIO MALDONADO, Case No. 5:25-CV-02169-SSS

(MAAx)

13 Plaintiff(s),

Honorable Sunshine Suzanne Sykes

14 V. Honorable Magistrate Maria A.

Audero

15 | CITY OF REDLANDS, REDLANDS

POLICE DEPARTMENT, and JAMES STIPULATED PROTECTIVE

16 | RAGAN, ORDER

17 Defendant(s). Complaint Filed: 08/19/25

18

19 1. PURPOSES AND LIMITATIONS

20 Discovery in this action is likely to involve production of confidential,

21 | proprietary, or private information for which special protection from public

22 | disclosure and from use for any purpose other than prosecuting this litigation may be

23 || warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter

94 | the following Stipulated Protective Order. The parties acknowledge that this

25 || Stipulated Protective Order does not confer blanket protections on all disclosures or

26 || responses to discovery and that the protection it affords from public disclosure and

27 || use extends only to the limited information or items that are entitled to confidential

28

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ES MAYER meee eee oes

1 | treatment under the applicable legal principles. The parties further acknowledge, as

2 | set forth in Section 13.3 below, that this Stipulated Protective Order does not entitle

3 | them to file confidential information under seal; Local Rule 79-5 sets forth the

4 | procedures that must be followed and the standards that will be applied when a party

5 || seeks permission from the Court to file material under seal.

6 2. GOOD CAUSE STATEMENT

7 This action 1s likely to involve discovery that is confidential and privileged

8 || for which special protection from public disclosure and from use for any purpose

9 | other than prosecution of this action may be warranted. Such confidential and

10 | proprietary materials and information consist of, among other things, information

11 | pertaining to the investigation from Redlands Police Department (RPD) of the

12 | underlying activities, as well as peace officer personnel file information and/or

13 | documents which the parties agree include (1) Personal data, including marital

14 | status, family members, educational and employment history, home addresses, or

15 | similar information; (2) Medical history; (3) Election of employee benefits; (4)

16 | Employee advancement, appraisal or discipline; and (5) Complaints, or

17 | investigations of complaints, if any, concerning an event or transaction in which a

18 | peace officer participated, or which a peace officer perceived, and pertaining to the

19 | manner in which the peace officer performed his or her duties.

20 Such confidential materials and information consist of, among other things,

21 | materials which may be entitled to privileges and/or protections under the

22 | following: United States Constitution, First Amendment; the California

23 | Constitution, Article I, Section 1; California Penal Code §§ 832.5, 832.7 and 832.8;

24 | California Evidence Code §§ 1040 and 1043 et. seq; the Privacy Act of 1974, 5

25 | U.S.C. § 552; Health Insurance Portability and Accountability Act of 1996

26 | (HIPPA); the right to privacy; decisional law relating to such provisions; and

27 | information otherwise generally unavailable to the public, or which may be

28 || privileged or otherwise protected from disclosure under state or federal statutes,

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1 | court rules, case decisions, or common law.

2 Defendants also contend that such confidential materials and information are

3 | entitled to the Official Information Privilege. Sanchez v. City of Santa Ana, 936

4 | F.2d 1027, 1033 (9th Cir. Cal.1990); see also Kerr v. United States Dist. Ct. for

5 | N.D. Cal., 511 F.2d 192, 198 (9th Cir. Cal. 1975). Aff'd, 426 U.S. 394, 96 S. Ct.

6 || 3229, 48 L.Ed.2d 725 (1976). The information otherwise may be generally

7 | unavailable to the public, or may be privileged or otherwise protected from

8 | disclosure under state or federal statutes, court rules, case decisions, or common

9 | law.

10 Further, discovery may require depositions, written discovery and/or the

11 | production of certain information the public disclosure of which could comprise

12 | officer safety, and/or raise security issues. Additionally, public disclosure of such

13 | information poses a substantial risk of embarrassment, oppression, and/or physical

14 | harm to peace officers whose confidential information is disclosed. The risk of

15 | harm to peace officers is greater than with other government employees due to the

16 | nature of their profession. The benefit of public disclosure of confidential

17 | information is minimal while the potential disadvantages are great.

18 Accordingly, to expedite the flow of information, to facilitate the prompt

19 | resolution of disputes over confidentiality of discovery materials, to adequately

20 | protect information the parties are entitled to keep confidential, to ensure that the

21 | parties are permitted reasonable necessary uses of such material in preparation for

22 | and in the conduct of trial, to address their handling at the end of the litigation, and

23 || serve the ends of justice, a protective order for such information is justified in this

24 | matter. It is the intent of the parties that information will not be designated as

25 | confidential for tactical reasons and that nothing be so designated without a good

26 | faith belief that it has been maintained in a confidential, non-public manner, and

27 | there is good cause why it should not be part of the public record of this case.

28 3. DEFINITIONS

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1 3.1. Action: Antonio Maldonado v City of Redlands, Redlands Police

2 | Department, and James Ragan.

3 3.2. Challenging Party: A Party or Nonparty that challenges the designation of

4 | information or items under this Stipulated Protective Order.

5 3.3. “CONFIDENTIAL” Information or Items: Information (regardless of how

6 || it is generated, stored or maintained) or tangible things that qualify for protection

7 | under Federal Rule of Civil Procedure 26(c), and as specified above in the Good

8 || Cause Statement.

9 3.4. Counsel: Outside Counsel of Record and In-House Counsel (as well as

10 | their support staff).

11 3.5. Designating Party: A Party or Nonparty that designates information or

12 | items that it produces in disclosures or in responses to discovery as

13 | “CONFIDENTIAL.”

14 3.6. Disclosure or Discovery Material: All items or information, regardless of

15 | the medium or manner in which it is generated, stored, or maintained (including,

16 | among other things, testimony, transcripts, and tangible things), that 1s produced or

17 | generated in disclosures or responses to discovery in this matter.

18 3.7. Expert: A person with specialized knowledge or experience in a matter

19 | pertinent to the litigation who has been retained by a Party or its counsel to serve as

20 | an expert witness or as a consultant in this Action.

21 3.8. In-House Counsel: Attorneys who are employees of a party to this Action.

22 | In-House Counsel does not include Outside Counsel of Record or any other outside

23 || counsel.

24 3.9. Nonparty: Any natural person, partnership, corporation, association, or

25 | other legal entity not named as a Party to this action.

26 3.10. Outside Counsel of Record: Attorneys who are not employees of a party

27 | to this Action but are retained to represent or advise a party to this Action and have

28 | appeared in this Action on behalf of that party or are affiliated with a law firm

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1 | which has appeared on behalf of that party, and includes support staff.

2 3.11. Party: Any party to this Action, including all of its officers, directors,

3 | employees, consultants, retained experts, In-House Counsel, and Outside Counsel

4 | of Record (and their support staffs).

5 3.12. Producing Party: A Party or Nonparty that produces Disclosure or

6 || Discovery Material in this Action.

7 3.13. Professional Vendors: Persons or entities that provide litigation support

8 || services (e.g., photocopying, videotaping, translating, preparing exhibits or

9 | demonstrations, and organizing, storing, or retrieving data in any form or medium)

10 | and their employees and subcontractors.

11 3.14. Protected Material: Any Disclosure or Discovery Material that is

12 | designated as “CONFIDENTIAL.”

13 3.15. Receiving Party: A Party that receives Disclosure or Discovery Material

14 | from a Producing Party.

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;

19 | and (3) any testimony, conversations, or presentations by Parties or their Counsel

20 | that might reveal Protected Material.

21 Any use of Protected Material at trial shall be governed by the orders of the

22 | trial judge. This Stipulated Protective Order does not govern the use of Protected

23 | Material at trial.

24 5. DURATION

25 Even after final disposition of this litigation, the confidentiality obligations

26 || imposed by this Stipulated Protective Order shall remain in effect until a

27 || Designating Party agrees otherwise in writing or a court order otherwise directs.

28 || Final disposition shall be deemed to be the later of (1) dismissal of all claims and

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1 || defenses in this Action, with or without prejudice; and (2) final judgment herein

2 | after the completion and exhaustion of all appeals, rehearings, remands, trials, or

3 || reviews of this Action, including the time limits for filing any motions or

4 | applications for extension of time pursuant to applicable law.

5 6. DESIGNATING PROTECTED MATERIAL

6 6.1. Exercise of Restraint and Care in Designating Material for Protection.

7 | Each Party or Nonparty that designates information or items for protection under

8 || this Stipulated Protective Order must take care to limit any such designation to

9 | specific material that qualifies under the appropriate standards. The Designating

10 | Party must designate for protection only those parts of material, documents, items,

11 | or oral or written communications that qualify so that other portions of the material,

12 | documents, items, or communications for which protection is not warranted are not

13 | swept unjustifiably within the ambit of this Stipulated Protective Order. Mass,

14 | indiscriminate, or routinized designations are prohibited. Designations that are

15 | shown to be clearly unjustified or that have been made for an improper purpose

16 | (e.g., to unnecessarily encumber the case development process or to impose

17 || unnecessary expenses and burdens on other parties) may expose the Designating

18 | Party to sanctions.

19 6.2. Manner and Timing of Designations. Except as otherwise provided in

20 | this Stipulated Protective Order (see, e.g., Section 6.2(a)), or as otherwise stipulated

21 | or ordered, Disclosure or Discovery Material that qualifies for protection under this

22 | Stipulated Protective Order must be clearly so designated before the material is

23 | disclosed or produced. Designation in conformity with this Stipulated Protective

24 | Order requires the following:

25 (a) For information in documentary form (e.g., paper or electronic

26 | documents, but excluding transcripts of depositions or other pretrial or trial

27 || proceedings), that the Producing Party affix at a minimum, the legend

28 | “CONFIDENTIAL” to each page that contains protected material. If only a portion

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1 | or portions of the material on a page qualifies for protection, the Producing Party

2 | also must clearly identify the protected portion(s) (e.g., by making appropriate

3 | markings in the margins). A Party or Nonparty that makes original documents

4 | available for inspection need not designate them for protection until after the

5 || inspecting Party has indicated which documents it would like copied and produced.

6 | During the inspection and before the designation, all of the material made available

7 | for inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has

8 || identified the documents it wants copied and produced, the Producing Party must

9 | determine which documents, or portions thereof, qualify for protection under this

10 | Stipulated Protective Order. Then, before producing the specified documents, the

11 | Producing Party must affix the legend “CONFIDENTIAL” to each page that

12 | contains Protected Material. If only a portion or portions of the material on a page

13 | qualifies for protection, the Producing Party also must clearly identify the protected

14 | portion(s) (e.g., by making appropriate markings in the margins).

15 (b) For testimony given in depositions, that the Designating Party

16 | identify the Disclosure or Discovery Material on the record, before the close of the

17 | deposition, all protected testimony.

18 (c) For information produced in nondocumentary form, and for any

19 | other tangible items, that the Producing Party affix in a prominent place on the

20 | exterior of the container or containers in which the information is stored the legend

21 | “CONFIDENTIAL.” If only a portion or portions of the information warrants

22 | protection, the Producing Party, to the extent practicable, shall identify the

23 | protected portion(s).

24 6.3. Inadvertent Failure to Designate. If timely corrected, an inadvertent

25 | failure to designate qualified information or items does not, standing alone, waive

26 || the Designating Party’s right to secure protection under this Stipulated Protective

27 | Order for such material. Upon timely correction of a designation, the Receiving

28 | Party must make reasonable efforts to assure that the material is treated in

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1 | accordance with the provisions of this Stipulated Protective Order.

2 7. CHALLENGING CONFIDENTIALITY DESIGNATIONS

3 7.1. Timing of Challenges. Any Party or Nonparty may challenge a

4 | designation of confidentiality at any time that is consistent with the Court’s

5 | Scheduling Order.

6 7.2. Meet and Confer. The Challenging Party shall initiate the dispute

7 | resolution process, which shall comply with Local Rule 37.1 et seq., and with

8 || Section 4 of Judge Audero’s Procedures (“Mandatory Telephonic Conference for

9 | Discovery Disputes’’).1

10 7.3. Burden of Persuasion. The burden of persuasion in any such challenge

11 | proceeding shall be on the Designating Party. Frivolous challenges, and those

12 | made for an improper purpose (e.g., to harass or impose unnecessary expenses and

13 | burdens on other parties) may expose the Challenging Party to sanctions. Unless

14 | the Designating Party has waived or withdrawn the confidentiality designation, all

15 | parties shall continue to afford the material in question the level of protection to

16 | which it is entitled under the Producing Party’s designation until the Court rules on

17 | the challenge.

18 8. ACCESS TO AND USE OF PROTECTED MATERIALS

19 8.1. Basic Principles. A Receiving Party may use Protected Material that is

20 | disclosed or produced by another Party or by a Nonparty in connection with this

21 | Action only for prosecuting, defending, or attempting to settle this Action. Such

22 | Protected Material may be disclosed only to the categories of persons and under the

23 || conditions described in this Stipulated Protective Order. When the Action reaches a

24 | final disposition, a Receiving Party must comply with the provisions of Section 14

25 | below. Protected Material must be stored and maintained by a Receiving Party at a

26 | location and in a secure manner that ensures that access is limited to the persons

27 || authorized under this Stipulated Protective Order.

28 8.2. Disclosure of “CONFIDENTIAL” Information or Items. Unless

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1 | otherwise ordered by the Court or permitted in writing by the Designating Party, a

2 | Receiving Party may disclose any information or item designated

3 | “CONFIDENTIAL” only to:

4 (a) The Receiving Party’s Outside Counsel of Record, as well as

5 | employees of said Outside Counsel of Record to whom it is reasonably necessary to

6 | disclose the information for this Action;

7 (b) The officers, directors, and employees (including In-House

8 | Counsel) of the Receiving Party to whom disclosure is reasonably necessary for this

9 | Action;

10 (c) Experts of the Receiving Party to whom disclosure is reasonably

11 | necessary for this Action and who have signed the “Acknowledgment and

12 | Agreement to Be Bound” (Exhibit A);

13 (d) The Court and its personnel;

14 (e) Court reporters and their staff;

15 (f) Professional jury or trial consultants, mock jurors, and Professional

16 | Vendors to whom disclosure is reasonably necessary or this Action and who have

17 | signed the “Acknowledgment and Agreement to be Bound” (Exhibit A);

18 (g) The author or recipient of a document containing the information

19 | or a custodian or other person who otherwise possessed or knew the information;

20 (h) During their depositions, witnesses, and attorneys for witnesses, in

21 | the Action to whom disclosure is reasonably necessary provided: (1) the deposing

22 || party requests that the witness sign the “Acknowledgment and Agreement to Be

23 | Bound” (Exhibit A); and (i1) the witness will not be permitted to keep any

24 | confidential information unless they sign the “Acknowledgment and Agreement to

25 | Be Bound,” unless otherwise agreed by the Designating Party or ordered by the

26 | Court. Pages of transcribed deposition testimony or exhibits to depositions that

27 | reveal Protected Material may be separately bound by the court reporter and may

28 | not be disclosed to anyone except as permitted under this Stipulated Protective

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1 | Order; and

2 (i) Any mediator or settlement officer, and their supporting personnel,

3 || mutually agreed upon by any of the parties engaged in settlement discussions.

4 9. PROTECTED MATERIAL SUBPOENAED OR ORDERED

5 PRODUCED IN OTHER LITIGATION

6 Ifa Party is served with a subpoena or a court order issued in other litigation

7 | that compels disclosure of any information or items designated in this Action as

8 | “CONFIDENTIAL,” that Party must:

9 (a) Promptly notify in writing the Designating Party. Such notification shall

10 | include a copy of the subpoena or court order;

11 (b) Promptly notify in writing the party who caused the subpoena or order to

12 | issue in the other litigation that some or all of the material covered by the subpoena

13 | or order is subject to this Stipulated Protective Order. Such notification shall

14 | include a copy of this Stipulated Protective Order; and

15 (c) Cooperate with respect to all reasonable procedures sought to be pursued

16 | by the Designating Party whose Protected Material may be affected.

17 If the Designating Party timely seeks a protective order, the Party served with

18 | the subpoena or court order shall not produce any information designated in this

19 | action as “CONFIDENTIAL” before a determination by the Court from which the

20 | subpoena or order issued, unless the Party has obtained the Designating Party’s

21 | permission. The Designating Party shall bear the burden and expense of seeking

22 | protection in that court of its confidential material and nothing in these provisions

23 || should be construed as authorizing or encouraging a Receiving Party in this Action

24 || to disobey a lawful directive from another court.

25 10.A NONPARTY’S PROTECTED MATERIAL SOUGHT TO BE

26 PRODUCED IN THIS LITIGATION

27 10.1. Application. The terms of this Stipulated Protective Order are

28 || applicable to information produced by a Nonparty in this Action and designated as

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1 | “CONFIDENTIAL.” Such information produced by Nonparties in connection with

2 | this litigation is protected by the remedies and relief provided by this Stipulated

3 | Protective Order. Nothing in these provisions should be construed as prohibiting a

4 | Nonparty from seeking additional protections.

5 10.2. Notification. In the event that a Party is required, by a valid discovery

6 || request, to produce a Nonparty’s confidential information in its possession, and the

7 | Party is subject to an agreement with the Nonparty not to produce the Nonparty’s

8 | confidential information, then the Party shall:

9 (a) Promptly notify in writing the Requesting Party and the Nonparty

10 | that some or all of the information requested is subject to a confidentiality

11 | agreement with a Nonparty;

12 (b) Promptly provide the Nonparty with a copy of the Stipulated

13 | Protective Order in this Action, the relevant discovery request(s), and a reasonably

14 | specific description of the information requested; and

15 (c) Make the information requested available for inspection by the

16 | Nonparty, if requested. 10.3. Conditions of Production. If the Nonparty fails to seek

17 | a protective order from this Court within fourteen (14) days after receiving the

18 | notice and accompanying information, the Receiving Party may produce the

19 | Nonparty’s confidential information responsive to the discovery request. If the

20 | Nonparty timely seeks a protective order, the Receiving Party shall not produce any

21 | information in its possession or control that is subject to the confidentiality

22 | agreement with the Nonparty before a determination by the Court. Absent a court

23 | order to the contrary, the Nonparty shall bear the burden and expense of seeking

24 || protection in this Court of its Protected Material.

25 11, UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

26 Ifa Receiving Party learns that, by inadvertence or otherwise, it has disclosed

27 || Protected Material to any person or in any circumstance not authorized under this

28 || Stipulated Protective Order, the Receiving Party immediately must (1) notify in

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a ________

1 | writing the Designating Party of the unauthorized disclosures, (2) use its best

2 | efforts to retrieve all unauthorized copies of the Protected Material, (3) inform the

3 | person or persons to whom unauthorized disclosures were made of all the terms of

4 | this Stipulated Protective Order, and (4) request such person or persons to execute

5 || the “Acknowledgment and Agreement to be Bound” (Exhibit A).

6 12. 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

10 | protection, the obligations of the Receiving Parties are those set forth in Federal

11 | Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify

12 | whatever procedure may be established in an e-discovery order that provides for

13 | production without prior privilege review. Pursuant to Federal Rule of Evidence

14 | 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure

15 || of a communication or information covered by the attorney-client privilege or work

16 | product protection, the parties may incorporate their agreement in the Stipulated

17 || Protective Order submitted to the Court.

18 13.MISCELLANEOUS

19 13.1. Right to Further Relief. Nothing in this Stipulated Protective Order

20 || abridges the right of any person to seek its modification by the Court in the future.

21 13.2. Right to Assert Other Objections. By stipulating to the entry of this

22 || Stipulated Protective Order, no Party waives any right it otherwise would have to

23 | object to disclosing or producing any information or item on any ground not

24 || addressed in this Stipulated Protective Order. Similarly, no Party waives any right

25 | to object on any ground to use in evidence of any of the material covered by this

26 || Stipulated Protective Order.

27 13.3. Filing Protected Material. A Party that seeks to file under seal any

28 || Protected Material must comply with Local Rule 79-5. Protected Material may

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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 14.FINAL DISPOSITION

6 After the final disposition of this Action, within sixty (60) days of a written

7 | request by the Designating Party, each Receiving Party must return all Protected

8 || 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

11 | Material. Whether the Protected Material is returned or destroyed, the Receiving

12 | Party must submit a written certification to the Producing Party (and, if not the

13 | same person or entity, to the Designating Party) by the 60-day deadline that (1)

14 | identifies (by category, where appropriate) all the Protected Material that was

15 | returned or destroyed and (2) affirms that the Receiving Party has not retained any

16 | copies, abstracts, compilations, summaries or any other format reproducing or

17 | capturing any of the Protected Material. Notwithstanding this provision, Counsel is

18 | entitled to retain an archival copy of all pleadings; motion papers; trial, deposition,

19 | and hearing transcripts; legal memoranda; correspondence; deposition and trial

20 | exhibits; expert reports; attorney work product; and consultant and expert work

21 || product, even if such materials contain Protected Material. Any such archival

22 | copies that contain or constitute Protected Material remain subject to this Stipulated

23 || Protective Order as set forth in Section 5.

24 15. VIOLATION

25 Any violation of this Stipulated Order may be punished by any and all

26 || appropriate measures including, without limitation, contempt proceedings and/or

27 || monetary sanctions.

28

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a _______

1 | ITISSO STIPULATED, THROUGH COUNSEL OF RECORD.

2

3 | Dated: March 31, 2026 S/ Andrew Schrader

4 Thomas A. Schultz

Andrew Schrader

5 Attorneys for Plaintiff, Antonio

6 Maldonado

7

g Dated: March 31, 2026 s/ Helen O. Kim

James R. Touchstone

9 Helen O. Kim

10 Thurgood M. Wynn

Attorneys for Defendants, City of

1] Redlands, Redlands Police, and James

12 Ragan

1

3 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

14

. 1 J 4

15 | Dated: April 2, 2026 4 ‘

16 Hon Oi Hh aria A. Audero

United. States Magistrate Judge

17

18

19

20

21

22

23

24

25

26

27

28

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ES MAYER meee eee oes

1

2 EXHIBIT A

3 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

4

si [print or type full name], of

6 [print or type full address], declare under penalty of perjury

7 | that I have read in its entirety and understand the Protective Order that was issued

8 || by the United States District Court for the Central District of California on

9 in the case of

10 . I agree to comply with and to be

11 | bound by all the terms of this Protective Order and I understand and acknowledge

12 | that failure to so comply could expose me to sanctions and punishment in the nature

13 | of contempt. I solemnly promise that I will not disclose in any manner any

14 | information or item that is subject to this Protective Order to any person or entity

15 | except in strict compliance with the provisions of this Order.

16 I further agree to submit to the jurisdiction of the United States District Court

17 | for the Central District of California for the purpose of enforcing the terms of this

18 | Protective Order, even if such enforcement proceedings occur after termination of

19 | this action. I hereby appoint [print or type full

20 | name] of [print or type full address

21 | and telephone number] as my California agent for service of process in connection

22 | with this action or any proceedings related to enforcement of this Protective Order.

23 | Date:

24 | City and State where sworn and signed:

25

26 | Printed name:

27 || Signature:

28

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