Opinion

Court: District Court, C.D. California
Filed: Jun 18, 2026
Cited by: 0 cases
Authority: More cited than 41.6%

The opinion

HYDEE FELDSTEIN SOTO, City Attorney

2 DENISE C. MILLS, Chief Deputy City Attorney

KATHLEEN KENEALY, Chief Assistant City Attorney

CHRISTIAN R. BOJORQUEZ, Deputy City Attorney

4 ERIN CHOI, Deputy City Attorney (SBN 342323)

200 North Main Street, 6th Floor, City Hall East

Los Angeles, CA 90012

6 Tel.: (213) 202-5429 | Fax: (213) 978-8785

7 E-mail: erin.choi@lacity.org

Attorneys for Defendants

9 CITY OF LOS ANGELES, OFFICER JORDAN T. PATTON, and

OFFICER LUIS A. MEDINA

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

14 EMMITT BRYANT

Case No. 2:25−cv−07237−SSC

15 Plaintiff(s),

16 STIPULATED PROTECTIVE

17 CITY OF LOS ANGELES; ORDER

OFFICER JORDAN T. PATTON

18 (#40574); OFFICER LUIS A. HONORABLE STEPHANIE S.

19 MEDINA (#44066); and DOES 1 CHRISTENSEN

THROUGH 10, inclusive United States Magistrate Judge

Defendant(s).

1. INTRODUCTION

1.1 Purposes and Limitations. Discovery in this action is likely to

involve production of confidential, proprietary, or private information for

27 which special protection from public disclosure and from use for any

1 Accordingly, the parties hereby stipulate to and petition the court to

2 enter the following Stipulated Protective Order. The parties

3 acknowledge that this Order does not confer blanket protections on all

4 disclosures or responses to discovery and that the protection it affords

5 from public disclosure and use extends only to the limited information or

6 items that are entitled to confidential treatment under the applicable

7 legal principles.

1.2 Good Cause Statement.

In light of the nature of the claims and allegations in this case and

the parties’ representations that discovery in this case may involve the

production of confidential records, and including but not limited to

employment/personnel records, information of individually named

Defendants and/or other employees of the City, information otherwise

generally unavailable to the public, or which may be privileged or

otherwise protected from disclosure under state or federal statutes, court

rules, case decisions, or common law.

Defendants maintain as confidential such as personnel files of the

peace officer(s) involved in this incident, Internal Affairs materials and

information, video recordings, audio recordings, photographs, and

information and other administrative materials and information

22 currently in the possession of Defendant City of Los Angeles (“City”), and

23 Defendants believe need special protection from public disclosure and

24 from use for any purpose other than pursuing this litigation. To the

25 extent personnel files of peace officers involved in the subject incident

26 are sought in discovery, personnel files are maintained as strictly

27 confidential and need special protection from public disclosure and from

1 The confidentiality of the materials and information is recognized

2 by California and federal law, as evidenced inter alia by California Penal

3 Code §§ 832.5, 832.7, and 832.8; Kerr v. U.S. Dist. Ct. for N.D. Cal., 511

4 F.2d 192, 198 (9th Cir. 1975); California Evidence Code §§ 1040 and 1043

5 et. seq; the Privacy Act of 1974, 5 U.S.C. § 552; the right to privacy;

6 decisional law relating to such provisions; official information privilege;

7 state or federal statutes, court rules, case decisions, or common law.

Further, discovery may require depositions, written discovery

and/or the production of certain information the public disclosure of

which could compromise officer safety, and/or raise security issues.

Additionally, public disclosure of such information poses a substantial

risk of embarrassment, oppression, and/or physical harm to peace

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

peace officers is greater than the risk of harm to other government

employees, due to the nature of their profession. The benefit of public

disclosure of confidential information is minimal while the potential

disadvantages are great. Defendants also contend that the unfettered

disclosure of the materials and information, absent a Protective Order,

would allow the media to share this information with potential jurors in

the area, impacting the rights of Defendants herein to receive a fair trial.

22 To expedite the flow of information, facilitate the prompt resolution

23 of disputes over confidentiality of discovery materials, adequately protect

24 information the parties are entitled to keep confidential, ensure that the

25 parties are permitted reasonable and necessary uses of such material in

26 connection with this action, address their handling of such material at

27 the end of the litigation, and serve the ends of justice, a Protective Order

1 designate any information/documents as confidential without a good

2 faith belief that such information/documents have been maintained in a

3 confidential, non-public manner, and that there is good cause or a

4 compelling reason why it should not be part of the public record of this

5 case.

6 1.3 Acknowledgment of Procedure for Filing Under Seal. The

7 parties further acknowledge, as set forth in Section 12.3, below, that this

Stipulated Protective Order does not entitle them to file confidential

information under seal; Local Rule 79-5 sets forth the procedures that

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

seeks permission from the court to file material under seal.

There is a strong presumption that the public has a right of access

to judicial proceedings and records in civil cases. In connection with

non-dispositive motions, good cause must be shown to support a filing

under seal. See Kamakana v. City and Cnty. of Honolulu, 447 F.3d

1172, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd v. Gen. Motors

Corp., 307 F.3d 1206, 1210–11 (9th Cir. 2002), Makar-Welbon v. Sony

Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated

protective orders require good cause showing), and a specific showing of

good cause or compelling reasons with proper evidentiary support and

22 legal justification, must be made with respect to Protected Material that

23 a party seeks to file under seal. The parties’ mere designation of

24 Disclosure or Discovery Material as CONFIDENTIAL does not—

25 without the submission of competent evidence by declaration,

26 establishing that the material sought to be filed under seal qualifies as

27 confidential, privileged, or otherwise protectable—constitute good cause.

1 or trial, then compelling reasons, not only good cause, for the sealing

2 must be shown, and the relief sought shall be narrowly tailored to serve

3 the specific interest to be protected. See Pintos v. Pac. Creditors Ass’n,

4 605 F.3d 665, 677–79 (9th Cir. 2010). For each item or type of

5 information, document, or thing sought to be filed or introduced under

6 seal in connection with a dispositive motion or trial, the party seeking

7 protection must articulate compelling reasons, supported by specific

facts and legal justification, for the requested sealing order. Again,

competent evidence supporting the application to file documents under

seal must be provided by declaration.

Any document that is not confidential, privileged, or otherwise

protectable in its entirety will not be filed under seal if the confidential

portions can be redacted. If documents can be redacted, then a redacted

version for public viewing, omitting only the confidential, privileged, or

otherwise protectable portions of the document, shall be filed. Any

application that seeks to file documents under seal in their entirety

should include an explanation of why redaction is not feasible.

2. DEFINITIONS

21 2.1 Action: Emmitt Bryant v. City of Los Angeles, et al., Case No.

22 2:25−cv−07237−SSC

23 2.2 Challenging Party: a Party or Non-Party that challenges the

24 designation of information or items under this Order.

25 2.3 “CONFIDENTIAL” Information or Items: information

26 (regardless of how it is generated, stored or maintained) or tangible

things that qualify for protection under Rule 26(c) of the Federal Rules of

1 Civil Procedure, and as specified above in the Good Cause Statement.

2 2.4 Counsel: Outside Counsel of Record and House Counsel (as

3 well as their support staff).

4 2.5 Designating Party: a Party or Non-Party that designates

5 information or items that it produces in disclosures or in responses to

6 discovery as “CONFIDENTIAL.”

7 2.6 Disclosure or Discovery Material: all items or information,

regardless of the medium or manner in which it is generated, stored, or

maintained (including, among other things, testimony, transcripts, and

tangible things), that are produced or generated in disclosures or

responses to discovery in this matter.

2.7 Expert: a person with specialized knowledge or experience in

a matter pertinent to the litigation who has been retained by a Party or

its counsel to serve as an expert witness or as a consultant in this Action.

2.8 Final Disposition: the later of (1) dismissal of all claims and

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

herein after the completion and exhaustion of all appeals, rehearings,

remands, trials, or reviews of this Action, including the time limits for

filing any motions or applications for extension of time pursuant to

applicable law.

22 2.9 In-House Counsel: attorneys who are employees of a party to

23 this Action. In-House Counsel does not include Outside Counsel of

24 Record or any other outside counsel.

25 2.10 Non-Party: any natural person, partnership, corporation,

26 association, or other legal entity not named as a Party to this action.

27 2.11 Outside Counsel of Record: attorneys who are not employees

1 this Action and have appeared in this Action on behalf of that party or

2 are affiliated with a law firm which has appeared on behalf of that party,

3 and includes support staff.

4 2.12 Party: any party to this Action, including all of its officers,

5 directors, employees, consultants, retained experts, and Outside Counsel

6 of Record (and their support staffs).

7 2.13 Producing Party: a Party or Non-Party that produces

Disclosure or Discovery Material in this Action.

2.14 Professional Vendors: persons or entities that provide

litigation- support services (e.g., photocopying, videotaping, translating,

preparing exhibits or demonstrations, and organizing, storing, or

retrieving data in any form or medium) and their employees and

subcontractors.

2.15 Protected Material: any Disclosure or Discovery Material that

is designated as “CONFIDENTIAL.”

2.16 Receiving Party: a Party that receives Disclosure or Discovery

Material from a Producing Party.

3. SCOPE

21 The protections conferred by this Stipulation and Order cover not

22 only Protected Material (as defined above), but also (1) any information

23 copied or extracted from Protected Material; (2) all copies, excerpts,

24 summaries, or compilations of Protected Material; and (3) any

25 testimony, conversations, or presentations by Parties or their Counsel

26 that might reveal Protected Material.

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

2 orders of the trial judge. This Stipulated Protective Order does not

3 govern the use of Protected Material at trial.

5 4. TRIAL AND DURATION

The terms of this Stipulated Protective Order apply through Final

Disposition of the Action.

Once a case proceeds to trial, information that was designated as

CONFIDENTIAL or maintained pursuant to this Stipulated Protective

Order and used or introduced as an exhibit at trial becomes public and

will be presumptively available to all members of the public, including

the press, unless compelling reasons supported by specific factual

14 findings to proceed otherwise are made to the trial judge in advance of

15 the trial. See Kamakana, 447 F.3d at 1180–81 (distinguishing “good

16 cause” showing for sealing documents produced in discovery from

17 “compelling reasons” standard when merits-related documents are part

18 of court record). Accordingly, for such materials, the terms of this

19 Stipulated Protective Order do not extend beyond the commencement of

20 the trial.

21 Even after Final Disposition of this litigation, the confidentiality

22 obligations imposed by this Stipulated Protective Order shall remain in

effect until a Designating Party agrees otherwise in writing or a court

order otherwise directs.

5. DESIGNATING PROTECTED MATERIAL

1 Protection. Each Party or Non-Party that designates information or

2 items for protection under this Order must take care to limit any such

3 designation to specific material that qualifies under the appropriate

4 standards. The Designating Party must designate for protection only

5 those parts of material, documents, items, or oral or written

6 communications that qualify so that other portions of the material,

7 documents, items, or communications for which protection is not

warranted are not swept unjustifiably within the ambit of this Order.

Mass, indiscriminate, or routinized designations are prohibited.

Designations that are shown to be clearly unjustified or that have been

made for an improper purpose (e.g., to unnecessarily encumber the case

development process or to impose unnecessary expenses and burdens on

other parties) may expose the Designating Party to sanctions.

If it comes to a Designating Party’s attention that information or

items that it designated for protection do not qualify for protection, that

Designating Party must promptly notify all other Parties that it is

withdrawing the inapplicable designation.

19 5.2 Manner and Timing of Designations. Except as otherwise

20 provided in this Stipulated Protective Order (see, e.g., second paragraph

21 of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure

22 or Discovery Material that qualifies for protection under this Stipulated

23 Protective Order must be clearly so designated before the material is

24 disclosed or produced.

25 Designation in conformity with this Stipulated Protective Order

26 requires:

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

1 documents, but excluding transcripts of depositions or other pretrial or

2 trial proceedings), that the Producing Party affix at a minimum, the

3 legend “CONFIDENTIAL” to each page that contains protected

4 material. If only a portion or portions of the material on a page

5 qualifies for protection, the Producing Party also must clearly identify

6 the protected portion(s) (e.g., by making appropriate markings in the

7 margins).

A Party or Non-Party that makes original documents available for

inspection need not designate them for protection until after the

inspecting Party has indicated which documents it would like copied

and produced. During the inspection and before the designation, all of

the material made available for inspection shall be deemed

CONFIDENTIAL. After the inspecting Party has identified the

documents it wants copied and produced, the Producing Party must

determine which documents, or portions thereof, qualify for protection

under this Stipulated Protective Order. Then, before producing the

specified documents, the Producing Party must affix the

“CONFIDENTIAL” legend to each page that contains Protected

Material. If only a portion or portions of the material on a page

qualifies for protection, the Producing Party also must clearly identify

22 the protected portion(s) (e.g., by making appropriate markings in the

23 margins).

24 (b) for testimony given in depositions that the Designating Party

25 identify the Disclosure or Discovery Material on the record, before the

26 close of the deposition all protected testimony.

27 (c) for information produced in some form other than

1 affix in a prominent place on the exterior of the container or containers

2 in which the information is stored the “CONFIDENTIAL” legend. If only

3 a portion or portions of the information warrants protection, the

4 Producing Party, to the extent practicable, shall identify the protected

5 portion(s).

5.3 Inadvertent Failures to Designate. If timely corrected, an

inadvertent failure to designate qualified information or items does not,

standing alone, waive the Designating Party’s right to secure protection

under this Order for such material. Upon timely correction of a

designation, the Receiving Party must make reasonable efforts to assure

that the material is treated in accordance with the provisions of this

Stipulated Protective Order.

6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

16 6.1 Timing of Challenges. Any Party or Non-Party may

17 challenge a designation of confidentiality at any time that is consistent

18 with the court’s Scheduling Order.

19 6.2 Meet and Confer. The Challenging Party shall initiate the

20 dispute resolution process under Local Rule 37.1 et seq. and with

21 Section 2 of Judge Christensen’s Civil Procedures titled “Brief Pre-

22 Discovery Motion Conference.”1

6.3 The burden of persuasion in any such challenge proceeding

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

made for an improper purpose (e.g., to harass or impose unnecessary

1 Judge Christensen’s Procedures are available at

1 expenses and burdens on other parties) may expose the Challenging

2 Party to sanctions. Unless the Designating Party has waived or

3 withdrawn the confidentiality designation, all parties shall continue to

4 afford the material in question the level of protection to which it is

5 entitled under the Producing Party’s designation until the court rules on

6 the challenge.

7. ACCESS TO AND USE OF PROTECTED MATERIAL

7.1 Basic Principles. A Receiving Party may use Protected

Material that is disclosed or produced by another Party or by a Non-

Party in connection with this Action only for prosecuting, defending, or

attempting to settle this Action. Such Protected Material may be

disclosed only to the categories of persons and under the conditions

described in this Order. When the Action reaches a Final Disposition, a

Receiving Party must comply with the provisions of section 13 below.

17 Protected Material must be stored and maintained by a Receiving

18 Party at a location and in a secure manner that ensures that access is

19 limited to the persons authorized under this Stipulated Protective

20 Order.

21 7.2 Disclosure of “CONFIDENTIAL” Information or Items.

22 Unless otherwise ordered by the court or permitted in writing by the

23 Designating Party, a Receiving Party may disclose any information or

24 item designated “CONFIDENTIAL” only:

25 (a) to the Receiving Party’s Outside Counsel of Record in this

Action, as well as employees of said Outside Counsel of Record to whom

it is reasonably necessary to disclose the information for this Action;

1 (b) to the officers, directors, and employees (including House

2 Counsel) of the Receiving Party to whom disclosure is reasonably

3 necessary for this Action;

4 (c) to Experts (as defined in this Order) of the Receiving Party to

5 whom disclosure is reasonably necessary for this Action and who have

6 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);

7 (d) to the court and its personnel;

(e) to court reporters and their staff;

(f) to professional jury or trial consultants, mock jurors, and

Professional Vendors to whom disclosure is reasonably necessary for

this Action and who have signed the “Acknowledgment and Agreement

to Be Bound” (Exhibit A);

(g) to the author or recipient of a document containing the

information or a custodian or other person who otherwise possessed or

knew the information;

(h) during their depositions, to witnesses, and attorneys for

witnesses, in the Action to whom disclosure is reasonably necessary,

provided: (1) the deposing party requests that the witness sign the

“Acknowledgment and Agreement to Be Bound” (Exhibit A); and (2) the

witness will not be permitted to keep any confidential information

22 unless they sign the “Acknowledgment and Agreement to Be Bound”

23 (Exhibit A), unless otherwise agreed by the Designating Party or

24 ordered by the court. Pages of transcribed deposition testimony or

25 exhibits to depositions that reveal Protected Material may be separately

26 bound by the court reporter and may not be disclosed to anyone except

27 as permitted under this Stipulated Protective Order; and

1 personnel, mutually agreed upon by any of the parties engaged in

2 settlement discussions.

4 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED

5 PRODUCED IN OTHER LITIGATION

6 If a Party is served with a subpoena or a court order issued in

7 other litigation that compels disclosure of any information or items

designated in this Action as “CONFIDENTIAL,” that Party must:

(a) 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 issue in the other litigation that some or all of the

material covered by the subpoena or order is subject to this Protective

Order. Such notification shall include a copy of this Stipulated

Protective Order; and

18 be pursued by the Designating Party whose Protected Material may be

19 affected.

20 If the Designating Party timely seeks a protective order, the

21 Party served with the subpoena or court order shall not produce any

22 information designated in this action as “CONFIDENTIAL” before a

23 determination by the court from which the subpoena or order issued,

24 unless the Party has obtained the Designating Party’s permission. The

25 Designating Party shall bear the burden and expense of seeking

26 protection in that court of its confidential material and nothing in these

provisions should be construed as authorizing or encouraging a

1 Receiving Party in this Action to disobey a lawful directive from another

2 court.

4 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

5 PRODUCED IN THIS LITIGATION

6 9.1 Application. The terms of this Stipulated Protective Order

7 are applicable to information produced by a Non-Party in this Action and

designated as “CONFIDENTIAL.” Such information produced by Non-

Parties in connection with this litigation is protected by the remedies

and relief provided by this Order. Nothing in these provisions should be

construed as prohibiting a Non-Party from seeking additional

protections.

9.2 Notification. In the event that a Party is required, by a valid

discovery request, to produce a Non-Party’s confidential information in

its possession, and the Party is subject to an agreement with the Non-

Party not to produce the Non-Party’s confidential information, then the

Party shall:

(a) promptly notify in writing the Requesting Party and the

Non-Party that some or all of the information requested is subject to a

21 confidentiality agreement with a Non-Party;

22 (b) make the information requested available for inspection by

23 the Non-Party, if requested.

24 9.3 Conditions of Production. If the Non-Party fails to seek a

25 protective order from this court within 14 days of receiving the notice

26 and accompanying information, the Receiving Party may produce the

27 Non-Party’s confidential information responsive to the discovery request.

1 shall not produce any information in its possession or control that is

2 subject to the confidentiality agreement with the Non-Party before a

3 determination by the court. Absent a court order to the contrary, the

4 Non-Party shall bear the burden and expense of seeking protection in

5 this court of its Protected Material.

7 10. UNAUTHORIZED DISCLOSURE OF PROTECTED

MATERIAL

If a Receiving Party learns that, by inadvertence or otherwise, it

has disclosed Protected Material to any person or in any circumstance

not authorized under this Stipulated Protective Order, the Receiving

Party must immediately (a) notify in writing the Designating Party of

the unauthorized disclosures, (b) use its best efforts to retrieve all

unauthorized copies of the Protected Material, (c) inform the person or

persons to whom unauthorized disclosures were made of all the terms of

17 this Order, and (d) request such person or persons to execute the

18 “Acknowledgment and Agreement to Be Bound” (Exhibit A).

20 11. INADVERTENT PRODUCTION OF PRIVILEGED OR

21 OTHERWISE PROTECTED MATERIAL

When a Producing Party gives notice to Receiving Parties that

certain inadvertently produced material is subject to a claim of privilege

or other protection, the obligations of the Receiving Parties are those set

forth in Rule 26(b)(5)(B) of the Federal Rules of Civil Procedure. This

provision is not intended to modify whatever procedure may be

1 prior privilege review. Pursuant to Rules 502(d) and (e) of the Federal

2 Rules of Evidence, insofar as the parties reach an agreement on the

3 effect of disclosure of a communication or information covered by the

4 attorney-client privilege or work product protection, the parties may

5 incorporate their agreement in the stipulated protective order

6 submitted to the court.

12. MISCELLANEOUS

12.1 Right to Further Relief. Nothing in this Stipulated

Protective Order abridges the right of any person to seek its

modification by the court in the future.

12.2 Right to Assert Other Objections. By stipulating to the entry

of this Stipulated Protective Order no Party waives any right it

otherwise would have to object to disclosing or producing any

information or item on any ground not addressed in this Stipulated

17 Protective Order. Similarly, no Party waives any right to object on any

18 ground to use in evidence of any of the material covered by this

19 Stipulated Protective Order.

20 12.3 Filing Protected Material. A Party that seeks to file under

21 seal any Protected Material must comply with Local Rule 79-5.

22 Protected Material may only be filed under seal pursuant to a court

23 order authorizing the sealing of the specific Protected Material at issue.

24 If a Party's request to file Protected Material under seal is denied by the

25 court, then the Receiving Party may file the information in the public

record unless otherwise instructed by the court.

1 13. FINAL DISPOSITION

2 After the Final Disposition of this Action, as defined in Paragraph

3 2.8, within 60 days of a written request by the Designating Party, each

Receiving Party must return all Protected Material to the Producing

Party or destroy such material. As used in this subdivision, “all

Protected Material” includes all copies, abstracts, compilations,

summaries, and any other format reproducing or capturing any of the

Protected Material. Whether the Protected Material is returned or

destroyed, the Receiving Party must submit a written certification to

the Producing Party (and, if not the same person or entity, to the

Designating Party) by the 60 day deadline that (1) identifies (by

category, where appropriate) all the Protected Material that was

returned or destroyed and (2) affirms that the Receiving Party has not

retained any copies, abstracts, compilations, summaries or any other

format reproducing or capturing any of the Protected Material.

Notwithstanding this provision, Counsel is entitled to retain an archival

18 copy of all pleadings, motion papers, trial, deposition, and hearing

19 transcripts, legal memoranda, correspondence, deposition and trial

20 exhibits, expert reports, attorney work product, and consultant and

21 expert work product, even if such materials contain Protected Material.

22 Any such archival copies that contain or constitute Protected Material

23 remain subject to this Protective Order as set forth in Section 4.

1 || 14. VIOLATION

2 Any violation of this Stipulated Protective Order may be punished

3 || by any and all appropriate measures including, without limitation,

4 || contempt proceedings and/or monetary sanctions.

6 || IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

7 ll Dated: June 18,2026 PLC LAW GROUP, APC

/s/Lauren K.McRae

? PETER L. CARR, IV, ESQ.

10 NA’SHAUN L. NEAL, ESQ.

LAUREN K. MCRAE, ESQ.

2 Attorneys for Plaintiff, EMMITT BRYANT

14 Dated: June 18, 2026 HYDEE FELDSTEIN SOTO, City Attorney

DENISE C. MILLS, Chief Deputy City Attorney

15 KATHLEEN KENEALY, Chief Assistant City

16 CHRISTIAN R. BOJORQUEZ, Deputy City Attorne

17 /s/ Erin Choi

12 ERIN CHOI, Deputy City Attorney

19 Attorneys for Defendants, CITY OF LOS ANGELES

OFFICER JORDAN T. PATTON, and OFFICER

20 LUIS A. MEDINA

33 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

25 DATED: June 18, 2026

STEPHANIE S. CHRISTENSEN

7 United States Magistrate Judge

1 EXHIBIT A

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

I, ________________________ [print or type full name], of

_________________ [print or type full address], declare under

penalty of perjury that I have read in its entirety and understand the

Stipulated Protective Order that was issued by the United States

District Court for the Central District of California on [date] in the

case of Emmitt Bryant v. City of Los Angeles, et al., Case No.

2:25−cv−07237−SSC. I agree to comply with and to be bound by all the

terms of this Stipulated Protective Order and I understand and

acknowledge that failure to so comply could expose me to sanctions

and punishment in the nature of contempt. I solemnly promise that I

14 will not disclose in any manner any information or item that is subject

15 to this Stipulated Protective Order to any person or entity except in

16 strict compliance with the provisions of this Order.

17 I further agree to submit to the jurisdiction of the United States

18 District Court for the Central District of California for the purpose of

19 enforcing the terms of this Stipulated Protective Order, even if such

20 enforcement proceedings occur after termination of this action. I

21 hereby appoint ________________________ [print or type full name]

22 of _________ [print or type full address and telephone number] as

1 my California agent for service of process in connection with this action

2 or any proceedings related to enforcement of this Stipulated Protective

3 Order.

5 Date: ___________________________

6 City and State where sworn and

7 signed: ___________________________

Printed name: ___________________________

Signature: ___________________________

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.