The opinion
1 || Mildred K. O’Linn (State Bar No. 159055)
5 Missy.OLinn@manningkass.com
Hyelim Cho (State Bar No. 337498)
|| Hyvelim.Cho@manningkass.com
MANNING & KASS
4 ELLROD, RAMIREZ, TRESTER LLP
5 || 801 S. Figueroa St, 15th Floor,
Los Angeles, California 90017-3012
6 Telephone: (213) 624-6900
7 || Facsimile: (213) 624-6999
8 || Attorneys for Defendants, CITY OF
REDONDO BEACH and OFFICER
9 | WARREN
10 UNITED STATES DISTRICT COURT
Ul CENTRAL DISTRICT OF CALIFORNIA
22
fe
||MATTHEW RALSTON, Case No. 2:26-cv—02097-FLA-RAO
Plaintiffs,
15 STIPULATED PROTECTIVE
v. ORDER
16
7 CITY OF REDONDO BEACH,
OFFICER WARREN, AND DOE
18 |! OFFICERS 1-10.
19 Defendants.
20
21
22
23 || 1. A. PURPOSES AND LIMITATIONS
24 Discovery in this action is likely to involve production of confidential,
25 || proprietary, or private information for which special protection from public disclosure
26 || and from use for any purpose other than prosecuting this litigation may be warranted.
27 || Accordingly, the parties hereby stipulate to and petition the Court to enter the
28 || following Stipulated Protective Order. The parties acknowledge that this Order does
1 confer blanket protections on all disclosures or responses to discovery and that
2 ||the protection it affords from public disclosure and use extends only to the limited
3 || information or items that are entitled to confidential treatment under the applicable
4 || legal principles. The parties further acknowledge, as set forth in Section 12.3, below,
5||that this Stipulated Protective Order does not entitle them to file confidential
6 || information under seal; Civil Local Rule 79-5 sets forth the procedures that must be
7 || followed and the standards that will be applied when a party seeks permission from
8 || the court to file material under seal.
9
10 B. GOOD CAUSE STATEMENT
11 This action is likely to involve medical records, sensitive and confidential
12 ||}documents related to police reporting and practices, documents containing private
13 || information from third parties, police investigation procedures and tactics, and other
14||confidential and private information for which special protection from public
| 15]|disclosure and from use for any purpose other than prosecution of this action is
2 16 || warranted. Such confidential and proprietary materials and information consist of,
3 17 || among other things, confidential personal information of non-parties, private medical
18 || and autopsy records, internal police reviews and procedures, and other confidential
19 || and sensitive information otherwise generally unavailable to the public, or which may
20 || be privileged or otherwise protected from disclosure under state or federal statutes,
21 |)court rules, case decisions, or common law. Defendants contend that there is good
22 || cause for a protective order to maintain the confidentiality of peace officer personnel
23 || records. They emphasize that releasing these records, which include internal analyses
24 || and legal communications, could hinder law enforcement investigations.
25 Accordingly, to expedite the flow of information, to facilitate the prompt
26 ||resolution of disputes over confidentiality of discovery materials, to adequately
27 protect information the parties are entitled to keep confidential, to ensure that the
28 || parties are permitted reasonable necessary uses of such material in preparation for and
1 || in the conduct of trial, to address their handling at the end of the litigation, and serve
2 ||the ends of justice, a protective order for such information is justified in this matter.
3 || It is the intent of the parties that information will not be designated as confidential for
4 || tactical reasons and that nothing be so designated without a good faith belief that it
5 ||has been maintained in a confidential, non-public manner, and there is good cause
6 || why it should not be part of the public record of this case.
7
8 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL
9 The parties further acknowledge, as set forth in Section 12.3, below, that this
10 || Stipulated Protective Order does not entitle them to file confidential information
11 || under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed
12 || and the standards that will be applied when a party seeks permission from the court
13 || to file material under seal.
14 There is a strong presumption that the public has a right of access to judicial
15 proceedings and records in civil cases. In connection with non-dispositive motions,
16 || good cause must be shown to support a filing under seal. See Kamakana v. City and
3
County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006); Phillips v. Gen. Motors
18 || Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002); Makar-Welbon v. Sony Electrics,
19 || Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders
20 |) require good cause showing), and a specific showing of good cause or compelling
21 |/reasons with proper evidentiary support and legal justification, must be made with
22 ||respect to Protected Material that a party seeks to file under seal. The parties’ mere
23 || designation of Disclosure or Discovery Material as CONFIDENTIAL does not—
24 |) without the submission of competent evidence by declaration, establishing that the
25 || material sought to be filed under seal qualifies as confidential, privileged, or
26 || otherwise protectable—constitute good cause.
27 Further, if a party requests sealing related to a dispositive motion or trial, then
28 || compelling reasons, not only good cause, for the sealing must be shown, and the
1 || relief sought shall be narrowly tailored to serve the specific interest to be protected.
2 || See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For
3 || each item or type of information, document, or thing sought to be filed or introduced
4 || under seal in connection with a dispositive motion or trial, the party seeking
5 || protection must articulate compelling reasons, supported by specific facts and legal
6 || justification, for the requested sealing order. Again, competent evidence supporting
7 || the application to file documents under seal must be provided by declaration.
8 Any document that is not confidential, privileged, or otherwise protectable in
9 || its entirety will not be filed under seal if the confidential portions can be redacted. If
10 || documents can be redacted, then a redacted version for public viewing, omitting only
11 confidential, privileged, or otherwise protectable portions of the document shall
12 ||be filed. Any application that seeks to file documents under seal in their entirety
13 || should include an explanation of why redaction is not feasible.
15|]2. DEFINITIONS
16 2.1 Action: this pending federal lawsuit.
3
17 2.2 Challenging Party: a Party or Non-Party that challenges the designation of
18 || information or ttems under this Order.
19 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how
20 |/it is generated, stored or maintained) or tangible things that qualify for protection
21 |)/under Federal Rule of Civil Procedure 26(c), and as specified above in the Good
22 || Cause Statement.
23 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their
24 || support staff).
25 2.5 Designating Party: a Party or Non-Party that designates information or
26 |/items that it produces in disclosures or in responses to discovery as
27 || “CONFIDENTIAL.”
28 2.6 Disclosure or Discovery Material: all items or information, regardless of
1 medium or manner in which it is generated, stored, or maintained (including,
2 ||among other things, testimony, transcripts, and tangible things), that are produced or
3 || generated in disclosures or responses to discovery in this matter.
4 2.7 Expert: a person with specialized knowledge or experience in a matter
5 || pertinent to the litigation who has been retained by a Party or its counsel to serve as
6 || an expert witness or as a consultant in this Action.
7 2.8 House Counsel: attorneys who are employees of a party to this Action.
8 || House Counsel does not include Outside Counsel of Record or any other outside
9 || counsel.
10 2.9 Non-Party: any natural person, partnership, corporation, association, or
11 || other legal entity not named as a Party to this action.
12 2.10 Outside Counsel of Record: attorneys who are not employees of a party to
13 this Action but are retained to represent or advise a party to this Action and have
14 || appeared in this Action on behalf of that party or are affiliated with a law firm which
| {has appeared on behalf of that party, and includes support staff.
2 16 2.11 Party: any party to this Action, including all of its officers, directors,
—17]}|employees, consultants, retained experts, and Outside Counsel of Record (and their
18 || support staffs).
19 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
20 || Discovery Material in this Action.
21 2.13 Professional Vendors: persons or entities that provide litigation support
22 ||services (e.g., photocopying, videotaping, translating, preparing exhibits or
23 || demonstrations, and organizing, storing, or retrieving data in any form or medium)
24 || and their employees and subcontractors.
25 2.14 Protected Material: any Disclosure or Discovery Material that 1s
26 || designated as “CONFIDENTIAL.”
27 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material
28 || from a Producing Party.
1 ||3. SCOPE
2 The protections conferred by this Stipulation and Order cover not only
3 || Protected Material (as defined above) but also any information copied or extracted
4 || from Protected Material; all copies, excerpts, summaries, or compilations of Protected
5 ||Material; and any testimony, conversations, or presentations by Parties or their
6 || Counsel that might reveal Protected Material.
7 Any use of Protected Material at trial will be governed by the orders of the
8 || trial judge. This Order does not govern the use of Protected Material at trial.
9
10 4. DURATION
11 Once a case proceeds to trial, information that was designated as
12 || CONFIDENTIAL or maintained pursuant to this protective order used or introduced
13 ||as an exhibit at trial becomes public and will be presumptively available to all
14 ||members of the public, including the press, unless compelling reasons supported by
15 specific factual findings to proceed otherwise are made to the trial judge in advance
2 16||of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause”
—17||showing for sealing documents produced in discovery from “compelling reasons”
18 || standard when merits-related documents are part of court record). Accordingly, the
19 || terms of this protective order do not extend beyond the commencement of the trial.
20
]|5. DESIGNATION OF PROTECTED MATERIAL
22 5.1. Exercise of Restraint and Care in Designating Material for Protection.
23 || Each Party or non-party that designates information or items for protection under this
24 || Stipulation and its associated Order must take care to limit any such designation to
25 || specific material that qualifies under the appropriate standards. A Designating Party
26 || must take care to designate for protection only those parts of material, documents,
27 ||items, or oral or written communications that qualify — so that other portions of the
28 || material, documents, items or communications for which protection is not warranted
1 || are not swept unjustifiably within the ambit of this Order.
2 Mass, indiscriminate, or routine designations are prohibited. Designations that
3 || are shown to be clearly unjustified, or that have been made for an improper purpose
4 || (e.g., to unnecessarily encumber or retard the case development process, or to impose
5 || unnecessary expenses and burdens on other parties), expose the Designating Party to
6 || sanctions.
7 If it comes to a Designating Party’s attention that information or items that it
8 || designated for protection do not qualify for protection, that Designating Party must
9 || promptly notify all other Parties that it is withdrawing the inapplicable designation.
10 5.2. Manner and Timing of Designations. Except as otherwise provided in
11 || this Order, or as otherwise stipulated or ordered, material that qualifies for protection
12 |}under this Order must be clearly so designated before the material is disclosed or
13 || produced.
14 Designation in conformity with this Order requires the following:
15 (a) for information in documentary form (apart from transcripts of
2 16 || depositions or other pretrial or trial proceedings, and regardless of whether produced
17||in hardcopy or electronic form), that the Producing Party affix the legend
18 || “CONFIDENTIAL” to each page that contains Protected Material. If only a portion
19 || or portions of the material on a page qualifies for protection, the Producing Party also
20 || must clearly identify the protected portion(s) (e.g., by making appropriate markings
21 |/in the margins). Whenever possible, the “CONFIDENTIAL legend” should be placed
22 ||in the margins of the designated document. The “CONFIDENTIAL legend” should
23 ||not obscure the contents of the document or material. (See Local Rule 11-3.1.)
24 A Party or Non-Party that makes original documents or materials available for
25 || inspection need not designate them for protection until after the inspecting Party has
26 || indicated which material it would like copied and produced. During the inspection
27 || and before the designation, all of the material made available for inspection shall be
28 || deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents
] || it wants copied and produced, the Producing Party must determine which documents,
2 || or portions thereof, qualify for protection under this Order. Then, before producing
3 ||the specified documents, the Producing Party must affix the “CONFIDENTIAL”
4 || legend to each page that contains Protected Material. If only a portion or portions of
5 || the material on a page qualifies for protection, the Producing Party also must clearly
6 ||identify the protected portion(s) (e.g., by making appropriate markings in the
7 || margins).
8 (b) for testimony given in depositions, the Designating Party must identify
9 || the Disclosure or Discovery Material that is protected on the record, before the close
10 || of the deposition.
11 (c) for information produced in some form other than documentary, and for
12 || any other tangible items, the Producing Party must affix in a prominent place on the
13 || exterior of the container or containers in which the information or item is stored the
14|| legend “CONFIDENTIAL.” If only portions of the information or item warrant
15 protection, the Producing Party, to the extent practicable, shall identify the protected
16 || portions, specifying the material as “CONFIDENTIAL.”
17 5.3. Inadvertent Failures to Designate. If timely corrected, an inadvertent
18 || failure to designate qualified information or items does not, standing alone, waive the
19 || Designating Party’s right to secure protection under this Order for that material. On
20 || timely correction of a designation, the Receiving Party must make reasonable efforts
21 || to assure that the material is treated in accordance with the provisions of this Order.
22
23 || 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS.
24 6.1. Timing of Challenges. Any Party or Non-Party may challenge a
25 ||designation of confidentiality at any time that is consistent with the Court's
26 || Scheduling Order.
27 6.2. Meet and Confer. The Challenging Party shall initiate the dispute
28 || resolution process under Local Rule 37.1 et seq.
l 6.3. The burden of persuasion in any such challenge proceeding shall be on
2 || the Designating Party. Frivolous challenges, and those made for an improper purpose
3 || (e.g., to harass or impose unnecessary expenses and burdens on other parties) may
4 || expose the Challenging Party to sanctions. Unless the Designating Party has waived
5 || or withdrawn the confidentiality designation, all parties shall continue to afford the
6 || material in question the level of protection to which it is entitled under the Producing
7 || Party’s designation until the Court rules on the challenge.
8
9 || 7. ACCESS TO AND USE OF PROTECTED MATERIAL
10 7.1. Basic Principles. A Receiving Party may use Protected Material that is
«| 11 ]/ disclosed or produced by another Party or by a non-party in connection with this case
12 || only for preparing, prosecuting, defending, or attempting to settle this litigation — up
13 || to and including final disposition of the above-entitled action — and not for any other
14 || purpose, including any other litigation or dispute outside the scope of this action.
| 15||Such Protected Material may be disclosed only to the categories of persons and under
2 16 || the conditions described in this Stipulation and its associated Order. When the above
|lentitled litigation has been terminated, a Receiving Party must comply with the
18 || provisions of section 13, below (FINAL DISPOSITION).
19 Protected Material must be stored and maintained by a Receiving Party at a
20 || location and in a secure manner that ensures that access is limited to the persons
21 || authorized under this Stipulation and its Order.
22 7.2. Disclosure _of “CONFIDENTIAL” Information or Items. Unless
23 || otherwise ordered by the Court or permitted in writing by the Designating Party, a
24 || Receiving Party may disclose any information or item designated CONFIDENTIAL
25 || only to the following people:
26 (a) the Receiving Party’s Outside Counsel of record in this action, as well
27 ||as employees of such Counsel to whom it is reasonably necessary to disclose the
28 || information for this Action;
l (b) the officers, directors, and employees (including House Counsel) of the
2 || Receiving Party to whom disclosure is reasonably necessary for this litigation;
3 (c) Experts (as defined in this Stipulation and Order) of the Receiving Party
4||to whom disclosure is reasonably necessary for this litigation and who have signed
5 || the "Acknowledgement 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
10 || signed 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 to whom
14 || disclosure is reasonably necessary, provided that the deposing party requests that the
| 15 || witness sign the form attached as Exhibit A hereto and the witnesses will not be
|| permitted to keep any confidential information unless they sign the form, unless
3
| —17]lotherwise agreed by the Designating Party or ordered by the Court. Pages of
18 || transcribed deposition testimony or exhibits to depositions that reveal Protected
19 || Material may be separately bound by the court reporter and may not be disclosed to
20 || anyone except as permitted under this Order; and
21 (4) any mediator or settlement officer, and their supporting personnel,
||mutually agreed on by any of the Parties engaged in settlement discussions or
23 || appointed by the Court.
24
25 |/8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN
*6 OTHER LITIGATION.
27
28 If a Party is served with a subpoena or a court order issued in other litigation
1 ||that compels disclosure of any information or items designated in this action as
2 || “CONFIDENTIAL,” that Party must:
3 (a) promptly notify in writing the Designating Party, preferably (though not
4 || necessarily) by facsimile or electronic mail. Such notification shall include a copy of
5 || the subpoena or court order at issue;
6 (b) promptly notify in writing the party who caused the subpoena or order to
7 || issue in the other litigation that some or all of the material covered by the subpoena
8 || or order is subject to this Stipulation and its Protective Order. Such notification shall
9 || include a copy of this Stipulation and its Protective Order; and
10 (c) cooperate with respect to all reasonable procedures sought to be pursued
11 || by all sides in any such situation, while adhering to the terms of this Stipulation and
12 |} its Order.
13 If the Designating Party timely seeks a protective order, the Party served with
14 || the subpoena or court order shall not produce any information designated in this action
| |/as “CONFIDENTIAL” before a determination by the court from which the subpoena
16 || or order issued, unless the Party has obtained the Designating Party’s permission. The
3
1! Designating Party shall bear the burden and expense of seeking protection in that court
18 || of its confidential material — and nothing in these provisions should be construed as
19 || authorizing or encouraging a Receiving Party in this action to disobey a □□□□□□
20 || directive from another court.
21/9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
22 PRODUCED IN THIS LITIGATION
23 (a) Theterms of this Order are applicable to information produced by a Non-
24||Party in this Action and designated as “CONFIDENTIAL.” Such information
25 ||produced by Non-Parties in connection with this litigation is protected by the
26 ||remedies and relief provided by this Order. Nothing in these provisions should be
27 || construed as prohibiting a Non-Party from seeking additional protections.
28 (b) In the event that a Party is required, by a valid discovery request, to
1 || produce a Non-Party’s confidential information in its possession, and the Party is
2||subject to an agreement with the Non-Party not to produce the Non-Party’s
3 || confidential information, then the Party must:
4 (1) promptly notify in writing the Requesting Party and the Nonparty
5 that some or all of the information requested is subject to a
6 confidentiality agreement with a Nonparty;
7 (2) promptly provide the Nonparty with a copy of this Order, the
8 relevant discovery request(s), and a reasonably specific
9 description of the information requested; and
10 (3) make the information requested available for inspection by the
ll Non-Party, if requested.
12 (c) Ifthe Non-Party fails to seek a protective order from this court within 21
13 || days of receiving the notice and accompanying information, the Receiving Party may
14 || produce the Non-Party’s confidential information responsive to the discovery request.
| 15||Ifthe Non-Party timely seeks a protective order, the Receiving Party shall not produce
2 16||any information in its possession or control that is subject to the confidentiality
3
—17]|agreement with the Non-Party before a determination by the court. Absent a court
18 || order to the contrary, the Non-Party shall bear the burden and expense of seeking
19 || protection in this court of its Protected Material.
20
21|}10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
22 If a Receiving Party learns that by inadvertence or otherwise, it has disclosed
23 || Protected Material to any person or in any circumstance not authorized under this
24 || Order, the Receiving Party must immediately notify the Designating Party in writing
25 || of the unauthorized disclosures, use its best efforts to retrieve all unauthorized copies
26 ||of the Protected Material, inform the person or people to whom unauthorized
27 || disclosures were made of the terms of this Order, and ask that person or people to
28 || execute the “Acknowledgment and Agreement to Be Bound” that is attached hereto
1 |jas Exhibit A.
2
3})}11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
4 PROTECTED MATERIAL
5
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 Federal Rule of Civil
Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
? may be established in an e-discovery order that provides for production without prior
'0 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
parties reach an agreement on the effect of disclosure of a communication or
information covered by the attorney-client privilege or work product protection, the
parties may incorporate their agreement in the stipulated protective order submitted
to the court.
1S
16
3
17)/12. MISCELLANEOUS
18 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
19 || person to seek its modification by the Court in the future.
20 12.2 Right to Assert Other Objections. By stipulating to the entry of this
21 □□ Protective Order no Party waives any right it otherwise would have to object to
22 || disclosing or producing any information or item on any ground not addressed in this
23 || Stipulated Protective Order. Similarly, no Party waives any right to object on any
24 || ground to use in evidence of any of the material covered by this Protective Order.
25 12.3 Filing Protected Material. A Party that seeks to file under seal any
26 || Protected Material must comply with Civil Local Rule 79-5. Protected Material may
27 || only be filed under seal pursuant to a court order authorizing the sealing of the specific
28 || Protected Material at issue. If a Party's request to file Protected Material under seal is
1 || denied by the court, then the Receiving Party may file the information in the public
2 ||record unless otherwise instructed by the court.
3
4|/13. FINAL DISPOSITION
5 After the final disposition of this Action, as defined in paragraph 4, within 60
6 || days of a written request by the Designating Party, each Receiving Party must return
7 || all Protected Material to the Producing Party or destroy such material. As used in this
8 || subdivision, “all Protected Material” includes all copies, abstracts, compilations,
9 ||}summaries, and any other format reproducing or capturing any of the Protected
10 || Material. Whether the Protected Material is returned or destroyed, the Receiving Party
11 || must submit a written certification to the Producing Party (and, if not the same person
12 || or entity, to the Designating Party) by the 60-day deadline that identifies (by category,
13 ||} when appropriate) all the Protected Material that was returned or destroyed and
14 || affirms that the Receiving Party has not retained any copies, abstracts, compilations,
15 summaries, or any other format reproducing or capturing any of the Protected
2 16 || Material. Notwithstanding this provision, Counsel are entitled to retain an archival
! copy of all pleadings; motion papers; trial, deposition, and hearing transcripts; legal
18 || memoranda; correspondence; deposition and trial exhibits; expert reports; attorney
19 || work product; and consultant and expert work product even if such materials contain
20 || Protected Material. Any such archival copies that contain or constitute Protected
21 || Material remain subject to this Order as set forth in Section 4 (DURATION).
22
23||14. VIOLATION
24 Any violation of this Order may be punished by appropriate measures
25 |) including, without limitation, contempt proceedings and/or monetary sanctions.
26
27 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
28
1|}DATED: August 12, 2026 KIRAKOSIAN LAW, APC
By:
3 Greg L. Kirakosian
4 Astina T. Shakilyan
Attorneys for Plaintiff,
5 MATTHEW RALSTON
6
7
8||DATED: August 12, 2026 MANNING & KASS
9 ELLROD, RAMIREZ, TRESTER LLP
10 By: /s/ Hyelim Cho
Mildred K. O’Linn
Hyelim Cho
12 Attorneys for Defendants, CITY OF
REDONDO BEACH and OFFICER
WARREN
me
614
15
a 1
17|1fOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
18
19||DATED: 08/12/2026
20
21
22 Rapedie A.
23 || HON. ROZELLA A. OLIVER
United States Magistrate Judge
25
26
27
28
1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3
4 I, [print or type full
5 ||/name], of [print or type full address], declare
6 || under penalty of perjury that I have read in its entirety and understand the Stipulated
7 || Protective Order that was issued by the United States District Court for the Central
8 || District of California on [date] in the case of MATTHEW RALSTON. v.
9 || CITY OF REDONDO BEACH, et al., Case No. 2:26—cv—02097—FLA—RAO. I
10 || agree to comply with and to be bound by all the terms of this Stipulated Protective
11 || Order and I understand and acknowledge that failure to so comply could expose me
12 || to sanctions and punishment in the nature of contempt. I solemnly promise that I will
13 || not disclose in any manner any information or item that is subject to this Stipulated
14 || Protective Order to any person or entity except in strict compliance with the
15 provisions of this Order.
2 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 || Stipulated Protective Order, even if such enforcement proceedings occur after
19 || termination of this action. I hereby appoint [print
20 || or type full name] of [print or type
21 || full address and telephone number] as my California agent for service of process
22 |)in connection with this action or any proceedings related to enforcement of this
23 || Stipulated Protective Order.
24 || Date:
25 || City and State where sworn and signed:
26 || Printed name:
27 || Signature:
28