Maribel Murillo v. City of Los Angeles

1 DENISE C. MILLS, Chief Deputy City Attorney (SBN 191992)

SCOTT MARCUS, Chief Assistant City Attorney (SBN 184980)

2

CORY M. BRENTE, Senior Assistant City Attorney (SBN 115453)

3 CHRISTIAN R. BOJORQUEZ, Deputy City Attorney (SBN 192872)

200 N. Main Street, 6th Floor, City Hall East

4 Los Angeles, California 90012

Tel: (213) 978-7023; Fax: (213) 978-8785

5

Email: christian.bojorquez@lacity.org

6

Attorneys for Defendant CITY OF LOS ANGELES

7

8 UNITED STATES DISTRICT COURT

9 CENTRAL DISTRICT OF CALIFORNIA

10

11 MARIBEL MURILLO, et al. Case No. 2:22-cv-03188 DMG (SK)

12 Plaintiffs, H Mo an go isr ta rb al te e J Ju ud dg ge e: : D Sto el vl ey KM i. m G ; e Ce t; r C mr 5tm 40 8 C

13 v.

14 CITY OF LOS ANGELES, et al.

STIPULATED PROTECTIVE

15 Defendants. ORDER

16

17

18

19

1. A. 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

23

be warranted. Accordingly, the parties hereby stipulate to and petition the Court to

24

enter the following Stipulated Protective Order. The parties acknowledge that this

25

Order does not confer blanket protections on all disclosures or responses to

26

discovery and that the protection it affords from public disclosure and use extends

27

only to the limited information or items that are entitled to confidential treatment

28

1 under the applicable legal principles. The parties further acknowledge, as set forth

2 in Section 12.3 (Filing Protected Material), below, that this Stipulated Protective

3 Order does not entitle them to a file confidential information under seal; Civil Local

4 Rule 79-5 sets forth the procedures that must be followed and the standards that will

5 be applied when a party seeks permission from the court to file material under seal.

6

7 B. GOOD CAUSE STATEMENT

Defendants’ Statement of Good Cause:

8

Defendants contend the Force Investigation Division of the Los Angeles

9

Police Department and the Internal Affairs and/or Complaint Investigators conduct

10

internal administrative investigations of categorical officer-involved uses of force

11

and internal complaints and external citizen complaints of police misconduct. In

12

this above-captioned matter, the Force Investigation Division of the Los Angeles

13

Police Department conducted an internal administrative investigation into the

14

events of this underlying incident. FID has also collected involved Officers’ Body

15

Camera Footage of what took place during the underlying incident. Such

16

information is obtained through the administrative investigation of this incident

17

and are maintained as confidential peace officer personnel records and utilized for

18

administrative issues for any involved Officers. Defendants contend that a

19

Protective Order is appropriate for the following Good Cause reasons:

20

Once completed, an FID report and/or Personnel Complaint Investigation is

21

prepared. Such reports are reviewed by appropriate command officers in the

22

Department and by the Board of Police Commissioners. This review has several

23

purposes: (1) to determine whether the involved officers violated any Department

24

policies or procedures; (2) to determine whether administrative discipline and/or

25

26 retraining of the involved officers is necessary; (3) to ascertain if police policies

27 and procedures in such areas as supervision, training, tactics, policies, etc.; should

28 be modified. In sum, FID reports and/or Personnel Complaint Investigations are

1 an essential aid to providing critical self-evaluation of Department officers and

policies and to determine the most effective way to serve the citizens of Los

2

Angeles.

3

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

4

resolution of disputes over confidentiality of discovery materials, to adequately

5

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

6

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

7

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

8

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

9

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

10

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

11

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

12

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

13

14

15 2. DEFINITIONS

16 2.1 Action: Maribel Murillo v. City of Los Angeles, et al, 2:22-cv-03188

17 DMB (SK)

18 2.2 Challenging Party: a Party or Non-Party that challenges the

19 designation of information or items under this Order.

20 2.3 “CONFIDENTIAL” Information or Items: information (regardless of

21 how it is generated, stored, or maintained) or tangible things that qualify for

22 protection under Federal Rule of Civil Procedure 26(c), and as specified above in

23 the Good Cause Statement.

24 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as

25 their support staff).

26 2.5 Designating Party: a Party or Non-Party that designates information

27 or items that it produces in disclosures or in responses to discovery as

28 “CONFIDENTIAL.”

1 2.6 Disclosure or Discovery Material: all items or information, regardless

2 of the medium or manner in which it is generated, stored, or maintained (including,

3 among other things, testimony, transcripts, and tangible things), that are produced

4 or generated in disclosures or responses to discovery in this matter.

5 2.7 Expert: a person with specialized knowledge or experience in a matter

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

7 an expert witness or as a consultant in this Action.

8 2.8 House Counsel: attorneys who are employees of a party to this Action.

9 House Counsel does not include Outside Counsel of Record or any other outside

10 counsel.

11 2.9 Non-Party: any natural person, partnership, corporation, association,

12 or other legal entity not named as a Party to this action.

13 2.10 Outside Counsel of Record: attorneys who are not employees of a

14 party to this Action but are retained to represent or advise a party to this Action and

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

16 which has appeared on behalf of that party, including support staff.

17 2.11 Party: any party to this Action, including all of its officers, directors,

18 employees, consultants, retained experts, and Outside Counsel of Record (and their

19 support staffs).

20 2.12 Producing Party: a Party or Non-Party that produces Disclosure or

21 Discovery Material in this Action.

22 2.13 Professional Vendors: persons or entities that provide litigation

23 support services (e.g., photocopying, videotaping, translating, preparing exhibits or

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

25 and their employees and subcontractors.

2.14 Protected Material: any Disclosure or Discovery Material that is

26

designated as “CONFIDENTIAL.” Pursuant to several meet and confers, in lieu of

27

seeking Court Intervention, Defendants have agreed to Provide the Following

28

1 Documents as “CONFIDENTIAL” materials:

A) Force Investigation Division Documents Re: the underlying

2

abovementioned lawsuit, as follows, except for any documents

3

contained in the FID Report which, on their own, are not confidential

4

documents, e.g. the arrest report, the 51.7 form, among others:

5

a. Force Investigation Division Investigation Records;

6

b. Any and all documents, interviews, Officer Statements and/or

7

writings created during such Investigation, which include, but are not

8

limited to, the following:

9

Force Investigation Division Records

10

- Interviews;

11

12 - All Bodycam Footage of Involved Officers;

13 - Officer Statements, whether written or recorded;

14 - Legend w/diagram;

15 - Pictures - Which coincide with an Officer(s) compelled

16 statement which were intended to reflect the Officer’s stated

17 or perception of events;

18 - Investigative Internal Narrative Memoranda;

19 This list is not exclusive, and also includes other materials later agreed-upon

20 and/or ordered by the Court to be designated as Protected Material under this

21 Protective Order. The inclusion of this list does not constitute an agreement by

22 Plaintiffs that the CONFIDENTIAL designation is in fact appropriate for any of the

23 aforementioned materials. Plaintiffs reserve all rights to challenge these and any

24 other designations pursuant to the procedures set forth below in section 6 et seq.

25 It must be noted that Defendants are producing the FID Investigation

26 materials based upon the agreement of Counsel to enter into this Stipulation for

27 Protective Order and are relying upon the good faith negotiations that have taken

28 place this far in this litigation.

1 2.15 Receiving Party: a Party that receives Disclosure or Discovery

2 Material from a Producing Party.

3

4 3. SCOPE

5 The protections conferred by this Stipulation and Order cover not only

6 Protected Material (as defined above), but also (1) any information copied or

7 extracted from Protected Material; (2) all copies, excerpts, summaries, or

8 compilations of Protected Material; and (3) any testimony, conversations, or

9 presentations by Parties or their Counsel that might reveal Protected Material.

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

11 trial judge. This Order does not govern the use of Protected Material at trial.

12

13 4. DURATION

14 The terms of this protective order do not extend to the presentation of

15 evidence at trial. Any protection sought for documents that are presented at trial

16 shall be governed by order of the Judge presiding over the trial. Should any

17 Protected Material become part of the public record at trial or otherwise (such as a

18 where the Court denies the request to file under seal), this Protective Order shall

19

no longer apply to the portions which became part of the public record at trial with

20

the exception that any such material must still be returned in compliance with

21

Section 13: Final Disposition.

22

Should any portion of the Protected Material remain confidential until trial,

23

during any portion of the trial of this action which could entail the discussion or

24

disclosure of Confidential Information, that Designating Party may request the

25

opportunity to show compelling reasons to the Court as to why access to the

26

courtroom should be limited to parties, their counsel and other designated

27

representative, experts or consultants who agreed to be bound by this

28

1 stipulation/protective order, and court personnel. See Kamakana v. City and

County of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing “good

2

cause” showing for sealing documents produced in discovery from “compelling

3

reasons” standard when merits-related documents are part of court record).

4

5 For all portions of the Protected Material after final disposition of the Trial,

6 the confidentiality obligations by this Order shall remain in full effect. Final

7 disposition shall be deemed to be the later of (1) dismissal of all claims and

8 defenses in this Action, with or without prejudice; (2) In any event wherein all

9 remaining claims in this matter are remanded to State Court or severed from the

10 Federal matter and returned to State Court; and/or (3) final judgment herein after

11 the completion and exhaustion of all appeals, re-hearings, remands, trials, or

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

13 applications for extension of time pursuant to applicable law.

14

15 5. DESIGNATING PROTECTED MATERIAL

16 5.1 Exercise of Restraint and Care in Designating Material for Protection.

17 Each Party or Non-Party that designates information or items for protection under

18 this Order must take care to limit any such designation to specific material that

19 qualifies under the appropriate standards. The Designating Party must designate for

20 protection only those parts of material, documents, items, or oral or written

21 communications that qualify so that other portions of the material, documents,

22 items, or communications for which protection is not warranted are not swept

23 unjustifiably within the ambit of this Order.

24 Mass, indiscriminate, or routinized designations are prohibited. Designations

25 that are shown to be clearly unjustified or that have been made for an improper

26 purpose (e.g., to unnecessarily encumber the case development process or to impose

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

28 Party to sanctions.

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

2 designated for protection do not qualify for protection, that Designating Party must

3 promptly notify all other Parties that it is withdrawing the inapplicable designation.

4 5.2 Manner and Timing of Designations. Except as otherwise provided in

5 this Order (see, e.g., second paragraph of Section 5.2(a) below), or as otherwise

6 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection

7 under this Order must be clearly so designated before the material is disclosed or

8 produced.

9 Designation in conformity with this Order requires:

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

11 documents, but excluding transcripts of depositions or other pretrial or trial

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

13 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that

14 contains protected material. If only a portion or portions of the material on a page

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

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

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

18 inspection need not designate them for protection until after the inspecting Party has

19 indicated which documents it would like copied and produced. During the

20 inspection and before the designation, all of the material made available for

21 inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has

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

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

24 Order. Then, before producing the specified documents, the Producing Party must

25 affix the “CONFIDENTIAL legend” to each page that contains Protected Material.

26 If only a portion or portions of the material on a page qualifies for protection, the

27 Producing Party also must clearly identify the protected portion(s) (e.g., by making

28 appropriate markings in the margins).

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

2 the Disclosure or Discovery Material on the record, before the close of the

3 deposition all protected testimony.

4 (c) for information produced in some form other than documentary and

5 for any other tangible items, that the Producing Party affix in a prominent place on

6 the exterior of the container or containers in which the information is stored the

7 legend “CONFIDENTIAL.” If only a portion or portions of the information

8 warrants protection, the Producing Party, to the extent practicable, shall identify the

9 protected portion(s).

10 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent

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

12 the Designating Party’s right to secure protection under this Order for such material.

13 Upon timely correction of a designation, the Receiving Party must make reasonable

14 efforts to assure that the material is treated in accordance with the provisions of this

15 Order.

16

17 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

18 6.1 Timing of Challenges. Any Party or Non-Party may challenge a

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

20 Scheduling Order.

21 6.2 Meet and Confer. The Challenging Party Shall initiate the dispute

22 resolution process under Civil Local Rule 37-1 et seq.

23 6.3 The burden of persuasion in any such challenge proceeding shall be

24 on the Designating Party. Frivolous challenges, and those made for an improper

25 purpose (e.g., to harass or impose unnecessary expenses and burdens on other

26 parties), may expose the Challenging Party to sanctions. Unless the Designating

27 Party has waived or withdrawn the confidentiality designation, all parties shall

28 continue to afford the material in question the level of protection to which it

1 is entitled under the Producing Party’s designation until the Court rules on the

2 challenge.

3

4 7. ACCESS TO AND USE OF PROTECTED MATERIAL

5 7.1 Basic Principles. A Receiving Party may use Protected Material that

6 is disclosed or produced by another Party or by a Non-Party in connection with

7 this Action only for prosecuting, defending, or attempting to settle this Action.

8 Such Protected Material may be disclosed only to the categories of persons and

9 under the conditions described in this Order. When the Action has been

10 terminated, a Receiving Party must comply with the provisions of Section 13 below

11 (FINAL DISPOSITION).

12 In the event only certain claims are severed and remanded to State Court,

13 refiled in State Court or claims severed and remanded to State Court, then the Parties

14 shall meet and confer pursuant to Local Rule 37-1 regarding the disposition of all

15 materials produced pursuant to this Protective Order. In the event that the parties

16 are unable to reach an informal agreement, the Parties shall file an appropriate

17 motion with the Court utilizing the joint stipulation procedures set forth in Local

18 Rule 37-2.

19 In the event this entire matter is remanded to State Court or dismissed and

20 refiled in State Court then all materials, including the FID Investigation as well as

21 any other Court Ordered Documents provided pursuant to this Protective Order and

22 all copies thereof shall be returned to the Offices of the Los Angeles City Attorney’s

23 Office, 6th Floor, City Hall East, Los Angeles, California 90012 for

24 destruction/shredding. All Confidential documentation provided to any person or

25 party, pursuant to any provision hereof, also shall be returned to the City Attorney’s

26 Office. Protected Material must be stored and maintained by a Receiving Party at

27 a location and in a secure manner that ensures that access is limited to the

28 persons authorized under this Order.

1 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless

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

3 Receiving Party may disclose any information or item designated

4 “CONFIDENTIAL” only to:

5 (a) the Receiving Party’s Outside Counsel of Record in this Action, as

6 well as employees of said Outside Counsel of Record to whom it is reasonably

7 necessary to disclose the information for this Action;

8 (b) the officers, directors, and employees (including House Counsel) of

9 the Receiving Party to whom disclosure is reasonably necessary for this Action;

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

11 disclosure is reasonably necessary for this Action and who have signed the

12 “Acknowledgment and 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 for 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 or a

19 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 form attached as Exhibit A hereto; and (2)

23 they will not be permitted to keep any confidential information unless they sign the

24 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise

25 agreed by the Designating Party or ordered by the Court. Pages of transcribed

26 deposition testimony or exhibits to depositions that reveal Protected Material may

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

28 as permitted under this Stipulated Protective Order; and

1 (i) any mediator or settlement officer, and their supporting personnel,

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

3

4 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED

5 IN OTHER LITIGATION

6 If a 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

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

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

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

13 subpoena or order is subject to this Protective Order. Such notification shall include

14 a copy of this Stipulated Protective Order; and

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

16 pursued 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 / / /

26 / / /

27 / / /

28

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

2 PRODUCED IN THIS LITIGATION

3 (a) The terms of this Order are applicable to information produced by a

4 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information

5 produced by Non-Parties in connection with this litigation is protected by the

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

7 construed as prohibiting a Non-Party from seeking additional protections.

8 (b) In the event that a Party is required, by a valid discovery request, to

9 produce a Non-Party’s confidential information in its possession, and the Party is

10 subject to an agreement with the Non-Party not to produce the Non-Party’s

11 confidential information, then the Party shall:

12 (1) promptly notify in writing the Requesting Party and the Non-Party

13 that some or all of the information requested is subject to a confidentiality agreement

14 with a Non-Party;

15 (2) promptly provide the Non-Party with a copy of the Stipulated

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

17 specific description of the information requested; and

18 (3) make the information requested available for inspection by the Non-

19 Party, if requested.

20 (c) If the Non-Party fails to seek a protective order from this Court within

21 14 days of receiving the notice and accompanying information, the Receiving Party

22 may produce the Non-Party’s confidential information responsive to the discovery

23 request. If the Non-Party timely seeks a protective order, the Receiving Party shall

24 not produce any information in its possession or control that is subject to the

25 confidentiality agreement with the Non-Party before a determination by the Court.

26 Absent a court order to the contrary, the Non-Party shall bear the burden and

27 expense of seeking protection in this Court of its Protected Material.

28

1 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

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

4 Stipulated Protective Order, the Receiving Party must immediately (a) notify in

5 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts

6 to retrieve all unauthorized copies of the Protected Material, (c) inform the person

7 or persons to whom unauthorized disclosures were made of all the terms of this

8 Order, and (d) request such person or persons to execute the “Acknowledgment and

9 Agreement to Be Bound” that is attached hereto as Exhibit A.

10

11 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

12 PROTECTED MATERIAL

13 When a Producing Party gives notice to Receiving Parties that certain

14 inadvertently produced material is subject to a claim of privilege or other protection,

15 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil

16 Procedure 26(b)(5)(B). This provision is not intended to modify whatever

17 procedure may be established in an e-discovery order that provides for production

18 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and

19 (e), insofar as the parties reach an agreement on the effect of disclosure of a

20 communication or information covered by the attorney-client privilege or work

21 product protection, the parties may incorporate their agreement in the stipulated

22 protective order submitted to the Court.

23

24 12. MISCELLANEOUS

25 12.1 Right to Relief. Nothing in this Order abridges the right of any person

26 to seek its modification by the Court in the future.

27 12.2 Right to Assert Other Objections. By stipulating to the entry of this

28 Protective Order, no Party waives any right it otherwise would have to object to

1 disclosing or producing any information or item on any ground not addressed in this

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

3 ground to use in evidence of any of the material covered by this Protective Order.

4 12.3 Filing Protected Material. A Party that seeks to file under seal any

5 Protected Material must comply with Civil Local Rule 79-5. Protected Material

6 may only be filed under seal pursuant to a court order authorizing the sealing of the

7 specific Protected Material at issue. If a Party’s request to file Protected Material

8 under seal is denied by the court, then the Receiving Party may file the information

9 in the public record unless otherwise instructed by the court.

10

11 13. FINAL DISPOSITION

12 After the final disposition of this Action, as defined in Section 4

13 (DURATION), within 60 days of a written request by the Designating Party, each

14 Receiving Party must return all Protected Material to the Producing Party or destroy

15 such material. As used in this subdivision, “all Protected Material” includes all

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

17 capturing any of the Protected Material. Whether the Protected Material is returned

18 or destroyed, the Receiving Party must submit a written certification to the

19 Producing Party (and, if not the same person or entity, to the Designating Party) by

20 the 60 day deadline that (1) identifies (by category, where appropriate) all the

21 Protected Material that was returned or destroyed; and (2) affirms that the Receiving

22 Party has not retained any copies, abstracts, compilations, summaries, or any other

23 format reproducing or capturing any of the Protected Material. Notwithstanding this

24 provision, Counsel are entitled to retain an archival copy of all pleadings, motion

25 papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence,

26 deposition and trial exhibits, expert reports, attorney work product, and consultant

27 and expert work product, even if such materials contain Protected Material. Any

28

1 | such archival copies that contain or constitute Protected Material remain subject to

this Protective Order as set forth in Section 4 (DURATION).

14. Any violation of this Order may be punished by any and all appropriate

4 measures including, without limitation, contempt proceedings and/or

5 monetary sanctions.

6

ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD.

8

g| Dated: June 6, 2023 LAW OFFICE OF DALE K. GALIPO

10 By:__/S/ Marcel Sincich

Wl DALE K. GALIPO, ESQ.

MARCEL SINCICH, ESQ.

12 Attorneys for Plaintiffs MARIBEL MURILLO

13

14| Dated: June 6, 2023 HYDEE FELDSTEIN SOTO, City Attorney

15

By:__/S/ Christian Fe Coporguez

16 CHRISTIAN R. BOJORQUEZ, DCA

17 Attorneys for Defendant CITY OF LOS ANGELES

18

19 | Dated: June 6, 2023 ORBACH HUFF + HENDERSON LLP

20 By: _ /S/ Kevin E. Gilbert

KEVIN E. GILBERT, ESQ.

CAROLYN M. AGUILAR, ESQ.

22 Attorneys for Defendants JESUS MARTINEZ and

KYLE GRIFFIN

23

24

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

25

DATED: __ June 9, 2023

27 HONORABLE STEVE KIM

28 United States Magistrate Judge

1G

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

6 that I have read in its entirety and understand the Stipulated Protective Order that

7 was issued by the United States District Court for the Central District of California

8 on [date] in the case of Maribel Murillo v. City of Los Angeles, et al, 2:22-cv-03188

9 DMB (SK). I agree to comply with and to be bound by all the terms of this

10 Stipulated Protective Order, and I understand and acknowledge that failure to so

11 comply could expose me to sanctions and punishment in the nature of contempt. I

12 solemnly promise that I will not disclose in any manner any information or item that

13 is subject to this Stipulated Protective Order to any person or entity except in strict

14 compliance with the provisions of this Order.

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

16 for the Central District of California for the purpose of enforcing the terms of this

17 Stipulated Protective Order, even if such enforcement proceedings occur after

18 termination of this action. I hereby appoint __________________________ [print

19 or type full name] of _______________________________________ [print or type

20 full address and telephone number] as my California agent for service of process in

21 connection with this action or any proceedings related to enforcement of this

22 Stipulated Protective Order.

23 Date: ______________________________________

24 City and State where sworn and signed: _________________________________

25

26 Printed name: _______________________________

27

28 Signature: __________________________________