Marco Diaz v. City of Los Angeles

1

2

3

4

5

6

7

UNITED STATES DISTRICT COURT

8

CENTRAL DISTRICT OF CALIFORNIA

9

10

MARCO DIAZ, an individual, CASE NO. 2:23-cv-01916-SPG-MAA

11 [Assigned to Judge Sherilyn Garnett, 1st Cthse, Ctrm 5C;

Plaintiff, Mag. Audero, USDC-Roybal Bldg, Ctrm 690]

12

v.

13

CITY OF LOS ANGELES, a [PROPOSED] STIPULATED

14 municipality; LAPD OFFICER PROTECTIVE ORDER

KELEIGH EDWARDS (#40564), an

15 individual; LAPD OFFICER

HERIBERTO CRISANTOS

16 GARCIA (#39541), an individual;

and DOES 1-10, inclusive,

17 individuals,

18 Defendants.

19

20 1. PURPOSES AND LIMITATIONS

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

22 proprietary, or private information for which special protection from public

23 disclosure and from use for any purpose other than prosecuting this litigation may

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

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

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

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

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

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

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

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

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

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

6

7 2. GOOD CAUSE STATEMENT

8 This action involves the City of Los Angeles and members of the Los Angeles

9 Police Department. Plaintiff is seeking materials and information that Defendants

10 the City of Los Angeles et al. (“City”) maintains as confidential, such as personnel

11 files of the police officers involved in this incident, Internal Affairs materials and

12 information, video recordings (including Body-Worn Video recordings and Digital

13 In-Car Video recordings), audio recordings, and information and other administrative

14 materials and information currently in the possession of the City and which the City

believes need special protection from public disclosure and from use for any purpose

15

other than prosecuting this litigation. Plaintiff is also seeking official information

16

contained in the personnel files of the police officers involved in the subject incident,

17

which the City maintains as strictly confidential and which the City believes need

18

special protection from public disclosure and from use for any purpose other than

19

prosecuting this litigation.

20

The City asserts that the confidentiality of the materials and information sought

21

by Plaintiff is recognized by California and federal law, as evidenced inter alia by

22

California Penal Code section 832.7 and Kerr v. United States Dist. Ct. for N.D. Cal.,

23

511 F.2d 192, 198 (9th Cir. 1975), aff'd, 426 U.S. 394 (1976). The City has not

24

publicly released the materials and information referenced above except under

25

protective order or pursuant to a court order, if at all. These materials and information

26

are of the type that has been used to initiate disciplinary action against Los Angeles

27

Police Department (“LAPD”) officers, and has been used as evidence in disciplinary

28

1 proceedings, where the officers’ conduct was considered to be contrary to LAPD

2 policy.

3 The City contends that absent a protective order delineating the responsibilities

4 of nondisclosure on the part of the parties hereto, there is a specific risk of

5 unnecessary and undue disclosure by one or more of the many attorneys, secretaries,

6 law clerks, paralegals and expert witnesses involved in this case, as well as the

7 corollary risk of embarrassment, harassment and professional and legal harm on the

part of the LAPD officers referenced in the materials and information.

8

The City also contends that the unfettered disclosure of the materials and

9

information, absent a protective order, would allow the media to share this

10

information with potential jurors in the area, impacting the rights of the City herein

11

to receive a fair trial.

12

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

13

resolution of disputes over confidentiality of discovery materials, to adequately

14

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

15

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

16

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

17

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

18

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

19

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

20

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

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

22

23

24 3. DEFINITIONS

25 3.1. Action: This pending federal lawsuit – Marco Diaz v. City of Los

26 Angeles, et al., Case No. 2:23-cv-01916-SPG-MAA.

27 3.2. Challenging Party: A Party or Nonparty that challenges the

28 designation of information or items under this Stipulated Protective

1 Order.

2 3.3. “CONFIDENTIAL” Information or Items: Information (regardless of

3 how it is generated, stored or maintained) or tangible things that

4 qualify for protection under Federal Rule of Civil Procedure 26(c), and

5 as specified above in the Good Cause Statement.

6 3.4. Counsel: Outside Counsel of Record and In-House Counsel (as well

7 as their support staff).

8 3.5. Designating Party: A Party or Nonparty that designates information or

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

10 “CONFIDENTIAL.”

11 3.6. Disclosure or Discovery Material: All items or information, regardless

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

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

14 tangible things), that is produced or generated in disclosures or

15 responses to discovery in this matter.

16 3.7. Expert: A person with specialized knowledge or experience in a

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

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

19 3.8. In-House Counsel: Attorneys who are employees of a party to this

20 Action. In-House Counsel does not include Outside Counsel of

21 Record or any other outside counsel.

22 3.9. Nonparty: Any natural person, partnership, corporation, association,

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

24 3.10. Outside Counsel of Record: Attorneys who are not employees of a

25 party to this Action but are retained to represent or advise a party to

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

27 are affiliated with a law firm which has appeared on behalf of that

28 party, and includes support staff.

1 3.11. Party: Any party to this Action, including all of its officers, directors,

2 employees, consultants, retained experts, In-House Counsel, and

3 Outside Counsel of Record (and their support staffs).

4 3.12. Producing Party: A Party or Nonparty that produces Disclosure or

5 Discovery Material in this Action.

6 3.13. Professional Vendors: Persons or entities that provide litigation

7 support services (e.g., photocopying, videotaping, translating,

8 preparing exhibits or demonstrations, and organizing, storing, or

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

10 subcontractors.

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

12 designated as “CONFIDENTIAL.”

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

14 Material from a Producing Party.

15 4. SCOPE

16 The protections conferred by this Stipulated Protective Order cover not only

17 Protected Material, but also (1) any information copied or extracted from Protected

18 Material; (2) all copies, excerpts, summaries, or compilations of Protected Material;

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

20 that might reveal Protected Material.

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

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

23 Material at trial.

24

25 5. DURATION

26 Once a case proceeds to trial, all of the information that was designated as

27 confidential or maintained pursuant to this Stipulated Protective Order and that is

28 introduced or admitted as an exhibit at trial becomes public and presumptively will

1 be available to all members of the public, including the press, unless compelling

2 reasons supported by specific factual findings to proceed otherwise are made to the

3 trial judge in advance of the trial. See Kamakana v. City and County of Honolulu,

4 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing “good cause” showing for

5 sealing documents produced in discovery from “compelling reasons” standard when

6 merits-related documents are part of court record). Accordingly, the terms of this

7 Stipulated Protective Order do not extend beyond the commencement of the trial as

8 to the CONFIDENTIAL information and materials introduced or admitted as an

9 exhibit at trial.

10

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

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

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

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

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

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

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

18 applications for extension of time pursuant to applicable law.

19

20 6. DESIGNATING PROTECTED MATERIAL

21 6.1. Exercise of Restraint and Care in Designating Material for Protection.

22 Each Party or Nonparty that designates information or items for

23 protection under this Stipulated Protective Order must take care to

24 limit any such designation to specific material that qualifies under the

25 appropriate standards. The Designating Party must designate for

26 protection only those parts of material, documents, items, or oral or

27 written communications that qualify so that other portions of the

28 material, documents, items, or communications for which protection is

1 not warranted are not swept unjustifiably within the ambit of this

2 Stipulated Protective Order.

3 Mass, indiscriminate, or routinized designations are prohibited.

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

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

6 case development process or to impose unnecessary expenses and

7 burdens on other parties) may expose the Designating Party to

8 sanctions.

9 6.2. Manner and Timing of Designations.

10 Except as otherwise provided in this Stipulated Protective Order

11 (see, e.g., Section 6.2(a)), or as otherwise stipulated or ordered,

12 Disclosure or Discovery Material that qualifies for protection under

13 this Stipulated Protective Order must be clearly so designated before

14 the material is disclosed or produced.

15 Designation in conformity with this Stipulated Protective Order

16 requires the following:

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

18 documents, but excluding transcripts of depositions or other

19 pretrial or trial proceedings), that the Producing Party affix at a

20 minimum, the legend “CONFIDENTIAL” to each page that

21 contains protected material. If only a portion or portions of the

22 material on a page qualifies for protection, the Producing Party

23 also must clearly identify the protected portion(s) (e.g., by

24 making appropriate markings in the margins).

25 A Party or Nonparty that makes original documents

26 available for inspection need not designate them for protection

27 until after the inspecting Party has indicated which documents it

28 would like copied and produced. During the inspection and

1 before the designation, all of the material made available for

2 inspection shall be deemed “CONFIDENTIAL.” After the

3 inspecting Party has identified the documents it wants copied

4 and produced, the Producing Party must determine which

5 documents, or portions thereof, qualify for protection under this

6 Stipulated Protective Order. Then, before producing the

7 specified documents, the Producing Party must affix the legend

8 “CONFIDENTIAL” to each page that contains Protected

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

10 qualifies for protection, the Producing Party also must clearly

11 identify the protected portion(s) (e.g., by making appropriate

12 markings in the margins).

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

14 identify the Disclosure or Discovery Material on the record,

15 before the close of the deposition, all protected testimony.

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

17 other tangible items, that the Producing Party affix in a

18 prominent place on the exterior of the container or containers in

19 which the information is stored the legend “CONFIDENTIAL.”

20 If only a portion or portions of the information warrants

21 protection, the Producing Party, to the extent practicable, shall

22 identify the protected portion(s).

23 6.3. Inadvertent Failure to Designate.

24 If timely corrected, an inadvertent failure to designate qualified

25 information or items does not, standing alone, waive the Designating

26 Party’s right to secure protection under this Stipulated Protective Order

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

28 Receiving Party must make reasonable efforts to assure that the

1 material is treated in accordance with the provisions of this Stipulated

2 Protective Order.

3

4 7. CHALLENGING CONFIDENTIALITY DESIGNATIONS

5 7.1. Timing of Challenges.

6 Any Party or Nonparty may challenge a designation of

7 confidentiality at any time that is consistent with the Court’s

8 Scheduling Order.

9 7.2. Meet and Confer.

10 The Challenging Party shall initiate the dispute resolution

11 process, which shall comply with Local Rule 37.1 et seq., and with

12 Section 4 of Judge Audero’s Procedures (“Mandatory Telephonic

13 Conference for Discovery Disputes”).1

14 7.3. Burden of Persuasion.

15 The burden of persuasion in any such challenge proceeding shall

16 be on the Designating Party. Frivolous challenges, and those made for

17 an improper purpose (e.g., to harass or impose unnecessary expenses

18 and burdens on other parties) may expose the Challenging Party to

19 sanctions. Unless the Designating Party has waived or withdrawn the

20 confidentiality designation, all parties shall continue to afford the

21 material in question the level of protection to which it is entitled under

22 the Producing Party’s designation until the Court rules on the

23 challenge.

24

25 8. ACCESS TO AND USE OF PROTECTED MATERIALS

26

27

1 Judge Audero’s Procedures are available at

28 https://www.cacd.uscourts.gov/honorable-maria-audero.

1 8.1. Basic Principles.

2 A Receiving Party may use Protected Material that is disclosed

3 or produced by another Party or by a Nonparty in connection with this

4 Action only for prosecuting, defending, or attempting to settle this

5 Action. Such Protected Material may be disclosed only to the

6 categories of persons and under the conditions described in this

7 Stipulated Protective Order. When the Action reaches a final

8 disposition, a Receiving Party must comply with the provisions of

9 Section 14 below.

10 Protected Material must be stored and maintained by a

11 Receiving Party at a location and in a secure manner that ensures that

12 access is limited to the persons authorized under this Stipulated

13 Protective Order.

14 8.2. Disclosure of “CONFIDENTIAL” Information or Items.

15 Unless otherwise ordered by the Court or permitted in writing

16 by the Designating Party, a Receiving Party may disclose any

17 information or item designated “CONFIDENTIAL” only to:

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

19 employees of said Outside Counsel of Record to whom it is

20 reasonably necessary to disclose the information for this Action;

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

22 Counsel) of the Receiving Party to whom disclosure is

23 reasonably necessary for this Action;

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

25 necessary for this Action and who have signed the

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

27 (d) The Court and its personnel;

28 (e) Court reporters and their staff;

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

2 Professional Vendors to whom disclosure is reasonably

3 necessary or this Action and who have signed the

4 “Acknowledgment and Agreement to be Bound” (Exhibit A);

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

6 information or a custodian or other person who otherwise

7 possessed or knew the information;

8 (h) During their depositions, witnesses, and attorneys for witnesses,

9 in the Action to whom disclosure is reasonably necessary

10 provided: (i) the deposing party requests that the witness sign

11 the “Acknowledgment and Agreement to Be Bound” (Exhibit

12 A); and (ii) the witness will not be permitted to keep any

13 confidential information unless they sign the “Acknowledgment

14 and Agreement to Be Bound,” unless otherwise agreed by the

15 Designating Party or ordered by the Court. Pages of transcribed

16 deposition testimony or exhibits to depositions that reveal

17 Protected Material may be separately bound by the court

18 reporter and may not be disclosed to anyone except as permitted

19 under this Stipulated Protective Order; and

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

21 personnel, mutually agreed upon by any of the parties engaged

22 in settlement discussions.

23 8.3. Counsel making the disclosure to any qualified person described

24 herein shall retain the original executed copy of the Nondisclosure Agreement until

25 sixty (60) days after this litigation has become final, including any appellate review,

26 and monitoring of an injunction. Counsel for the Receiving Party shall maintain all

27 signed Nondisclosure Agreements and shall produce the original signature page

28 upon reasonable written notice from opposing counsel. If an issue arises regarding

1 a purported unauthorized disclosure of Confidential Information, upon noticed

2 motion of contempt filed by the Designating Party, counsel for the Receiving Party

3 may be required to file the signed Nondisclosure Agreements, as well as a list of the

4 disclosed materials, in camera with the Court having jurisdiction of the Stipulation.

5 9. PROTECTED MATERIAL SUBPOENAED OR ORDERED

6 PRODUCED IN OTHER LITIGATION

7 If a Party is served with a subpoena or a court order issued in other litigation

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

9 “CONFIDENTIAL,” that Party must:

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

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

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

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

14 by the subpoena or order is subject to this Stipulated Protective Order.

15 Such notification shall include a copy of this Stipulated Protective

16 Order; and

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

18 pursued by the Designating Party whose Protected Material may be

19 affected.

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

21 information designated in this action as “CONFIDENTIAL” before a determination

22 by the Court from which the subpoena or order issued, unless the Party has

23 obtained the Designating Party’s permission. The Designating Party shall bear the

24 burden and expense of seeking protection in that court of its confidential material

25 and nothing in these provisions should be construed as authorizing or encouraging a

26 Receiving Party in this Action to disobey a lawful directive from another court.

27

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

1 PRODUCED IN THIS LITIGATION

2 10.1. Application.

3 The terms of this Stipulated Protective Order are applicable to

4 information produced by a Nonparty in this Action and designated as

5 “CONFIDENTIAL.” Such information produced by Nonparties in

6 connection with this litigation is protected by the remedies and relief

7 provided by this Stipulated Protective Order. Nothing in these

8 provisions should be construed as prohibiting a Nonparty from seeking

9 additional protections.

10 10.2. Notification.

11 In the event that a Party is required, by a valid discovery

12 request, to produce a Nonparty’s confidential information in its

13 possession, and the Party is subject to an agreement with the Nonparty

14 not to produce the Nonparty’s confidential information, then the Party

15 shall:

16 (a) Promptly notify in writing the Requesting Party and the

17 Nonparty that some or all of the information requested is subject

18 to a confidentiality agreement with a Nonparty;

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

20 Protective Order in this Action, the relevant discovery

21 request(s), and a reasonably specific description of the

22 information requested; and

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

24 Nonparty, if requested.

25 10.3. Conditions of Production.

26 If the Nonparty fails to seek a protective order from this Court

27 within fourteen (14) days after receiving the notice and accompanying

28 information, the Receiving Party may produce the Nonparty’s

1 confidential information responsive to the discovery request. If the

2 Nonparty timely seeks a protective order, the Receiving Party shall not

3 produce any information in its possession or control that is subject to

4 the confidentiality agreement with the Nonparty before a

5 determination by the Court. Absent a court order to the contrary, the

6 Nonparty shall bear the burden and expense of seeking protection in

7 this Court of its Protected Material.

8

9 11. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

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

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

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

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

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

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

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

18 12. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

19 PROTECTED MATERIAL

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

21 inadvertently produced material is subject to a claim of privilege or other

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

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

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

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

26 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure

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

28 product protection, the parties may incorporate their agreement in the Stipulated

1 Protective Order submitted to the Court.

2

3 13. MISCELLANEOUS

4 13.1. Right to Further Relief.

5 Nothing in this Stipulated Protective Order abridges the right of

6 any person to seek its modification by the Court in the future.

7 13.2. Right to Assert Other Objections.

8 By stipulating to the entry of this Stipulated Protective Order, no

9 Party waives any right it otherwise would have to object to disclosing

10 or producing any information or item on any ground not addressed in

11 this Stipulated Protective Order. Similarly, no Party waives any right

12 to object on any ground to use in evidence of any of the material

13 covered by this Stipulated Protective Order.

14 13.3. Filing Protected Material.

15 A Party that seeks to file under seal any Protected Material must

16 comply with Local Rule 79-5. Protected Material may only be filed

17 under seal pursuant to a court order authorizing the sealing of the

18 specific Protected Material at issue. If a Party's request to file

19 Protected Material under seal is denied by the Court, then the

20 Receiving Party may file the information in the public record unless

21 otherwise instructed by the Court.

22

23 14. FINAL DISPOSITION

24 After the final disposition of this Action, as defined in Section 5, supra,

25 within sixty (60) days of a written request by the Designating Party, each Receiving

26 Party must return all Protected Material to the Producing Party or destroy such

27 material. As used in this subdivision, “all Protected Material” includes all copies,

28 abstracts, compilations, summaries, and any other format reproducing or capturing

1 any of the Protected Material. Whether the Protected Material is returned or

2 destroyed, the Receiving Party must submit a written certification to the Producing

3 Party (and, if not the same person or entity, to the Designating Party) by the 60-day

4 deadline that (1) identifies (by category, where appropriate) all the Protected

5 Material that was returned or destroyed and (2) affirms that the Receiving Party has

6 not retained any copies, abstracts, compilations, summaries or any other format

7 reproducing or capturing any of the Protected Material. Notwithstanding this

8 provision, Counsel is entitled to retain an archival copy of all pleadings; motion

9 papers; trial, deposition, and hearing transcripts; legal memoranda; correspondence;

10 deposition and trial exhibits; expert reports; attorney work product; and consultant

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

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

13 this Stipulated Protective Order as set forth in Section 5.

14 15. VIOLATION

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

16 appropriate measures including, without limitation, contempt proceedings and/or

17 monetary sanctions.

18

19 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

20 Dated: LAW OFFICES OF CHRISTIAN CONTRERAS

21 A PROFESSIONAL LAW CORPORATION

22 By: /s/ Christian Contreras

23 CHRISTIAN CONTRERAS, ESQ.

Attorneys for Plaintiffs

24

25

Dated: October 30, 2023 Respectfully submitted,

26

27 HYDEE FELDSTEIN SOTO, City Attorney

DENISE C. MILLS, Chief Deputy City Attorney

28

1 SCOTT MARCUS, Chief Asst. City Attorney

CORY M. BRENTE, Senior Assistant City Attorney

2

3 By: Ty A. Ford

TY A. FORD, Deputy City Attorney

4

Attorneys for Defendants, CITY OF LOS ANGELES,

5 KELEIGH EDWARDS and HERIBERTO

CRISANTOS GARCIA

6

7 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

8

November 1, 2023

9 Dated:

Maria A. Audero

10

United States Magistrate Judge

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

1 EXHIBIT A

2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3 I, [full name], of

4 [address], declare under penalty of perjury that I have read in its

5 entirety and understand the Stipulated Protective Order that was issued by the

6 United States District Court for the Central District of California on

7 [date] in the case of Marco Diaz v. City of Los Angeles, et al., Case No. 2:23-cv-

8 01916-SPG-MAA. I agree to comply with and to be bound by all the terms of this

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

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

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

12 that is subject to this Stipulated Protective Order to any person or entity except in

13 strict compliance with the provisions of this Stipulated Protective Order.

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

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

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

17 termination of this action. I hereby appoint [full name]

18 of [address and telephone number]

19 as my California agent for service of process in connection with this action or any

20 proceedings related to enforcement of this Stipulated Protective Order.

21

22 Signature:

23 Printed Name:

24 Date:

25 City and State Where Sworn and Signed:

26

27

28