Emmitt Bryant v. City of Los Angeles

1 HYDEE FELDSTEIN SOTO, City Attorney 2 DENISE C. MILLS, Chief Deputy City Attorney KATHLEEN KENEALY, Chief Assistant City Attorney 3 CHRISTIAN R. BOJORQUEZ, Deputy City Attorney 4 ERIN CHOI, Deputy City Attorney (SBN 342323) 200 North Main Street, 6th Floor, City Hall East 5 Los Angeles, CA 90012 6 Tel.: (213) 202-5429 | Fax: (213) 978-8785 7 E-mail: erin.choi@lacity.org 8 Attorneys for Defendants 9 CITY OF LOS ANGELES, OFFICER JORDAN T. PATTON, and OFFICER LUIS A. MEDINA 10 11 UNITED STATES DISTRICT COURT 12 CENTRAL DISTRICT OF CALIFORNIA 13 14 EMMITT BRYANT Case No. 2:25−cv−07237−SSC 15 Plaintiff(s), v. 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 20 Defendant(s). 21 22 23 1. INTRODUCTION 24 1.1 Purposes and Limitations. Discovery in this action is likely to 25 involve production of confidential, proprietary, or private information for 26 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. 8 1.2 Good Cause Statement. 9 In light of the nature of the claims and allegations in this case and 10 the parties’ representations that discovery in this case may involve the 11 production of confidential records, and including but not limited to 12 employment/personnel records, information of individually named 13 Defendants and/or other employees of the City, information otherwise 14 generally unavailable to the public, or which may be privileged or 15 otherwise protected from disclosure under state or federal statutes, court 16 rules, case decisions, or common law. 17 Defendants maintain as confidential such as personnel files of the 18 peace officer(s) involved in this incident, Internal Affairs materials and 19 information, video recordings, audio recordings, photographs, and 20 information and other administrative materials and information 21 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. 8 Further, discovery may require depositions, written discovery 9 and/or the production of certain information the public disclosure of 10 which could compromise officer safety, and/or raise security issues. 11 Additionally, public disclosure of such information poses a substantial 12 risk of embarrassment, oppression, and/or physical harm to peace 13 officers whose confidential information is disclosed. The risk of harm to 14 peace officers is greater than the risk of harm to other government 15 employees, due to the nature of their profession. The benefit of public 16 disclosure of confidential information is minimal while the potential 17 disadvantages are great. Defendants also contend that the unfettered 18 disclosure of the materials and information, absent a Protective Order, 19 would allow the media to share this information with potential jurors in 20 the area, impacting the rights of Defendants herein to receive a fair trial. 21 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 8 Stipulated Protective Order does not entitle them to file confidential 9 information under seal; Local Rule 79-5 sets forth the procedures that 10 must be followed and the standards that will be applied when a party 11 seeks permission from the court to file material under seal. 12 There is a strong presumption that the public has a right of access 13 to judicial proceedings and records in civil cases. In connection with 14 non-dispositive motions, good cause must be shown to support a filing 15 under seal. See Kamakana v. City and Cnty. of Honolulu, 447 F.3d 16 1172, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd v. Gen. Motors 17 Corp., 307 F.3d 1206, 1210–11 (9th Cir. 2002), Makar-Welbon v. Sony 18 Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated 19 protective orders require good cause showing), and a specific showing of 20 good cause or compelling reasons with proper evidentiary support and 21 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 8 facts and legal justification, for the requested sealing order. Again, 9 competent evidence supporting the application to file documents under 10 seal must be provided by declaration. 11 Any document that is not confidential, privileged, or otherwise 12 protectable in its entirety will not be filed under seal if the confidential 13 portions can be redacted. If documents can be redacted, then a redacted 14 version for public viewing, omitting only the confidential, privileged, or 15 otherwise protectable portions of the document, shall be filed. Any 16 application that seeks to file documents under seal in their entirety 17 should include an explanation of why redaction is not feasible. 18 19 2. DEFINITIONS 20 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 27 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, 8 regardless of the medium or manner in which it is generated, stored, or 9 maintained (including, among other things, testimony, transcripts, and 10 tangible things), that are produced or generated in disclosures or 11 responses to discovery in this matter. 12 2.7 Expert: a person with specialized knowledge or experience in 13 a matter pertinent to the litigation who has been retained by a Party or 14 its counsel to serve as an expert witness or as a consultant in this Action. 15 2.8 Final Disposition: the later of (1) dismissal of all claims and 16 defenses in this Action, with or without prejudice; and (2) final judgment 17 herein after the completion and exhaustion of all appeals, rehearings, 18 remands, trials, or reviews of this Action, including the time limits for 19 filing any motions or applications for extension of time pursuant to 20 applicable law. 21 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 8 Disclosure or Discovery Material in this Action. 9 2.14 Professional Vendors: persons or entities that provide 10 litigation- support services (e.g., photocopying, videotaping, translating, 11 preparing exhibits or demonstrations, and organizing, storing, or 12 retrieving data in any form or medium) and their employees and 13 subcontractors. 14 2.15 Protected Material: any Disclosure or Discovery Material that 15 is designated as “CONFIDENTIAL.” 16 2.16 Receiving Party: a Party that receives Disclosure or Discovery 17 Material from a Producing Party. 18 19 3. SCOPE 20 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. 27 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. 4 5 4. TRIAL AND DURATION 6 The terms of this Stipulated Protective Order apply through Final 7 Disposition of the Action. 8 Once a case proceeds to trial, information that was designated as 9 CONFIDENTIAL or maintained pursuant to this Stipulated Protective 10 Order and used or introduced as an exhibit at trial becomes public and 11 will be presumptively available to all members of the public, including 12 the press, unless compelling reasons supported by specific factual 13 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 23 effect until a Designating Party agrees otherwise in writing or a court 24 order otherwise directs. 25 26 5. DESIGNATING PROTECTED MATERIAL 27 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 8 warranted are not swept unjustifiably within the ambit of this Order. 9 Mass, indiscriminate, or routinized designations are prohibited. 10 Designations that are shown to be clearly unjustified or that have been 11 made for an improper purpose (e.g., to unnecessarily encumber the case 12 development process or to impose unnecessary expenses and burdens on 13 other parties) may expose the Designating Party to sanctions. 14 If it comes to a Designating Party’s attention that information or 15 items that it designated for protection do not qualify for protection, that 16 Designating Party must promptly notify all other Parties that it is 17 withdrawing the inapplicable designation. 18 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: 27 (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). 8 A Party or Non-Party that makes original documents available for 9 inspection need not designate them for protection until after the 10 inspecting Party has indicated which documents it would like copied 11 and produced. During the inspection and before the designation, all of 12 the material made available for inspection shall be deemed 13 CONFIDENTIAL. After the inspecting Party has identified the 14 documents it wants copied and produced, the Producing Party must 15 determine which documents, or portions thereof, qualify for protection 16 under this Stipulated Protective Order. Then, before producing the 17 specified documents, the Producing Party must affix the 18 “CONFIDENTIAL” legend to each page that contains Protected 19 Material. If only a portion or portions of the material on a page 20 qualifies for protection, the Producing Party also must clearly identify 21 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). 6 5.3 Inadvertent Failures to Designate. If timely corrected, an 7 inadvertent failure to designate qualified information or items does not, 8 standing alone, waive the Designating Party’s right to secure protection 9 under this Order for such material. Upon timely correction of a 10 designation, the Receiving Party must make reasonable efforts to assure 11 that the material is treated in accordance with the provisions of this 12 Stipulated Protective Order. 13 14 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 15 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 23 6.3 The burden of persuasion in any such challenge proceeding 24 shall be on the Designating Party. Frivolous challenges, and those 25 made for an improper purpose (e.g., to harass or impose unnecessary 26 27 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 8 7. ACCESS TO AND USE OF PROTECTED MATERIAL 9 7.1 Basic Principles. A Receiving Party may use Protected 10 Material that is disclosed or produced by another Party or by a Non- 11 Party in connection with this Action only for prosecuting, defending, or 12 attempting to settle this Action. Such Protected Material may be 13 disclosed only to the categories of persons and under the conditions 14 described in this Order. When the Action reaches a Final Disposition, a 15 Receiving Party must comply with the provisions of section 13 below. 16 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 26 Action, as well as employees of said Outside Counsel of Record to whom 27 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; 8 (e) to court reporters and their staff; 9 (f) to professional jury or trial consultants, mock jurors, and 10 Professional Vendors to whom disclosure is reasonably necessary for 11 this Action and who have signed the “Acknowledgment and Agreement 12 to Be Bound” (Exhibit A); 13 (g) to the author or recipient of a document containing the 14 information or a custodian or other person who otherwise possessed or 15 knew the information; 16 (h) during their depositions, to witnesses, and attorneys for 17 witnesses, in the Action to whom disclosure is reasonably necessary, 18 provided: (1) the deposing party requests that the witness sign the 19 “Acknowledgment and Agreement to Be Bound” (Exhibit A); and (2) the 20 witness will not be permitted to keep any confidential information 21 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. 3 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 8 designated in this Action as “CONFIDENTIAL,” that Party must: 9 (a) promptly notify in writing the Designating Party. Such 10 notification shall include a copy of the subpoena or court order; 11 (b) promptly notify in writing the party who caused the 12 subpoena or order to issue in the other litigation that some or all of the 13 material covered by the subpoena or order is subject to this Protective 14 Order. Such notification shall include a copy of this Stipulated 15 Protective Order; and 16 (c) cooperate with respect to all reasonable procedures sought to 17 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 27 provisions should be construed as authorizing or encouraging a 1 Receiving Party in this Action to disobey a lawful directive from another 2 court. 3 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 8 designated as “CONFIDENTIAL.” Such information produced by Non- 9 Parties in connection with this litigation is protected by the remedies 10 and relief provided by this Order. Nothing in these provisions should be 11 construed as prohibiting a Non-Party from seeking additional 12 protections. 13 9.2 Notification. In the event that a Party is required, by a valid 14 discovery request, to produce a Non-Party’s confidential information in 15 its possession, and the Party is subject to an agreement with the Non- 16 Party not to produce the Non-Party’s confidential information, then the 17 Party shall: 18 (a) promptly notify in writing the Requesting Party and the 19 Non-Party that some or all of the information requested is subject to a 20 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. 6 7 10. UNAUTHORIZED DISCLOSURE OF PROTECTED 8 MATERIAL 9 If a Receiving Party learns that, by inadvertence or otherwise, it 10 has disclosed Protected Material to any person or in any circumstance 11 not authorized under this Stipulated Protective Order, the Receiving 12 Party must immediately (a) notify in writing the Designating Party of 13 the unauthorized disclosures, (b) use its best efforts to retrieve all 14 unauthorized copies of the Protected Material, (c) inform the person or 15 persons to whom unauthorized disclosures were made of all the terms of 16 17 this Order, and (d) request such person or persons to execute the 18 “Acknowledgment and Agreement to Be Bound” (Exhibit A). 19 20 11. INADVERTENT PRODUCTION OF PRIVILEGED OR 21 OTHERWISE PROTECTED MATERIAL 22 When a Producing Party gives notice to Receiving Parties that 23 certain inadvertently produced material is subject to a claim of privilege 24 or other protection, the obligations of the Receiving Parties are those set 25 forth in Rule 26(b)(5)(B) of the Federal Rules of Civil Procedure. This 26 provision is not intended to modify whatever procedure may be 27 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. 7 8 12. MISCELLANEOUS 9 12.1 Right to Further Relief. Nothing in this Stipulated 10 Protective Order abridges the right of any person to seek its 11 modification by the court in the future. 12 12.2 Right to Assert Other Objections. By stipulating to the entry 13 of this Stipulated Protective Order no Party waives any right it 14 otherwise would have to object to disclosing or producing any 15 information or item on any ground not addressed in this Stipulated 16 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 26 record unless otherwise instructed by the court. 27 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 4 Receiving Party must return all Protected Material to the Producing 5 Party or destroy such material. As used in this subdivision, “all 6 Protected Material” includes all copies, abstracts, compilations, 7 summaries, and any other format reproducing or capturing any of the 8 Protected Material. Whether the Protected Material is returned or 9 destroyed, the Receiving Party must submit a written certification to 10 the Producing Party (and, if not the same person or entity, to the 11 Designating Party) by the 60 day deadline that (1) identifies (by 12 category, where appropriate) all the Protected Material that was 13 returned or destroyed and (2) affirms that the Receiving Party has not 14 retained any copies, abstracts, compilations, summaries or any other 15 format reproducing or capturing any of the Protected Material. 16 Notwithstanding this provision, Counsel is entitled to retain an archival 17 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. 24 25 26 27 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. 5 6 || IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 7 ll Dated: June 18,2026 PLC LAW GROUP, APC 8 /s/Lauren K.McRae ? PETER L. CARR, IV, ESQ. 10 NA’SHAUN L. NEAL, ESQ. LAUREN K. MCRAE, ESQ. 1] 2 Attorneys for Plaintiff, EMMITT BRYANT 13 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 21 22 33 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 24 25 DATED: June 18, 2026 STEPHANIE S. CHRISTENSEN 7 United States Magistrate Judge 28 1 EXHIBIT A ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 2 3 I, ________________________ [print or type full name], of 4 _________________ [print or type full address], declare under 5 penalty of perjury that I have read in its entirety and understand the 6 Stipulated Protective Order that was issued by the United States 7 District Court for the Central District of California on [date] in the 8 case of Emmitt Bryant v. City of Los Angeles, et al., Case No. 9 2:25−cv−07237−SSC. I agree to comply with and to be bound by all the 10 terms of this Stipulated Protective Order and I understand and 11 acknowledge that failure to so comply could expose me to sanctions 12 and punishment in the nature of contempt. I solemnly promise that I 13 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 23 24 25 26 27 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. 4 5 Date: ___________________________ 6 City and State where sworn and 7 signed: ___________________________ 8 Printed name: ___________________________ 9 Signature: ___________________________ 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27