STIPULATION REGARDING THE FOUNDATION OF EXHIBITS AND ORDER

TROY L. NUNLEY, District Judge.

Plaintiffs, Estate of Johnathan Rose, by and through his parents Theodore Milton Rose and Karen Rose, as successors in interest, Theodore Milton Rose, individually, and Karen Rose, individually, are represented by Stewart Katz of the Law Office of Stewart Katz, Moseley C. Collins, III of the Law Office of Moseley C. Collins, III and Dale K Galipo of the Law Office of Dale K. Galipo. Defendants County of Sacramento and David McEntire ("Defendants") are represented by Van Longyear and Peter Zilaff of Longyear, O'Dea & Lavra, LLP.

For the purposes of reducing trial testimony, the parties through their respective attorneys stipulate to the foundation, although not the admissibility, of the following documents. The parties reserve all other objections to the evidence.

1. Each of the photographs included in the parties' trial exhibits lists depicting and described as the Plaintiffs' house exterior, interior and surrounding street, marked by bates stamps CO_000306-CO000891, were taken by Sacramento Sheriff's Department Crime Scene Investigators on the night of January 17 and morning of January 18, 2012 and accurately depict the scene inside and surrounding the Plaintiffs' house as it appeared at that time.

2. The videos included in Defendants' trial exhibit list depicting and described as the Rose home interior and exterior, marked by bates stamps CO_001037-CO_001038, were recorded by Sacramento Sheriff's Department Crime Scene Investigators on the night of January 17 and morning of January 18, 2012 and accurately depict the scene inside and surrounding the Plaintiffs' house as it appeared at that time.

3. Each of the photographs included in the parties' trial exhibits lists depicting and described as the photographs of Deputy David McEntire, marked by bates stamps CO_000279 — CO_000305, were taken by Sacramento Sheriff's Department Crime Scene Investigators the night of January 17, 2012 and accurately depict Deputy McEntire as he appeared at that time.

4. Each of the photographs included in the parties' trial exhibits lists depicting and described as the photographs of Deputy David McEntire, marked by bates stamps CO_000715 — CO_000748, were taken by Sacramento Sheriff's Department Crime Scene Investigators the early morning of January 18, 2012 and accurately depict Deputy McEntire as he appeared at that time.

5. Each of the photographs included in the parties' trial exhibits lists depicting and described as the photographs of Deputy David McEntire, marked by bates stamps CO_000940-000971 and CO_001000 — CO_001031, were taken by Sacramento Sheriff's Department Crime Scene Investigators on January 19, 2012 and accurately depict Deputy McEntire as he appeared at that time.

6. Each of the photographs included in the parties' trial exhibits lists depicting and described as the photographs of Johnathan Rose in the Mercy San Juan Hospital operating room, marked by bates stamps CO_000972-000987, were taken by Sacramento Sheriff's Department Crime Scene Investigators on January 17, 2012 and accurately depict Johnathan Rose as he appeared at that time.

7. Each of the photographs included in the parties' trial exhibits lists depicting and described as the photographs of Johnathan Rose during his autopsy by the Sacramento County Department of Coroner, marked by bates stamps CO_001059-001140, were taken on January 19, 2012 and accurately depict Johnathan Rose as he appeared at that time.

8. The photographs, listed as Plaintiffs' exhibits numbers 73-78, are photographs of Johnathan Rose that accurately depict him at the time taken.

9. Each of the photographs included in the parties' trial exhibits lists depicting and described as the photographs of Deputy David McEntire's duty belt and contents, marked by bates stamps CO_000892-CO_000939 and CO_000988-000999, were taken on January 18 and 19, 2012 and accurately depict the duty belt and contents as they appeared at that time.

10. The exhibit, identified by parties with bates stamps CO_000096-97, is a diagram and corresponding legend prepared by Sacramento Sheriff's Department Crime Scene Investigators and depicts the living and dining area of the Plaintiffs' house on the night of January 17, 2012. The parties agree that the diagram is not to scale.

11. The exhibit, identified by bates stamp CO_001036, is an accurate copy of the recorded portion of the interview by Sacramento Sheriffs' Department Detective Robert Tracy of the Plaintiffs Theodore Milton Rose and Karen Rose, and their adult children Theodore and Tiffany Rose, recorded in the early morning hours of January 18, 2012.

12. The exhibit, identified by bates stamp CO_001141, is an accurate recording of Plaintiff Theodore Milton Rose's telephone call with 911 dispatchers on the night of January 17, 2012. The exhibits, listed by Defendants as Exhibits "Q1" and "Q2," are audio enhanced copies of Plaintiff Theodore Milton Rose's telephone call with 911 dispatchers on the night of January 17, 2012.

13. The exhibits, identified by bates stamps CO_001033 and CO_001034 (video and audio, respectively), are accurate recordings of the statement by Deputy David McEntire provided to Sacramento Sheriff's Department Detective Brian Meux in the early morning of January 18, 2012.

IT IS HEREBY STIPULATED.

IT IS SO ORDERED.