Opinion

Estate of Jess Flores v. County of Riverside

Court: District Court, C.D. California
Filed: Mar 11, 2025
Cited by: 0 cases
Authority: More cited than 34.4%

distinguishing “good cause” 12 showing for sealing documents produced in discovery from “compelling reasons” 13 standard when merits-related documents are part of court record

How later courts described this case

distinguishing “good cause” 12 showing for sealing documents produced in discovery from “compelling reasons” 13 standard when merits-related documents are part of court record
a party’s privacy rights are to be protected 24 through a “carefully crafted protective order.”

Written by the judges who cited it.

The opinion

1 Denisse O. Gastélum, SBN 282771 Christian Contreras, SBN 330269

2 Selene Estrada-Villela, SBN 354994 LAW OFFICES OF CHRISTIAN CONTRERAS

GASTÉLUM LAW, APC PROFESSIONAL LAW CORPORATION

3 A PROFESSIONAL CORPORATION 360 E. 2nd St., 8th Floor

3767 Worsham Ave. Los Angeles, California 90012

4 Long Beach, California 90808 Tel: (323) 435-8000

Tel: (213) 340-6112 Fax: (323) 597-0101

5 Fax: (213) 402-8622 Email: CC@Contreras-Law.com

Email: dgastelum@gastelumfirm.com

7 Attorneys for Plaintiffs,

ESTATE OF JESS FLORES, by and through successors in interest, M.F., R.F., and

8 S.F.; M.F., a minor, by and through Guardian Ad Litem, Justine Flores; R.F., a minor,

by and through Guardian Ad Litem, Justine Flores; S.F., a minor, by and through

9 Guardian Ad Litem, Lydia Arzola; JESS R. FLORES, JR., individually; and

DEBORAH ANN JACOBS, individually

UNITED STATES DISTRICT COURT

THE CENTRAL DISTRICT OF CALIFORNIA

13 ESTATE OF JESS FLORES, by and ) CASE NO. 5:24−cv−01933−KK−SHK

through successors in interest, M.F., ) [Assigned to the Hon. Kenly Kiya Kato,

14 R.F., and S.F.; M.F., a minor, by and ) District Judge; Referred to the Hon. Shashi

through Guardian Ad Litem, Justine ) H. Kewalramani, Magistrate Judge]

15 Flores; R.F., a minor, by and through )

Guardian Ad Litem, Justine Flores; )

16 S.F., a minor, by and through Guardian )

Ad Litem, Lydia Arzola; JESS R. ) STIPULATED PROTECTIVE ORDER

17 FLORES, JR., individually; and )

DEBORAH ANN JACOBS, )

18 individually, )

Plaintiffs, )

19 )

v. )

20 )

COUNTY OF RIVERSIDE, a public )

21 entity; RIVERSIDE COUNTY )

SHERIFF’S DEPARTMENT; )

22 SHERIFF CHAD BIANCO, in his )

individual and official capacities; )

23 EDWARD DELGADO; JAMES )

KRACHMER; DAVID HOLM; DOES )

24 1 through 10, individually, jointly and )

severally, )

25 )

Defendants. )

26 )

)

27 )

1 1. A. PURPOSES AND LIMITATIONS

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

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

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

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

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

does not confer blanket protections on all disclosures or responses to discovery and

that the protection it affords from public disclosure and use extends only to the limited

information or items that are entitled to confidential treatment under the applicable

legal principles. The parties further acknowledge, as set forth in Section 12.3, below,

that this Stipulated Protective Order does not entitle them to a file confidential

information under seal; Civil Local Rule 79-5 sets forth the procedures that must be

followed and the standards that will be applied when a party seeks permission from

the court to file material under seal.

B. GOOD CAUSE STATEMENT

15 Plaintiffs and the individual Defendants may produce certain documents in this

16 case that contain personal medical, employment or financial information. Such

17 information may implicate the privacy interests of the party and are properly

18 protected through a Fed. R. Civ. P. 26(c) protective order. Seattle Times Co. v.

19 Rhinehart, 467 U.S. 20, 35 n.21 (1984) (“Rule 26(c) includes among its express

20 purposes the protection of a ‘party or person from annoyance, embarrassment,

21 oppression or undue burden or expense.’ Although the Rule contains no specific

22 reference to privacy or to other rights or interests that may be implicated, such matters

are implicit in the broad purpose and language of the Rule.”); Soto v. City of Concord,

162 F.R.D. 603, 617 (N.D. Cal. 1995) (a party’s privacy rights are to be protected

through a “carefully crafted protective order.”).

In light of the nature of the claims and allegations in this case and the parties’

representations that discovery in this case will involve the production of confidential

records, including but not limited to sensitive operational documents (including

1 information of individually named Defendants and/or other employees of the County,

2 as well as Mr. Jess Flores’ medical and mental health information, pre-incident

treatment records containing private and sensitive information pertaining to Mr.

Flores, and private and sensitive documents referencing past criminal history as it

relates to the claims and defenses in this action. The disclosure of the foregoing

information to non-parties or others would be harmful to the parties' interests,

including Plaintiffs. Therefore, this information must be protected. The parties shall

not designate any information/documents as confidential without a good faith belief

that such information/documents have been maintained in a confidential, non-public

manner, and that there is good cause or a compelling reason why it should not be part

of the public record of this case.

2. DEFINITIONS

2.1 Action: This pending federal law suit, Estate of Jess Flores, et al. v.

County of Riverside, et al.; Case No. 5:24−cv−01933−KK−SHK.

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

of information or items under this Order.

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

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

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

Good Cause Statement.

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

their support staff).

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

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

“CONFIDENTIAL.”

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

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

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

1 2.7 Expert: a person with specialized knowledge or experience in a matter

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

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

4 2.8 House Counsel: attorneys who are employees of a party to this Action.

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

6 counsel.

7 2.9 Non-Party: any natural person, partnership, corporation, association, or

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

9 2.10 Outside Counsel of Record: attorneys who are not employees of a party

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

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

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

13 2.11 Party: any party to this Action, including all of its officers, directors,

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

15 support staffs).

16 2.12 Producing Party: a Party or Non-Party that produces Disclosure or

17 Discovery Material in this Action.

18 2.13 Professional Vendors: persons or entities that provide litigation support

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

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

21 and their employees and subcontractors.

22 2.14 Protected Material: any Disclosure or Discovery Material that is

23 designated as “CONFIDENTIAL.”

24 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material

25 from a Producing Party.

26 3. SCOPE

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

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

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

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

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

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

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

4. DURATION

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

confidential or maintained pursuant to this protective order becomes public and will

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

compelling reasons supported by specific factual findings to proceed otherwise are

made to the trial judge in advance of the trial. See Kamakana v. City and County of

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

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

standard when merits-related documents are part of court record). Accordingly, the

terms of this protective order do not extend beyond the commencement of the trial.

5. DESIGNATING PROTECTED MATERIAL

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, items,

22 or communications for which protection is not warranted are not swept unjustifiably

23 within the ambit of this Order.

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

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

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

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

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

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

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

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

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

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

produced.

Designation in conformity with this Order requires:

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

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

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

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

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

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

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

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

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

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

19 and before the designation, all of the material made available for inspection shall be

20 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents

21 it wants copied and produced, the Producing Party must determine which documents,

22 or portions thereof, qualify for protection under this Order. Then, before producing

23 the specified documents, the Producing Party must affix the “CONFIDENTIAL

24 legend” to each page that contains Protected Material. If only a portion or portions of

25 the material on a page qualifies for protection, the Producing Party also must clearly

26 identify the protected portion(s) (e.g., by making appropriate markings in the

margins). Markings added to documents pursuant to this paragraph shall not obscure

the content or text of the documents produced.

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 deposition

all protected testimony. The court reporter must affix to each such transcript page

containing Protected Material the “CONFIDENTIAL legend”, as instructed by the

Designating Party.

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

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

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

protection, the Producing Party, to the extent practicable, shall identify the protected

portion(s).

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

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

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

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

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

Order.

5.4 Privilege Log

If a party withholds information that is responsive to a discovery request by

claiming that it is privileged or otherwise protected from discovery, that party shall

promptly prepare and provide a privilege log that is sufficiently detailed and

informative for the opposing party to assess whether a document's designation as

privileged is justified. See Fed. R. Civ. P. 26(b)(5). The privilege log shall set forth

the privilege relied upon and specify separately for each document or for each category

of similarly situated documents:

(a) the title and description of the document, including number of pages

or Bates- number range;

(b) the subject matter addressed in the document;

1 (d) the identity and position of all addressees and recipients;

2 (e) the date the document was prepared and, if different, the date(s) on

3 which it was sent to or shared with persons other than its author(s); and

4 (f) the specific basis for the claim that the document is privileged and

5 protected.

6 Communications involving counsel that post-date the filing of the complaint

7 need not be placed on a privilege log.

8 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

9 6.1 Timing of Challenges. Any Party or Non-Party may challenge a

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

11 Scheduling Order.

12 6.2 Meet and Confer. The Challenging Party Shall initiate the dispute

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

14 6.3 Failing to Meet and Confer

15 Failing informal resolution between parties, the Designating Party may file and

16 serve a Motion for a Protective Order with the Court strictly pursuant to Local Rule

17 37, including the Joint Stipulation Procedure. The parties agree that if the Motion for

18 Protective Order is filed within 21 days of the written challenge (subject to extension

19 upon agreement of the Parties), the Material will retain its original designation until

20 the Court rules on the Motion for a Protective Order. If the Designating Party does

21 not file a motion within the 21-day period following a challenge, the material is no

22 longer designated as CONFIDENTIAL INFORMATION for purposes of this

23 Stipulation, but that change in designation does not bar the Producing Party from

24 subsequently filing a motion for a protective order.

25 6.4 Burden of Persuasion

26 The burden of persuasion in any such challenge proceeding shall be on the

27 Designating Party. Frivolous challenges, and those made for an improper purpose

28 (e.g., to harass or impose unnecessary expenses and burdens on other parties), may

1 expose the Challenging Party to sanctions. Unless the Designating Party has waived

2 or withdrawn the confidentiality designation, all parties shall continue to afford the

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

4 Producing Party’s designation until the Court rules on the challenge.

5 6.5 Withdrawal of “CONFIDENTIAL” Designation.

6 At its discretion, a Designating Party may remove Protected Material from some or

7 all of the protections and provisions of this Stipulated Protective Order at any time by

8 any of the following methods:

9 (a) Express Written Withdrawal. A Designating Party may withdraw a

10 “CONFIDENTIAL” designation made to any specified Protected Material from some

11 or all of the protections of this Stipulated Protective Order by an express withdrawal in

12 writing signed by the Designating Party or Designating Party’s counsel (but not

13 including staff of such counsel) that specifies and itemizes the Disclosure or Discovery

14 Material previously designated as Protected Material that shall not longer be subject to

15 some or all of the provisions of this Stipulated Protective Order. Such express

16 withdrawal shall be effective when transmitted or served upon the Receiving Party. If

17 a Designating Party is withdrawing Protected Material from only some of the

18 provisions/protections of this Stipulated Protective Order, the Designating Party must

19 state which specific provisions are no longer to be enforced as to the specified material

20 for which confidentiality protection hereunder is withdrawn: otherwise, such

21 withdrawal shall be construed as a withdrawal of such material from all of the

22 protections/provisions of this Stipulated Protective Order;

23 (b) Express Withdrawal on the Record. A Designating Party may withdraw

24 a “CONFIDENTIAL” designation made to any specified Protected Material from all

25 of the provisions/protections of this Stipulated Protective Order by verbally consenting

26 in court proceedings on the record to such withdrawal – provided that such withdrawal

27 specifies the Disclosure or Discovery Material previously designated as Protected

1 Material shall no longer be subject to any of the provisions of this Stipulation and

2 Order;

3 (c) Implicit Withdrawal by Publication or Failure to Oppose Challenge. A

4 Designating Party shall be construed to have withdrawn a “CONFIDENTIAL”

5 designation made to any specified Protected Material from all of the

6 provisions/protections of this Stipulated Protective Order by either (1) making such

7 Protected Material part of the public record – including but not limited to attaching

8 such as exhibits to any filing with the court without moving, prior to such filing, for

9 the court to seal such records; or (2) failing to timely oppose a Challenging Party’s

10 motion to remove a “CONFIDENTIAL” designation to specified Protected Material.

11 7. ACCESS TO AND USE OF PROTECTED MATERIAL

12 7.1 Basic Principles. A Receiving Party may use Protected Material that is

13 disclosed or produced by another Party or by a Non-Party in connection with this

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

15 Protected Material may be disclosed only to the categories of persons and under the

16 conditions described in this Order. When the Action has been terminated, a

17 Receiving Party must comply with the provisions of Section 13 below (FINAL

18 DISPOSITION).

19 Protected Material must be stored and maintained by a Receiving Party at a

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

authorized under this Order.

7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless

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

Receiving Party may disclose any information or item designated

“CONFIDENTIAL” only to:

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

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

necessary to disclose the information for this Action;

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

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

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

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

(d) the Court and its personnel;

(e) court reporters and their staff;

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

Vendors to whom disclosure is reasonably necessary for this Action and who have

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

(g) the author or recipient of a document containing the information or a

custodian or other person who otherwise possessed or knew the information;

(h) during their depositions, witnesses, and attorneys for witnesses, in the

Action to whom disclosure is reasonably necessary provided: (1) the deposing party

14 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will

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

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

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

18 deposition testimony or exhibits to depositions that reveal Protected Material may be

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

20 permitted under this Stipulated Protective Order; and

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

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

8. PROTECTED MATERIAL SUBPOENAED OR ORDERED

PRODUCED IN OTHER LITIGATION

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

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

“CONFIDENTIAL,” that Party must:

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

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

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

or order is subject to this Protective Order. Such notification shall include a copy of

this Stipulated Protective Order; and

pursued by the Designating Party whose Protected Material may be affected.

If the Designating Party timely seeks a protective order, the Party served with

the subpoena or court order shall not produce any information designated in this

action as “CONFIDENTIAL” before a determination by the court from which the

subpoena or order issued, unless the Party has obtained the Designating Party’s

permission. The Designating Party shall bear the burden and expense of seeking

protection in that court of its confidential material, and nothing in these provisions

should be construed as authorizing or encouraging a Receiving Party in this Action

to disobey a lawful directive from another court.

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

PRODUCED IN THIS LITIGATION

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

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

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

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

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

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

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

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

confidential information, then the Party shall:

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

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

with a Non-Party;

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

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

specific description of the information requested; and

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

Party, if requested.

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

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

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

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

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

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

of seeking protection in this Court of its Protected Material.

///

14 ///

15 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

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

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

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

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

21 persons to whom unauthorized disclosures were made of all the terms of this Order,

22 and (d) request such person or persons to execute the “Acknowledgment and

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

11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

PROTECTED MATERIAL

When a Producing Party gives notice to Receiving Parties that certain

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

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

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

2 may be established in an e-discovery order that provides for production without prior

privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the

parties reach an agreement on the effect of disclosure of a communication or

information covered by the attorney-client privilege or work product protection, the

parties may incorporate their agreement in the stipulated protective order submitted

to the Court.

12. MISCELLANEOUS

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

to seek its modification by the Court in the future.

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

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

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

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

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

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

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

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

Protected Material at issue. If a Party’s request to file Protected Material under seal

is denied by the court, then the Receiving Party may file the information in the public

record unless otherwise instructed by the court.

13. FINAL DISPOSITION

After the final disposition of this Action, as defined in paragraph 4, within 60

days of a written request by the Designating Party, each Receiving Party must return

all Protected Material to the Producing Party or destroy such material. As used in

this subdivision, “all Protected Material” includes all copies, abstracts, compilations,

summaries, and any other format reproducing or capturing any of the Protected

Material. Whether the Protected Material is returned or destroyed, the Receiving

1 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies

2 (by category, where appropriate) all the Protected Material that was returned or

destroyed; and (2) affirms that the Receiving Party has not retained any copies,

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

of the Protected Material. Notwithstanding this provision, Counsel are entitled to

retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing

transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert

reports, attorney work product, and consultant and expert work product, even if such

materials contain Protected Material. Any 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

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

sanctions.

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

17 Dated: March 10, 2025 GASTÉLUM LAW, APC

By: /s/Denisse O. Gastélum

Denisse O. Gastélum, Esq.

20 Selene Estrada-Villela, Esq.

Attorneys for Plaintiffs,

ESTATE OF JESS FLORES, by and through

22 successors in interest, M.F., R.F., and S.F.; M.F., a

minor, by and through Guardian Ad Litem, Justine

Flores; R.F., a minor, by and through Guardian Ad

24 Litem, Justine Flores; S.F., a minor, by and through

Guardian Ad Litem, Lydia Arzola; JESS R.

FLORES, JR., individually; and DEBORAH ANN

26 JACOBS, individually

1 Dated: March 10, 2025 LAW OFFICES OF CHRISTIAN CONTRERAS

A Professional Law Corporation

By: /s/ Christian Contreras

4 Christian Contreras, Esq.

Attorneys for Plaintiffs,

5 ESTATE OF JESS FLORES, by and through

6 successors in interest, M.F., R.F., and S.F.; M.F., a

minor, by and through Guardian Ad Litem, Justine

Flores; R.F., a minor, by and through Guardian Ad

8 Litem, Justine Flores; S.F., a minor, by and through

Guardian Ad Litem, Lydia Arzola; JESS R.

FLORES, JR., individually; and DEBORAH ANN

10 JACOBS, individually

Dated: March 10, 2025 KJAR, MCKENNA & STOCKALPER, LLP

By: /s/ Chaena Dade

Patrick E. Stockalper

16 Molshree Gupta

17 Chaena Dade

Attorneys for Defendants,

18 COUNTY OF RIVERSIDE, RIVERSIDE COUNTY

19 SHERIFF’S DEPARTMENT,

SHERIFF CHAD BIANCO, EDWARD DELGADO,

JAMES KRACHMER,

21 DAVID HOLM

1 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

3 || DATED: 03/11/2025

6 || United States Magistrate Judge

1 EXHIBIT A

2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

I, _____________________________ [print or type full name], of

_________________ [print or type full address], declare under penalty of perjury that

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

issued by the United States District Court for the Central District of California on

[date] in the case of Estate of Jess Flores, et al. v. County of Riverside, et al.; Case

No. 5:24−cv−01933−KK−SHK. I agree to comply with and to be bound by all the

terms of this Stipulated Protective Order, and I understand and acknowledge that

failure to so comply could expose me to sanctions and punishment in the nature of

contempt. I solemnly promise that I will not disclose in any manner any information

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

in strict compliance with the provisions of this 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 __________________________ [print or

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

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

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

21 Stipulated Protective Order.

Date: ______________________________________

City and State where sworn and signed: _________________________________

Printed name: _______________________________

Signature: __________________________________

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