# Tarik Smith v. County of Riverside

> District Court, C.D. California · July 1, 2025

URL: https://www.frixlaw.com/law-library/cases/11089153

## Case

- **Court:** District Court, C.D. California
- **Decided:** July 1, 2025
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

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## Opinion text

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7 UNITED STATES DISTRICT COURT
8 CENTRAL DISTRICT OF CALIFORNIA
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10 Case No. 5:25-cv-00545-FLA (SK)
TARIK SMITH,
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Plaintiff,
STIPULATED PROTECTIVE
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v. ORDER
13 COUNTY OF RIVERSIDE, SARAI
14 CAMACHO, individually and in her Action Filed: February 28, 2025
Pretrial Conference: ***
official capacity, REBECCA Trial Date: ***
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ZAMORA, individually and in her
Assigned to:
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official capacity and DOES 1-13, Hon. Judge Fernando L. Aenlle-
Rocha, District Judge
17 inclusive,
Courtroom 6B
18 Defendants.
Magistrate Judge Hon. Judge Steve
Kim
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Courtroom 540
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1. A. PURPOSES AND LIMITATIONS
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Discovery in this action is likely to involve production of confidential,
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proprietary, or private information for which special protection from public
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disclosure and from use for any purpose other than prosecuting this litigation may
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be warranted. Accordingly, the parties hereby stipulate to and petition the Court to
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enter the following Stipulated Protective Order. The parties acknowledge that this
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Order does not confer blanket protections on all disclosures or responses to
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1 discovery and that the protection it affords from public disclosure and use extends
2 only to the limited information or items that are entitled to confidential treatment
3 under the applicable legal principles. The parties further acknowledge, as set forth
4 in Section 12.3 (Filing Protected Material), below, that this Stipulated Protective
5 Order does not entitle them to file confidential information under seal; Civil Local
6 Rule 79-5 sets forth the procedures that must be followed and the standards that will
7 be applied when a party seeks permission from the court to file material under seal.
8 B. GOOD CAUSE STATEMENT
9 In connection with this action, Plaintiff and Defendant may produce certain
10 documents, things, materials, or other information derived therefrom that contain
11 personal medical, employment or financial information not available to the public;
12 and/or personnel files, information, Department of Public Social Services records
and County Department of Human Resources records; and any confidential
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information contained therein or in any summary, copy, abstract, or other documents
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derived in whole or part therefrom. Such information may implicate the privacy
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interests of the party and are properly protected through a Fed. R. Civ. P. 26(c)
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protective order. Seattle Times Co. v. Rhinehart, 467 U.S. 20, 35 n.21 (1984) (“Rule
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26(c) includes among its express purposes the protection of a ‘party or person from
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annoyance, embarrassment, oppression or undue burden or expense.’ Although the
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Rule contains no specific reference to privacy or to other rights or interests that may
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be implicated, such matters are implicit in the broad purpose and language of the
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Rule.”); Soto v. City of Concord, 162 F.R.D. 603, 617 (N.D. Cal. 1995) (a party’s
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privacy rights are to be protected through a “carefully crafted protective order.”).
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California law fiercely protects the confidentiality of juvenile records. See,
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e.g., Cal. Welf. & Inst. Code section 827 (providing that “the Legislature reaffirms
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its belief that juvenile court records, in general, should be confidential”). Federal
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courts have likewise adhered to this confidentiality. See Meyer v. County of San
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Diego, 2022 WL 395967, *7 (S.D. Cal., Feb. 8, 2022) and T.T. v. Cty. of San Diego,
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1 2020 WL 6118781, at *1 (S.D. Cal. Oct. 16, 2020) (granting a motion to seal
2 juvenile records because “given the confidential status of plaintiff’s juvenile records
3 pursuant to section 827 of the Welfare and Institutional Code, the Court finds that
4 defendants have articulated compelling reasons in support of their motion to seal”).
In light of the nature of the claims and allegations in this case and the parties’
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representations that discovery in this case will involve the production of confidential
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records, including but not limited to sensitive operational documents (including
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investigative records) and/or confidential employment/personnel records and
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information of employees of the County, as well as Plaintiff’s and/or Plaintiff’s
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children’s medical and/or mental health information, and confidential juvenile
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dependency court records containing private and sensitive information pertaining to
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Plaintiff and/or Plaintiff’s minor child as it relates to their underlying juvenile
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dependency case which is the subject of this action. The disclosure of the foregoing
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information to non-parties or others would be harmful to the parties' interests,
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including Plaintiff. Therefore, this information must be protected. The parties shall
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not designate any information/documents as confidential without a good faith belief
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that such information/documents have been maintained in a confidential, non-public
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manner, and that there is good cause or a compelling reason why it should not be
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part of the public record of this case.
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Accordingly, to expedite the flow of information, to facilitate the prompt
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resolution of disputes over confidentiality of discovery materials, to adequately
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protect information the parties are entitled to keep confidential, to ensure that the
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parties are permitted reasonable necessary uses of such material in preparation for
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and in the conduct of trial, to address their handling at the end of the litigation, and
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serve the ends of justice, a protective order for such information is justified in this
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matter. It is the intent of the parties that information will not be designated as
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confidential for tactical reasons and that nothing be so designated without a good
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1 faith belief that it has been maintained in a confidential, non-public manner, and
2 there is good cause why it should not be part of the public record of this case.
3 2. DEFINITIONS
4 2.1 Action: This pending federal lawsuit, Tarik Smith v. County of
5 Riverside, et al., Case No. 5:25-cv-00545-FLA (SKx)
6 2.2 Challenging Party: a Party or Non-Party that challenges the
7 designation of information or items under this Order.
8 2.3 “CONFIDENTIAL” Information or Items: information (regardless of
9 how it is generated, stored, or maintained) or tangible things that qualify for
10 protection under Federal Rule of Civil Procedure 26(c), and as specified above in
11 the Good Cause Statement.
12 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as
13 their support staff).
14 2.5 Designating Party: a Party or Non-Party that designates information
15 or items that it produces in disclosures or in responses to discovery as
16 “CONFIDENTIAL.”
17 2.6 Disclosure or Discovery Material: all items or information, regardless
18 of the medium or manner in which it is generated, stored, or maintained (including,
19 among other things, testimony, transcripts, and tangible things), that are produced
20 or generated in disclosures or responses to discovery in this matter.
21 2.7 Expert: a person with specialized knowledge or experience in a matter
22 pertinent to the litigation who has been retained by a Party or its counsel to serve as
23 an expert witness or as a consultant in this Action.
24 2.8 House Counsel: attorneys who are employees of a party to this Action.
25 House Counsel does not include Outside Counsel of Record or any other outside
26 counsel.
27 2.9 Non-Party: any natural person, partnership, corporation, association,
28 or other legal entity not named as a Party to this action.
1 2.10 Outside Counsel of Record: attorneys who are not employees of a
2 party to this Action but are retained to represent or advise a party to this Action and
3 have appeared in this Action on behalf of that party or are affiliated with a law firm
4 which has appeared on behalf of that party, including support staff.
5 2.11 Party: any party to this Action, including all of its officers, directors,
6 employees, consultants, retained experts, and Outside Counsel of Record (and their
7 support staffs).
8 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
9 Discovery Material in this Action.
10 2.13 Professional Vendors: persons or entities that provide litigation
11 support services (e.g., photocopying, videotaping, translating, preparing exhibits or
12 demonstrations, and organizing, storing, or retrieving data in any form or medium)
13 and their employees and subcontractors.
14 2.14 Protected Material: any Disclosure or Discovery Material that is
15 designated as “CONFIDENTIAL.”
16 2.15 Receiving Party: a Party that receives Disclosure or Discovery
17 Material from a Producing Party.
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19 3. SCOPE
20 The protections conferred by this Stipulation and Order cover not only
21 Protected Material (as defined above), but also (1) any information copied or
22 extracted from Protected Material; (2) all copies, excerpts, summaries, or
23 compilations of Protected Material; and (3) any testimony, conversations, or
24 presentations by Parties or their Counsel that might reveal Protected Material.
25 Any use of Protected Material at trial shall be governed by the orders of the
26 trial judge. This Order does not govern the use of Protected Material at trial.
27 4. DURATION
28 Even after final disposition of this litigation, as defined in Section 13 (FINAL
1 DISPOSITION), the confidentiality obligations imposed by this Order shall remain
2 in effect until a Designating Party agrees otherwise in writing or a court order
3 otherwise directs.
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5 5. DESIGNATING PROTECTED MATERIAL
6 5.1 Exercise of Restraint and Care in Designating Material for Protection.
7 Each Party or Non-Party that designates information or items for protection under
8 this Order must take care to limit any such designation to specific material that
9 qualifies under the appropriate standards. The Designating Party must designate for
10 protection only those parts of material, documents, items, or oral or written
11 communications that qualify so that other portions of the material, documents,
12 items, or communications for which protection is not warranted are not swept
13 unjustifiably within the ambit of this Order.
14 Mass, indiscriminate, or routinized designations are prohibited. Designations
15 that are shown to be clearly unjustified or that have been made for an improper
16 purpose (e.g., to unnecessarily encumber the case development process or to impose
17 unnecessary expenses and burdens on other parties) may expose the Designating
18 Party to sanctions.
19 If it comes to a Designating Party’s attention that information or items that it
20 designated for protection do not qualify for protection, that Designating Party must
21 promptly notify all other Parties that it is withdrawing the inapplicable designation.
22 5.2 Manner and Timing of Designations. Except as otherwise provided in
23 this Order (see, e.g., second paragraph of Section 5.2(a) below), or as otherwise
24 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
25 under this Order must be clearly so designated before the material is disclosed or
26 produced.
27 Designation in conformity with this Order requires:
28 (a) for information in documentary form (e.g., paper or electronic
1 documents, but excluding transcripts of depositions or other pretrial or trial
2 proceedings), that the Producing Party affix at a minimum, the legend
3 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
4 contains protected material. If only a portion or portions of the material on a page
5 qualifies for protection, the Producing Party also must clearly identify the protected
6 portion(s) (e.g., by making appropriate markings in the margins).
7 A Party or Non-Party that makes original documents available for
8 inspection need not designate them for protection until after the inspecting Party has
9 indicated which documents it would like copied and produced. During the
10 inspection and before the designation, all of the material made available for
11 inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has
12 identified the documents it wants copied and produced, the Producing Party must
13 determine which documents, or portions thereof, qualify for protection under this
14 Order. Then, before producing the specified documents, the Producing Party must
15 affix the “CONFIDENTIAL legend” to each page that contains Protected Material.
16 If only a portion or portions of the material on a page qualifies for protection, the
17 Producing Party also must clearly identify the protected portion(s) (e.g., by making
18 appropriate markings in the margins).
19 (b) for testimony given in depositions that the Designating Party identify
20 the Disclosure or Discovery Material on the record, before the close of the
21 deposition all protected testimony.
22 (c) for information produced in some form other than documentary and
23 for any other tangible items, that the Producing Party affix in a prominent place on
24 the exterior of the container or containers in which the information is stored the
25 legend “CONFIDENTIAL.” If only a portion or portions of the information
26 warrants protection, the Producing Party, to the extent practicable, shall identify the
27 protected portion(s).
28 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
1 failure to designate qualified information or items does not, standing alone, waive
2 the Designating Party’s right to secure protection under this Order for such material.
3 Upon timely correction of a designation, the Receiving Party must make reasonable
4 efforts to assure that the material is treated in accordance with the provisions of this
5 Order.
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7 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
8 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
9 designation of confidentiality at any time that is consistent with the Court’s
10 Scheduling Order.
11 6.2 Meet and Confer. The Challenging Party Shall initiate the dispute
12 resolution process under Civil Local Rule 37-1 et seq.
13 6.3 The burden of persuasion in any such challenge proceeding shall be
14 on the Designating Party. Frivolous challenges, and those made for an improper
15 purpose (e.g., to harass or impose unnecessary expenses and burdens on other
16 parties), may expose the Challenging Party to sanctions. Unless the Designating
17 Party has waived or withdrawn the confidentiality designation, all parties shall
18 continue to afford the material in question the level of protection to which it
19 is entitled under the Producing Party’s designation until the Court rules on the
20 challenge.
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22 7. ACCESS TO AND USE OF PROTECTED MATERIAL
23 7.1 Basic Principles. A Receiving Party may use Protected Material that
24 is disclosed or produced by another Party or by a Non-Party in connection with
25 this Action only for prosecuting, defending, or attempting to settle this Action.
26 Such Protected Material may be disclosed only to the categories of persons and
27 under the conditions described in this Order. When the Action has been
28 terminated, a Receiving Party must comply with the provisions of Section 13 below
1 (FINAL DISPOSITION).
2 Protected Material must be stored and maintained by a Receiving Party at
3 a location and in a secure manner that ensures that access is limited to the
4 persons authorized under this Order.
5 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
6 otherwise ordered by the Court or permitted in writing by the Designating Party, a
7 Receiving Party may disclose any information or item designated
8 “CONFIDENTIAL” only to:
9 (a) the Receiving Party’s Outside Counsel of Record in this Action, as
10 well as employees of said Outside Counsel of Record to whom it is reasonably
11 necessary to disclose the information for this Action;
12 (b) the officers, directors, and employees (including House Counsel) of
13 the Receiving Party to whom disclosure is reasonably necessary for this Action;
14 (c) Experts (as defined in this Order) of the Receiving Party to whom
15 disclosure is reasonably necessary for this Action and who have signed the
16 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
17 (d) the Court and its personnel;
18 (e) court reporters and their staff;
19 (f) professional jury or trial consultants, mock jurors, and Professional
20 Vendors to whom disclosure is reasonably necessary for this Action and who have
21 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
22 (g) the author or recipient of a document containing the information or a
23 custodian or other person who otherwise possessed or knew the information;
24 (h) during their depositions, witnesses, and attorneys for witnesses, in
25 the Action to whom disclosure is reasonably necessary provided: (1) the deposing
26 party requests that the witness sign the form attached as Exhibit A hereto; and (2)
27 they will not be permitted to keep any confidential information unless they sign the
28 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
1 agreed by the Designating Party or ordered by the Court. Pages of transcribed
2 deposition testimony or exhibits to depositions that reveal Protected Material may
3 be separately bound by the court reporter and may not be disclosed to anyone except
4 as permitted under this Stipulated Protective Order; and
5 (i) any mediator or settlement officer, and their supporting personnel,
6 mutually agreed upon by any of the parties engaged in settlement discussions.
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8 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
9 IN OTHER LITIGATION
10 If a Party is served with a subpoena or a court order issued in other litigation
11 that compels disclosure of any information or items designated in this Action as
12 “CONFIDENTIAL,” that Party must:
13 (a) promptly notify in writing the Designating Party. Such notification
14 shall include a copy of the subpoena or court order;
15 (b) promptly notify in writing the party who caused the subpoena or order
16 to issue in the other litigation that some or all of the material covered by the
17 subpoena or order is subject to this Protective Order. Such notification shall include
18 a copy of this Stipulated Protective Order; and
19 (c) cooperate with respect to all reasonable procedures sought to be
20 pursued by the Designating Party whose Protected Material may be affected.
21 If the Designating Party timely seeks a protective order, the Party served with
22 the subpoena or court order shall not produce any information designated in this
23 action as “CONFIDENTIAL” before a determination by the court from which the
24 subpoena or order issued, unless the Party has obtained the Designating Party’s
25 permission. The Designating Party shall bear the burden and expense of seeking
26 protection in that court of its confidential material, and nothing in these provisions
27 should be construed as authorizing or encouraging a Receiving Party in this Action
28 to disobey a lawful directive from another court.
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2 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
3 PRODUCED IN THIS LITIGATION
4 (a) The terms of this Order are applicable to information produced by a
5 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
6 produced by Non-Parties in connection with this litigation is protected by the
7 remedies and relief provided by this Order. Nothing in these provisions should be
8 construed as prohibiting a Non-Party from seeking additional protections.
9 (b) In the event that a Party is required, by a valid discovery request, to
10 produce a Non-Party’s confidential information in its possession, and the Party is
11 subject to an agreement with the Non-Party not to produce the Non-Party’s
12 confidential information, then the Party shall:
13 (1) promptly notify in writing the Requesting Party and the Non-Party
14 that some or all of the information requested is subject to a confidentiality agreement
15 with a Non-Party;
16 (2) promptly provide the Non-Party with a copy of the Stipulated
17 Protective Order in this Action, the relevant discovery request(s), and a reasonably
18 specific description of the information requested; and
19 (3) make the information requested available for inspection by the Non-
20 Party, if requested.
21 (c) If the Non-Party fails to seek a protective order from this Court within
22 14 days of receiving the notice and accompanying information, the Receiving Party
23 may produce the Non-Party’s confidential information responsive to the discovery
24 request. If the Non-Party timely seeks a protective order, the Receiving Party shall
25 not produce any information in its possession or control that is subject to the
26 confidentiality agreement with the Non-Party before a determination by the Court.
27 Absent a court order to the contrary, the Non-Party shall bear the burden and
28 expense of seeking protection in this Court of its Protected Material.
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2 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
3 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
4 Protected Material to any person or in any circumstance not authorized under this
5 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
6 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
7 to retrieve all unauthorized copies of the Protected Material, (c) inform the person
8 or persons to whom unauthorized disclosures were made of all the terms of this
9 Order, and (d) request such person or persons to execute the “Acknowledgment and
10 Agreement to Be Bound” that is attached hereto as Exhibit A.
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12 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
13 PROTECTED MATERIAL
14 When a Producing Party gives notice to Receiving Parties that certain
15 inadvertently produced material is subject to a claim of privilege or other protection,
16 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
17 Procedure 26(b)(5)(B). This provision is not intended to modify whatever
18 procedure may be established in an e-discovery order that provides for production
19 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and
20 (e), insofar as the parties reach an agreement on the effect of disclosure of a
21 communication or information covered by the attorney-client privilege or work
22 product protection, the parties may incorporate their agreement in the stipulated
23 protective order submitted to the Court.
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25 12. MISCELLANEOUS
26 12.1 Right to Relief. Nothing in this Order abridges the right of any person
27 to seek its modification by the Court in the future.
28 12.2 Right to Assert Other Objections. By stipulating to the entry of this
1 Protective Order, no Party waives any right it otherwise would have to object to
2 disclosing or producing any information or item on any ground not addressed in this
3 Stipulated Protective Order. Similarly, no Party waives any right to object on any
4 ground to use in evidence of any of the material covered by this Protective Order.
5 12.3 Filing Protected Material. A Party that seeks to file under seal any
6 Protected Material must comply with Civil Local Rule 79-5. Protected Material
7 may only be filed under seal pursuant to a court order authorizing the sealing of the
8 specific Protected Material at issue. If a Party’s request to file Protected Material
9 under seal is denied by the court, then the Receiving Party may file the information
10 in the public record unless otherwise instructed by the court.
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12 13. FINAL DISPOSITION
13 Final disposition shall be deemed to be the later of (1) dismissal of all claims
14 and defenses in this Action, with or without prejudice; and (2) final judgment herein
15 after the completion and exhaustion of all appeals, rehearings, remands, trials, or
16 reviews of this Action, including the time limits for filing any motions or
17 applications for extension of time pursuant to applicable law. After the final
18 disposition of this Action, within 60 days of a written request by the Designating
19 Party, each Receiving Party must return all Protected Material to the Producing
20 Party or destroy such material. As used in this subdivision, “all Protected Material”
21 includes all copies, abstracts, compilations, summaries, and any other format
22 reproducing or capturing any of the Protected Material. Whether the Protected
23 Material is returned or destroyed, the Receiving Party must submit a written
24 certification to the Producing Party (and, if not the same person or entity, to the
25 Designating Party) by the 60 day deadline that (1) identifies (by category, where
26 appropriate) all the Protected Material that was returned or destroyed; and (2)
27 affirms that the Receiving Party has not retained any copies, abstracts, compilations,
28 summaries, or any other format reproducing or capturing any of the Protected
1} Material. Notwithstanding this provision, Counsel are entitled to retain an archival
copy of all pleadings, motion| papers, trial, deposition, and hearing transcripts, legal
3 memoranda, correspondence deposition and trial exhibits, expert reports, attorney
work product, and consultant and expert work product, even if such materials
5} contain Protected Material. | Any such archival copies that contain or constitute
6 | Protected Material remain subject to this Protective Order as set forth in Section 4
7 (DURATION).
9| 14. Any violation of this|Order may be punished by any and all appropriate
10 | measures including, | without limitation, contempt proceedings and/or
11 monetary sanctions.
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13} ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD.
14 |
Dated: June 26, 2025 KJAR, MCKENNA & STOCKALPER, LLP
16 Ch Kohn om
17 By: d \
18 | PATRICK E. STOCKALPER
MOLSHREE GUPTA
19 | CHAENA B. DADE
70 | Attorneys for Defendant,
1 | COUNTY OF RIVERSIDE

‘Dated: June 18, 2025 nT
By: □□
24 | TARIK SMITH
45 Plaintiff, in pyé per
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FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
2
3| DATED: | July 1, 2025
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5 Sor
6 | Honorable Steve Kim
United States Magistrate Judge

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1«

1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3
4 I, _____________________________ [print or type full name], of
5 _________________ [print or type full address], declare under penalty of perjury
6 that I have read in its entirety and understand the Stipulated Protective Order that
7 was issued by the United States District Court for the Central District of California
8 on [date] in the case of Smith v. County of Riverside, et al. Case No. 5:25-cv-00545-
9 FLA (SKx). I agree to comply with and to be bound by all the terms of this
10 Stipulated Protective Order, and I understand and acknowledge that failure to so
11 comply could expose me to sanctions and punishment in the nature of contempt. I
12 solemnly promise that I will not disclose in any manner any information or item that
13 is subject to this Stipulated Protective Order to any person or entity except in strict
14 compliance with the provisions of this Order.
15 I further agree to submit to the jurisdiction of the United States District Court
16 for the Central District of California for the purpose of enforcing the terms of this
17 Stipulated Protective Order, even if such enforcement proceedings occur after
18 termination of this action. I hereby appoint __________________________ [print
19 or type full name] of _______________________________________ [print or type
20 full address and telephone number] as my California agent for service of process in
21 connection with this action or any proceedings related to enforcement of this
22 Stipulated Protective Order.
23 Date: ______________________________________
24 City and State where sworn and signed: _________________________________
25
26 Printed name: _______________________________
27
28 Signature: __________________________________

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/11089153. Public record. Not legal advice.