The opinion
1 John C. Carpenter, Esq.
carpenter@cz.law
2
Carlos A. Hernandez, Esq.
chernandez@cz.law
3
Gabriel Minsal, Esq., LL.M.
4 gminsal@cz.law
CARPENTER & ZUCKERMAN
5 8827 West Olympic Boulevard
Beverly Hills, CA 90211
6
Telephone: (310) 273-1230
7
Attorneys for Plaintiff
8
PRENTICE LONG, PC
9 Margaret E. Long – SBN 227176
Caitlin Smith – SBN 269716
10
Andrew Plett – SBN 301735
11 2240 Court Street
Redding, CA 96001
12 Telephone: (530) 691-0800
E-Mail: margaret@prenticelongpc.com
13 caitlin@prenticelongpc.com
14
Attorneys for Defendants County of Fresno,
15 Sheriff Margaret A. Mims, Lieutenant McCoy,
Officer Sunny Armenta (DOE 1), and
16 Sergeant Luis Figueroa (DOE 2)
17
18 UNITED STATES DISTRICT COURT
19 EASTERN DISTRICT OF CALIFORNIA
20
21 JEREMY CARGILL, an individual, No. 1:25-CV-00415-KES-BAM
22 Plaintiff, JOINT STIPULATION FOR
PROTECTIVE ORDER;
23 v. [PROPOSED] ORDER
24
COUNTY OF FRESNO, et al.,
25
Defendants.
26
27 / / /
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1 1. PURPOSES AND LIMITATIONS
2 Disclosure and discovery activity in this action are likely to involve production of
3 confidential, proprietary, or private information for which special protection from public disclosure
4 and from use for any purpose other than prosecuting this litigation may be warranted. Accordingly,
5 the parties hereby stipulate to and petition the court to enter the following Stipulated Protective
6 Order. The parties acknowledge that this Order does not confer blanket protections on all
7 disclosures or responses to discovery and that the protection it affords from public disclosure and
8 use extends only to the limited information or items that are entitled to confidential treatment under
9 the applicable legal principles. The parties further acknowledge, as set forth in Section 12.3, below,
10 that this Stipulated Protective Order does not entitle them to file confidential information under
11 seal; Civil Local Rule 141 and 141.1 set forth the procedures that must be followed and the
12 standards that will be applied when a party seeks permission from the court to file material under
13 seal.
14 2. DEFINITIONS
15 2.1 Challenging Party: a Party or Non-Party that challenges the designation of information
16 or items under this Order.
17 2.2 Designating Party: a Party or Non-Party that designates information or items that it
18 produces in disclosures or in responses to discovery as “CONFIDENTIAL.”
19 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how it is
20 generated, stored or maintained) or tangible things that qualify for protection under Federal Rule
21 of Civil Procedure 26(c). It encompasses information where public disclosure is likely to result in
22 particularized harm, or where public disclosure would violate privacy interests recognized by law.
23 Specifically, pursuant to Civil Local Rule 141.1(c)(1), the following information may be deemed
24 confidential by a Designating Party pursuant to the provisions of this Stipulation and Order:
25 (a) records pertaining to the physical attributes of the Fresno County Jail and its
26 security/surveillance systems, including but not limited to information pertaining to the physical
27 layout/design of the jail, the surveillance system and policies or procedures pertaining to security
28 or surveillance within the jail, information regarding the design of the facilities, security systems,
1 surveillance systems, observation towers, information pertaining to how the jail is staffed by
2 correctional officers relative to overseeing inmates/detainees, and information pertaining to video
3 or other equipment used for surveillance or security;
4 (b) personnel file records of any peace officer or medical professional;
5 (c) medical records;
6 (d) social security numbers, addresses, phone numbers, and similar such
7 sensitive, identifying information (unless redacted by order or by agreement of all parties).
8 As to a showing of particularized need for protection as to each category of information
9 under Civil Local Rule 141.1(c)(2), the parties submit that records pertaining to the physical layout
10 of and security/surveillance systems of the jail, personnel files of peace officers, personnel records
11 of medical professionals, medical records, and social security numbers and other such sensitive,
12 identifying information (which could be used to commit identity theft if inadvertently disclosed,
13 filed publicly, or disseminated without restriction) may contain sensitive information protected by
14 the parties’ privacy rights as well as the ongoing safety and security of the jail, including for jail
15 employees and inmates/detainees. As to a showing as to why the need for protection should be
16 addressed by a court order, as opposed to a private agreement between or among the parties, the
17 parties contend that a private agreement would not be as easily enforceable as would be a court’s
18 protective order, with which the parties have more familiarity.
19 2.4 Counsel (without qualifier): Outside Counsel of Record and House Counsel (as well as
20 their support staff).
21 2.5 Disclosure or Discovery Material: all items or information, regardless of the medium or
22 manner in which it is generated, stored, or maintained (including, among other things, testimony,
23 transcripts, and tangible things), that are produced or generated in disclosures or responses to
24 discovery in this matter.
25 2.6 Expert: a person with specialized knowledge or experience in a matter pertinent to the
26 litigation who has been retained by a Party or its counsel to serve as an expert witness or as a
27 consultant in this action.
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1 2.7 House Counsel: attorneys who are employees of a party to this action. House Counsel
2 does not include Outside Counsel of Record or any other outside counsel.
3 2.8 Non-Party: any natural person, partnership, corporation, association, or other legal
4 entity not named as a Party to this action, except that “Non-Party”, as defined in this Stipulated
5 Protective Order, does not include this Court (the U.S. District Court for the Eastern District of
6 California) or its personnel.
7 2.9 Outside Counsel of Record: attorneys who are not employees of a party to this action
8 but are retained to represent or advise a party to this action and have appeared in this action on
9 behalf of that party or are affiliated with a law firm which has appeared on behalf of that party.
10 2.10 Party: any party to this action, including all of its officers, directors, employees,
11 consultants, retained experts, and Outside Counsel of Record (and their support staffs).
12 2.11 Producing Party: a Party or Non-Party that produces Disclosure or Discovery Material
13 in this action.
14 2.12 Professional Vendors: persons or entities that provide litigation support services (e.g.,
15 photocopying, videotaping, translating, preparing exhibits or demonstrations, and organizing,
16 storing, or retrieving data in any form or medium) and their employees and subcontractors.
17 2.13 Protected Material: any Disclosure or Discovery Material that is designated as
18 “CONFIDENTIAL.”
19 2.14 Receiving Party: a Party that receives Disclosure or Discovery Material from a
20 Producing Party.
21 3. SCOPE
22 The protections conferred by this Stipulation and Order cover not only Protected Material
23 (as defined above), but also (1) any information copied from Protected Material; (2) all copies,
24 excerpts, summaries, or compilations of Protected Material that reveal the source of the Protected
25 Material or that reveal specific information, i.e., the raw data gleaned from protected documents,
26 entitled to confidentiality under this stipulated order; and (3) any testimony, conversations, or
27 presentations by Parties or their Counsel that might reveal Protected Material. However, the
28 protections conferred by this Stipulation and Order do not cover the following information: (a) any
1 information that is in the public domain at the time of disclosure to a Receiving Party or becomes
2 part of the public domain after its disclosure to a Receiving Party as a result of publication not
3 involving a violation of this Order, including becoming part of the public record through trial or
4 otherwise; and (b) any information known to the Receiving Party prior to the disclosure or obtained
5 by the Receiving Party after the disclosure from a source who obtained the information lawfully
6 and under no obligation of confidentiality to the Designating Party. Any use of Protected Material
7 at trial shall be governed by a separate agreement or order.
8 4. DURATION
9 Once the Clerk has closed an action, unless otherwise ordered, the Court will not retain
10 jurisdiction over enforcement of the terms of this protective order. Civil Local Rule 141.1(f).
11 5. DESIGNATING PROTECTED MATERIAL
12 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each Party or
13 Non-Party that designates information or items for protection under this Order must take care to
14 limit any such designation to specific material that qualifies under the appropriate standards. The
15 Designating Party must designate for protection only those parts of material, documents, items, or
16 oral or written communications that qualify – so that other portions of the material, documents,
17 items, or communications for which protection is not warranted are not swept unjustifiably within
18 the ambit of this Order. Mass, indiscriminate, or routinized designations are prohibited.
19 Designations that are shown to be clearly unjustified or that have been made for an improper
20 purpose (e.g., to unnecessarily encumber or retard the case development process or to impose
21 unnecessary expenses and burdens on other parties) expose the Designating Party to sanctions.
22 If it comes to a Designating Party’s attention that information or items that it designated for
23 protection do not qualify for protection, that Designating Party must promptly notify all other
24 Parties that it is withdrawing the mistaken designation.
25 5.2 Manner and Timing of Designations. Except as otherwise provided in this Order (see,
26 e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure
27 or Discovery Material that qualifies for protection under this Order must be clearly so designated
28 before the material is disclosed or produced. Designation in conformity with this Order requires:
1 (a) for information in documentary form (e.g., paper or electronic documents,
2 but excluding transcripts of depositions or other pretrial or trial proceedings), that the Producing
3 Party affix the legend “CONFIDENTIAL” to each page that contains protected material. If only a
4 portion or portions of the material on a page qualifies for protection, the Producing Party also must
5 clearly identify the protected portion(s) (e.g., by making appropriate markings in the margins). A
6 Party or Non-Party that makes original documents or materials available for inspection need not
7 designate them for protection until after the inspecting Party has indicated which material it would
8 like copied and produced. During the inspection and before the designation, all of the material made
9 available for inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has
10 identified the documents it wants copied and produced, the Producing Party must determine which
11 documents, or portions thereof, qualify for protection under this Order. Then, before producing the
12 specified documents, the Producing Party must affix the “CONFIDENTIAL” legend to each page
13 that contains Protected Material. If only a portion or portions of the material on a page qualifies for
14 protection, the Producing Party also must clearly identify the protected portion(s) (e.g., by making
15 appropriate markings in the margins).
16 (b) for testimony given in deposition or in other pretrial or trial proceedings, that
17 the Designating Party identify on the record, before the close of the deposition, hearing, or other
18 proceeding, all protected testimony, if it is practicable to do so; otherwise, it must be so designated
19 during the “review and sign” period under Rule 30 of the Federal Rules of Civil Procedure, unless
20 the parties agree to extend the time for designation.
21 (c) for information produced in some form other than documentary and for any
22 other tangible items, that the Producing Party affix in a prominent place on the exterior of the
23 container or containers in which the information or item is stored the legend “CONFIDENTIAL.”
24 If only a portion or portions of the information or item warrant protection, the Producing Party, to
25 the extent practicable, shall identify the protected portion(s).
26 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to designate
27 qualified information or items does not, standing alone, waive the Designating Party’s right to
28 secure protection under this Order for such material. Upon timely correction of a designation, the
1 Receiving Party must make reasonable efforts to assure that the material is treated in accordance
2 with the provisions of this Order.
3 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
4 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation of
5 confidentiality at any time. Unless a prompt challenge to a Designating Party’s confidentiality
6 designation is necessary to avoid foreseeable, substantial unfairness, unnecessary economic
7 burdens, or a significant disruption or delay of the litigation, a Party does not waive its right to
8 challenge a confidentiality designation by electing not to mount a challenge promptly after the
9 original designation is disclosed.
10 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution process by
11 providing written notice of each designation it is challenging and describing the basis for each
12 challenge. To avoid ambiguity as to whether a challenge has been made, the written notice must
13 recite that the challenge to confidentiality is being made in accordance with this specific paragraph
14 of the Protective Order. The parties shall attempt to resolve each challenge in good faith and must
15 begin the process by conferring directly (in voice to voice dialogue; other forms of communication
16 are not sufficient) within 14 days of the date of service of notice. In conferring, the Challenging
17 Party must explain the basis for its belief that the confidentiality designation was not proper and
18 must give the Designating Party an opportunity to review the designated material, to reconsider the
19 circumstances, and, if no change in designation is offered, to explain the basis for the chosen
20 designation. A Challenging Party may proceed to the next stage of the challenge process only if it
21 has engaged in this meet and confer process first or establishes that the Designating Party is
22 unwilling to participate in the meet and confer process in a timely manner.
23 6.3 Judicial Intervention. If the Parties cannot resolve a challenge without court
24 intervention, the Designating Party shall file and serve a motion to retain confidentiality in
25 compliance with Civil Local Rule 230 within 21 days of the initial notice of challenge or within 14
26 days of the parties agreeing that the meet and confer process will not resolve their dispute,
27 whichever is earlier. Each such motion must be accompanied by a competent declaration affirming
28 that the movant has complied with the meet and confer requirements imposed in the preceding
1 paragraph. Failure by the Designating Party to make such a motion including the required
2 declaration within 21 days (or 14 days, if applicable) shall automatically waive the confidentiality
3 designation for each challenged designation. In addition, the Challenging Party may file a motion
4 challenging a confidentiality designation at any time if there is good cause for doing so, including
5 a challenge to the designation of a deposition transcript or any portions thereof. Any motion brought
6 pursuant to this provision must be accompanied by a competent declaration affirming that the
7 movant has complied with the meet and confer requirements imposed by the preceding paragraph.
8 The burden of persuasion in any such challenge proceeding shall be on the Designating
9 Party. Frivolous challenges, and those made for an improper purpose (e.g., to harass or impose
10 unnecessary expenses and burdens on other parties) may expose the Challenging Party to sanctions.
11 Unless the Designating Party has waived the confidentiality designation by failing to file a motion
12 to retain confidentiality as described above, all parties shall continue to afford the material in
13 question the level of protection to which it is entitled under the Producing Party’s designation until
14 the court rules on the challenge.
15 7. ACCESS TO AND USE OF PROTECTED MATERIAL
16 7.1 Basic Principles. A Receiving Party may use Protected Material that is disclosed or
17 produced by another Party or by a Non-Party in connection with this case only for prosecuting,
18 defending, or attempting to settle this litigation. Such Protected Material may be disclosed only to
19 the categories of persons and under the conditions described in this Order. When the litigation has
20 been terminated, a Receiving Party must comply with the provisions of section 13 below (FINAL
21 DISPOSITION). Protected Material must be stored and maintained by a Receiving Party at a
22 location and in a secure manner that ensures that access is limited to the persons authorized under
23 this Order.
24 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise ordered by
25 the court or permitted in writing by the Designating Party, a Receiving Party may disclose any
26 information or item designated “CONFIDENTIAL” only to:
27 / / /
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1 (a) Experts (as defined in this Order), as well as other consultants, including
2 legal consultants, of the Receiving Party to whom disclosure is reasonably necessary for this
3 litigation and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
4 (b) the court and its personnel;
5 (c) court reporters and their staff, professional jury or trial consultants, mock
6 jurors, and Professional Vendors to whom disclosure is reasonably necessary for this litigation and
7 who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
8 (d) during their depositions, witnesses in the action to whom disclosure is
9 reasonably necessary and who have signed the “Acknowledgment and Agreement to Be Bound”
10 (Exhibit A), unless otherwise agreed by the Designating Party or ordered by the court. Pages of
11 transcribed deposition testimony or exhibits to depositions that reveal Protected Material must be
12 separately bound by the court reporter and may not be disclosed to anyone except as permitted
13 under this Stipulated Protective Order or as agreed by the Designating Party; or (e) the author or
14 recipient of a document containing the information or a custodian or other person who otherwise
15 possessed or knew the information.
16 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER
17 LITIGATION
18 If a Party is served with a subpoena or a court order issued in other litigation that compels
19 disclosure of any information or items designated in this action as “CONFIDENTIAL,” that Party
20 must:
21 (a) promptly notify in writing the Designating Party. Such notification shall include a
22 copy of the subpoena or court order;
23 (b) promptly notify in writing the party who caused the subpoena or order to issue in
24 the other litigation that some or all of the material covered by the subpoena or order is subject to
25 this Protective Order. Such notification shall include a copy of this Stipulated Protective Order; and
26 (c) cooperate with respect to all reasonable procedures sought to be pursued by the
27 Designating Party whose Protected Material may be affected.
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1 If the Designating Party timely seeks a protective order, the Party served with the subpoena
2 or court order shall not produce any information designated in this action as “CONFIDENTIAL”
3 before a determination by the court from which the subpoena or order issued, unless the Party has
4 obtained the Designating Party’s permission. The Designating Party shall bear the burden and
5 expense of seeking protection in that court of its confidential material – and nothing in these
6 provisions should be construed as authorizing or encouraging a Receiving Party in this action to
7 disobey a lawful directive from another court.
8 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS
9 LITIGATION
10 (a) The terms of this Order are applicable to information produced by a Non-Party in
11 this action and designated as “CONFIDENTIAL.” Such information produced by Non-Parties in
12 connection with this litigation is protected by the remedies and relief provided by this Order.
13 Nothing in these provisions should be construed as prohibiting a Non-Party from seeking additional
14 protections.
15 (b) In the event that a Party is required, by a valid discovery request, to produce a Non-
16 Party’s confidential information in its possession, and the Party is subject to an agreement with the
17 Non-Party not to produce the Non-Party’s confidential information, then the Party shall:
18 (1) promptly notify in writing the Requesting Party and the Non-Party that some
19 or all of the information requested is subject to a confidentiality agreement with a Non-Party;
20 (2) promptly provide the Non-Party with a copy of the Stipulated Protective
21 Order in this litigation, the relevant discovery request(s), and a reasonably specific description of
22 the information requested; and
23 (3) make the information requested available for inspection by the Non-Party.
24 (c) If the Non-Party fails to object or seek a protective order from this court within 14
25 days of receiving the notice and accompanying information, the Receiving Party may produce the
26 Non-Party’s confidential information responsive to the discovery request. If the Non-Party timely
27 seeks a protective order, the Receiving Party shall not produce any information in its possession or
28 control that is subject to the confidentiality agreement with the Non-Party before a determination
1 by the court. Absent a court order to the contrary, the Non-Party shall bear the burden and expense
2 of seeking protection in this court of its Protected Material.
3 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
4 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected
5 Material to any person or in any circumstance not authorized under this Stipulated Protective Order,
6 the Receiving Party must immediately (a) notify in writing the Designating Party of the
7 unauthorized disclosures, (b) use its best efforts to retrieve all unauthorized copies of the Protected
8 Material, (c) inform the person or persons to whom unauthorized disclosures were made of all the
9 terms of this 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.
11 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED
12 MATERIAL
13 When a Producing Party gives notice to Receiving Parties that certain inadvertently
14 produced material is subject to a claim of privilege or other protection, the obligations of the
15 Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This provision
16 is not intended to modify whatever procedure may be established in an e-discovery order that
17 provides for production without prior privilege review. Pursuant to Federal Rule of Evidence 502(d)
18 and (e), insofar as the parties reach an agreement on the effect of disclosure of a communication or
19 information covered by the attorney-client privilege or work product protection, the parties may
20 incorporate their agreement in the stipulated protective order submitted to the court.
21 12. MISCELLANEOUS
22 12.1 Right to Further Relief. Nothing in this Order abridges the right of any person to seek
23 its modification by the court in the future.
24 12.2 Right to Assert Other Objections. By stipulating to the entry of this Protective Order
25 no Party waives any right it otherwise would have to object to disclosing or producing any
26 information or item on any ground not addressed in this Stipulated Protective Order. Similarly, no
27 Party waives any right to object on any ground to use in evidence of any of the material covered by
28 this Protective Order.
1 12.3 Filing Protected Material. Without written permission from the Designating Party, a
2 court order secured after appropriate notice to all interested persons, or a change in the status of
3 designated material after the procedures for challenging a designation in Section 6, above, have
4 been employed, a Party may not file in the public record in this action any Protected Material. A
5 Party that seeks to file under seal any Protected Material must comply with Civil Local Rule 141.
6 Protected Material may only be filed under seal pursuant to a court order authorizing the sealing of
7 the specific Protected Material at issue. Pursuant to Civil Local Rule 141, a sealing order will issue
8 only upon a request establishing that the Protected Material at issue is privileged, protectable as a
9 trade secret, or otherwise entitled to protection under the law.
10 12.4 Court’s Established Practices and Rules Control. To the extent any term of this
11 Proposed Stipulated Protective Order conflicts with the Court’s established practices or Rules, the
12 Court’s established practices or Rules will govern.
13 13. FINAL DISPOSITION
14 Within 60 days after the final disposition of this action, as defined in paragraph 4, upon
15 written notification served by Producing or Designating Party, each Receiving Party must return
16 all Protected Material to the Producing Party or destroy such material. As used in this subdivision,
17 “all Protected Material” includes all copies, abstracts, compilations, summaries, and any other
18 format reproducing or capturing any of the Protected Material. Whether the Protected Material is
19 returned or destroyed, the Receiving Party must submit a written certification to the Producing
20 Party (and, if not the same person or entity, to the Designating Party) by the 60 day deadline that
21 (1) identifies (by category, where appropriate) all the Protected Material that was returned or
22 destroyed and (2) affirms that the Receiving Party has not retained any copies, abstracts,
23 compilations, summaries or any other format reproducing or capturing any of the Protected
24 Material. Notwithstanding this provision, Counsel are entitled to retain an archival copy of all
25 pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda,
26 correspondence, deposition and trial exhibits, videos, photographs, and other objective evidence –
27 as well as reports – reflecting, directly concerning, or arising out of the incident giving rise to the
28 litigation, expert reports, attorney work product, and consultant and expert work product, even if
1 such materials contain Protected Material. Any such archival copies that contain or constitute
2 Protected Material remain subject to this Protective Order as set forth in Section 4 (DURATION).
3 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
4
5 Dated: July 25, 2025 CARPENTER & ZUCKERMAN
6
By: /s/ Carlos A. Hernandez*
7 JOHN C. CARPENTER
CARLOS A. HERNANDEZ
8
GABRIEL MINSAL
9 Attorneys for Plaintiff
10
11
Dated: July 25, 2025 PRENTICE LONG, PC
12
13
By: /s/ Margaret E. Long
14 MARGARET E. LONG
CAITLIN SMITH
15 ANDREW PLETT
Attorneys for Defendants County of
16
Fresno, Sheriff Margaret A. Mims,
17 Lieutenant McCoy, Officer Sunny
Armenta (DOE 1), and Sergeant
18 Luis Figueroa (DOE 2)
19
20
*Counsel provided their consent to the filing of this document via CM/ECF.
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1 ORDER
2 The Court has reviewed the Joint Stipulation for Protective Order filed by Plaintiff Jeremy
3 Cargill and Defendants County of Fresno, Sheriff Margaret A. Mims, Lieutenant McCoy, Officer
4 Sunny Armenta, and Sergeant Luis Figueroa, through their counsel of record, requesting that the
5 Court enter an Order.
6 Pursuant to the stipulation of the parties, IT IS HEREBY ORDERED that:
7 1. The above stipulated protective order is entered;
8 2. The parties are advised that, pursuant to the Local Rules of the United States District
9 Court, Eastern District of California, any documents which are to be filed under seal
10 will require a written request that complies with Local Rule 141; and
11 3. The party making a request to file documents under seal shall be required to show
12 good cause for documents attached to a nondispositive motion or compelling
13 reasons for documents attached to a dispositive motion. Pintos v. Pacific Creditors
14 Ass’n, 605 F.3d 665, 677–78 (9th Cir. 2009). Within five (5) days of any approved
15 document filed under seal, the party shall file a redacted copy of the sealed
16 document. The redactions shall be narrowly tailored to protect only the information
17 that is confidential or was deemed confidential.
18 Additionally, the parties shall consider resolving any dispute arising under the protective
19 order according to the Court’s informal discovery dispute procedure.
20
IT IS SO ORDERED.
21
Dated: July 29, 2025 /s/ Barbara A. McAuliffe _
22
UNITED STATES MAGISTRATE JUDGE
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