a party’s privacy rights are to be protected through a “carefully 26 crafted protective order.”
How later courts described this case
- a party’s privacy rights are to be protected through a “carefully 26 crafted protective order.”
Written by the judges who cited it.
The opinion
1 KOe’HviAn ROA’H LarAaW, E sAqP., CS BN 314559 BLAriWan OHFuFrwICitEzS, EOsFq .B, SRBIANN 2 H82U8R1W7 ITZ
1730 W. Cameron Ave, Ste 200 6565 W Sunset Blvd, Ste 410
2 West Covina, CA 91790 Los Angeles, CA 90028-7218
T: (310) 525-5882 | F: (310) 525-5882 T: (323) 244-4147 | F: (323) 417-4869
3 Email: kevin@oharalawapc.com Email: bhurwitz@hurwitzlawgroup.com
4 Denisse O. Gastélum, SBN 282771
Selene Estrada-Villela, SBN 354994
5 GASTÉLUM LAW, APC
A Professional Corporation
6 3767 Worsham Ave.
Long Beach, California 90808
7 T: (213) 340-6112 | F: (213) 402-8622
Email: dgastelum@gastelumfirm.com
8 sestradavillela@gastelumfirm.com
9
Attorneys for Plaintiffs, ESTATE OF MAXWELL AGUIRRE, et al.
10
UNITED STATES DISTRICT COURT
11
12 THE CENTRAL DISTRICT OF CALIFORNIA – WESTERN DIVISION
13
ESTATE OF MAXWELL AGUIRRE, ) CASE NO. 2:24-cv-5318-ODW (AJRx)
14 by and through successors in interest, ) [Assigned to the Hon. Otis D. Wright,
Omar Aguirre and Yvette Aguirre; ) District Judge; Referred to the Hon. A.
15 OMAR AGUIRRE, an individual; ) Joel Richlin, Magistrate Judge]
YVETTE AGUIRRE, an individual, )
16 )
Plaintiffs, ) DISCOVERY MATTER
17 )
v. )
18 ) [PROPOSED] STIPULATED
COUNTY OF LOS ANGELES, a ) PROTECTIVE ORDER
19 public entity; LOS ANGELES )
COUNTY SHERIFF’S )
20 DEPARTMENT; SHERIFF ROBERT ) Action Filed: June 24, 2024
LUNA, in his individual and official )
21 capacities; SHERIFF SERGIO )
ALOMA, in his individual and official )
22 capacities; VIRGINIA DELGADO, in )
her individual and official capacities; )
23 ROGER MARTIN GALLION, in his )
individual and official capacities; LOS )
24 ANGELES COUNTY )
DEPARTMENT OF HEALTH )
25 SERVICES; and DOES 1 through 50, )
individually, jointly and severally, )
26 )
Defendants. )
27 )
28
1 1. PURPOSES AND LIMITATIONS/GOOD CAUSE STATEMENT
2 A. PURPOSES AND LIMITATIONS
3 Discovery in this action is likely to involve production of confidential,
4 proprietary, or private information for which special protection from public disclosure
5 and from use for any purpose other than prosecuting this litigation would be warranted.
6 Accordingly, the parties hereby stipulate to and petition the Court to enter the following
7 Stipulated Protective Order. The parties acknowledge that this Order does not confer
8 blanket protections on all disclosures or responses to discovery and that the protection
9 it affords from public disclosure and use extends only to the limited information or
10 items that are entitled to a confidential treatment under the applicable legal principles.
11 The parties further acknowledge, as set forth in Section 12.3, below, that this Stipulated
12 Protective Order does not entitle them to file confidential information under seal; Civil
13 Local Rule 79-5 sets forth the procedures that must be followed and the standards that
14 will be applied when a party seeks permission from the court to file material under seal.
15 B. GOOD CAUSE STATEMENT
16 Plaintiffs and the individual Defendants may produce certain documents in this
17 case that contain personal medical, employment or financial information. Such
18 information may implicate the privacy interests of the party and are properly protected
19 through a Fed. R. Civ. P. 26(c) protective order. Seattle Times Co. v. Rhinehart, 467
20 U.S. 20, 35 n.21 (1984) (“Rule 26(c) includes among its express purposes the
21 protection of a ‘party or person from annoyance, embarrassment, oppression or undue
22 burden or expense.’ Although the Rule contains no specific reference to privacy or to
23 other rights or interests that may be implicated, such matters are implicit in the broad
24 purpose and language of the Rule.”); Soto v. City of Concord, 162 F.R.D. 603, 617
25 (N.D. Cal. 1995) (a party’s privacy rights are to be protected through a “carefully
26 crafted protective order.”).
27 As Plaintiffs are seeking and Defendants may produce, among other things,
28 internal, security sensitive, third party and law enforcement private and confidential
1 information, administrative, personnel and institutional documents, which contain
2 sensitive information that the County of Los Angeles believes need special protection
3 from public disclosure. The documents identified in this Protective Order, which
4 Defendants believe in good faith constitute or embody confidential information which
5 the County of Los Angeles maintains as strictly confidential and are otherwise
6 generally unavailable to the public, or which may be privileged or otherwise protected
7 from disclosure under state or federal statutes, court rules, case decisions, or common
8 law, are therefore entitled to heightened protection from disclosure.
9 2. DEFINITIONS
10 2.1 Action: this pending federal law suit.
11 2.2 Challenging Party: a Party or Non-Party that challenges the designation
12 of information or items under this Order.
13 2.3 “CONFIDENTIAL” Information or Items: information (regardless of the
14 medium or how generated, stored, or maintained) or tangible things that qualify for
15 protection under Federal Rule of Civil Procedure 26(c), as specified above in the Good
16 Cause Statement, and other applicable federal privileges.
17 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their
18 support staff).
19 2.5 Designating Party: a Party or Non-Party that designates information or
20 items that it produces in disclosures or in responses to discovery as
21 “CONFIDENTIAL.”
22 2.6 Disclosure or Discovery Material: all items or information, regardless of
23 the medium or manner generated, stored, or maintained (including, among other things,
24 testimony, transcripts, or tangible things), that are produced or generated in disclosures
25 or responses to discovery in this matter.
26 2.7 Expert: a person with specialized knowledge or experience in a matter
27 pertinent to the litigation who has been retained by a Party or its counsel to serve as an
28 expert witness or as a consultant in this Action.
1 2.8 House Counsel: attorneys who are employees of a Party to this Action.
2 House Counsel does not include Outside Counsel of Record or any other outside
3 counsel.
4 2.9 Non-Party: any natural person, partnership, corporation, association, or
5 other legal entity not named as a Party to this action.
6 2.10 Outside Counsel of Record: attorneys who are not employees of a party
7 to this Action but are retained to represent or advise a party to this Action and have
8 appeared in this Action on behalf of that party or are affiliated with a law firm which
9 has appeared on behalf of that party, and includes support staff.
10 2.11 Party: any part to this Action, including all of its officers, directors,
11 employees, consultants, retained experts, and Outside Counsel of Record (and their
12 support staffs).
13 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
14 Discovery Material in this Action.
15 2.13 Professional Vendors: persons or entities that provide litigation support
16 services (e.g., photocopying; videotaping; translating; preparing exhibits or
17 demonstrations; and organizing, storing, or retrieving data in any form or medium) and
18 their employees and subcontractors.
19 2.14 Protected Material: any Disclosure or Discovery Material that is
20 designated as “CONFIDENTIAL.”
21 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material
22 from a Producing Party.
23 3. SCOPE
24 The protections conferred by this Stipulation and Order cover not only Protected
25 Material (as defined above), but also (1) any information copied or extracted from
26 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected
27 Material; and (3) any testimony, conversations, or presentations by Parties or their
28 Counsel that might reveal Protected Material.
1 Any use of Protected Material at trial shall be governed by the Orders of the trial
2 judge. This Order does not govern the use of Protected Material at trial.
3 4. DURATION
4 Once a case proceeds to trial, all of the information that was designated as
5 confidential or maintained pursuant to this protective order becomes public and will be
6 presumptively available to all members of the public, including the press, unless
7 compelling reasons supported by specific factual findings to proceed otherwise are
8 made to the trial judge in advance of the trial. See Kamakana v. City and County of
9 Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing “good cause”
10 showing for sealing documents produced in discovery from “compelling reasons”
11 standard when merits-related documents are part of court record). Accordingly, the
12 terms of this protective order do not extend beyond the commencement of the trial.
13 5. DESIGNATING PROTECTED MATERIAL
14 5.1 Exercise of Restraint and Care in Designating Material for Protection.
15 Each Party or Non-Party that designates information or items for protection under this
16 Order must take care to limit any such designation to specific material that qualifies
17 under the appropriate standards. The Designating Party must designate for protection
18 only those parts of material, documents, items, or oral or written communications that
19 qualify so that other portions of the material, documents, items, or communications for
20 which protection is not warranted are not swept unjustifiably within the ambit of this
21 Order.
22 Mass, indiscriminate, or routine designations are prohibited. Designations that
23 are shown to be clearly unjustified, or that have been made for an improper purpose
24 (e.g., to unnecessarily encumber the case development process or to impose
25 unnecessary expenses and burdens on other parties) may expose the Designating Party
26 to sanctions.
27 If it comes to a Designating Party’s attention that information or items that it
28 designated for protection do not qualify for protection, that Designating Party must
1 promptly notify all other parties that it is withdrawing the inapplicable designation.
2 5.2 Manner and Timing of Designations. Except as otherwise provided in this
3 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated
4 or ordered, Disclosure or Discovery Material that qualifies for protection under this
5 Order must be clearly so designated before the material is disclosed or produced.
6 Designation in conformity with this Order requires:
7 (a) for information in documentary form (e.g., paper or electronic
8 documents, but excluding transcripts of depositions or other pretrial or trial
9 proceedings), that the Producing Party affix at a minimum, the legend
10 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
11 contains protected material. If only a portion or portions of the material on a page
12 qualifies for protection, the Producing Party also must clearly identify the protected
13 portion(s) (e.g., by making appropriate markings in the margins).
14 A Party or Non-Party that makes original documents available for inspection
15 need not designate them for protection until after the inspecting Party has indicated
16 which documents it would like copied and produced. During the inspection and before
17 the designation, all of the material made available for inspection shall be deemed
18 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants
19 copied and produced, the Producing Party must determine which documents, or
20 portions thereof, qualify for protection under this Order. Then, before producing the
21 specified documents, the Producing Party must affix the “CONFIDENTIAL legend”
22 to each page that contains Protected Material. If only a portion or portions of the
23 material on a page qualifies for protection, the Producing Party also must clearly
24 identify the protected portion(s) (e.g., by making appropriate markings in the margins).
25 Markings added to documents pursuant to this paragraph shall not obscure the content
26 or text of the documents produced.
27 (b) for testimony given in depositions that the Designating Party
28 identify the Disclosure or Discovery Material on the record, before the close of the
1 deposition all protected testimony. The court reporter must affix to each such transcript
2 page containing Protected Material the “CONFIDENTIAL legend”, as instructed by
3 the Designating Party.
4 (c) for information produced in some form other than documentary and
5 for any other tangible items, that the Producing Party affix in a prominent place on the
6 exterior of the container or containers in which the information or item is stored the
7 legend “CONFIDENTIAL.” If only a portions or portions of the information or item
8 warrant protection, the Producing Party, to the extent practicable, shall identify the
9 protected portion(s).
10 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
11 failure to designate qualified information or items as “CONFIDENTIAL” does not,
12 standing alone, waive the Designating Party’s right to secure protection under this
13 Stipulation and its associated Order for such material. Upon timely correction of a
14 designation, the Receiving Party must make reasonable efforts to assure that the
15 material is treated in accordance with the provisions of this Order.
16 5.4 Privilege Logs. If a party withholds information that is responsive to a
17 discovery request by claiming that it is privileged or otherwise protected from
18 discovery, that party shall promptly prepare and provide a privilege log that is
19 sufficiently detailed and informative for the opposing party to assess whether a
20 document's designation as privileged is justified. See Fed. R. Civ. P. 26(b)(5). The
21 privilege log shall set forth the privilege relied upon and specify separately for each
22 document or for each category of similarly situated documents:
23 (a) the title and description of the document, including number of pages
24 or Bates- number range;
25 (b) the subject matter addressed in the document;
26 (c) the identity and position of its author(s);
27 (d) the identity and position of all addressees and recipients;
28 (e) the date the document was prepared and, if different, the date(s) on
1 which it was sent to or shared with persons other than its author(s); and
2 (f) the specific basis for the claim that the document is privileged and
3 protected.
4 Communications involving counsel that post-date the filing of the complaint
5 need not be placed on a privilege log.
6 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
7 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
8 designation of confidentiality at any time that is consistent with the Court's Scheduling
9 Order.
10 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
11 resolution process under Local Rule 37.1 et seq. Any discovery motion must strictly
12 comply with the procedures set forth in Local Rules 37-1, 37-2, and 37-3.
13 6.3 Failing informal resolution between parties, the Designating Party may
14 file and serve a Motion for a Protective Order with the Court strictly pursuant to Local
15 Rule 37, including the Joint Stipulation Procedure. The parties agree that if the Motion
16 for Protective Order is filed within 21 days of the written challenge (subject to
17 extension upon agreement of the Parties), the Material will retain its original
18 designation until the Court rules on the Motion for a Protective Order. If the
19 Designating Party does not file a motion within the 21-day period following a
20 challenge, the material is no longer designated as CONFIDENTIAL INFORMATION
21 for purposes of this Stipulation, but that change in designation does not bar the
22 Producing Party from subsequently filing a motion for a protective order.
23 6.4 Withdrawal of “CONFIDENTIAL” Designation. At its discretion, a
24 Designating Party may remove Protected Material from some or all of the protections
25 and provisions of this Stipulated Protective Order at any time by any of the following
26 methods:
27 (a) Express Written Withdrawal. A Designating Party may withdraw a
28 “CONFIDENTIAL” designation made to any specified Protected Material from some
1 or all of the protections of this Stipulated Protective Order by an express withdrawal in
2 writing signed by the Designating Party or Designating Party’s counsel (but not
3 including staff of such counsel) that specifies and itemizes the Disclosure or Discovery
4 Material previously designated as Protected Material that shall not longer be subject to
5 some or all of the provisions of this Stipulated Protective Order. Such express
6 withdrawal shall be effective when transmitted or served upon the Receiving Party. If
7 a Designating Party is withdrawing Protected Material from only some of the
8 provisions/protections of this Stipulated Protective Order, the Designating Party must
9 state which specific provisions are no longer to be enforced as to the specified material
10 for which confidentiality protection hereunder is withdrawn: otherwise, such
11 withdrawal shall be construed as a withdrawal of such material from all of the
12 protections/provisions of this Stipulated Protective Order;
13 (b) Express Withdrawal on the Record. A Designating Party may withdraw
14 a “CONFIDENTIAL” designation made to any specified Protected Material from all
15 of the provisions/protections of this Stipulated Protective Order by verbally consenting
16 in court proceedings on the record to such withdrawal – provided that such withdrawal
17 specifies the Disclosure or Discovery Material previously designated as Protected
18 Material shall no longer be subject to any of the provisions of this Stipulation and
19 Order;
20 (c) Implicit Withdrawal by Publication or Failure to Oppose Challenge. A
21 Designating Party shall be construed to have withdrawn a “CONFIDENTIAL”
22 designation made to any specified Protected Material from all of the
23 provisions/protections of this Stipulated Protective Order by either (1) making such
24 Protected Material part of the public record – including but not limited to attaching
25 such as exhibits to any filing with the court without moving, prior to such filing, for
26 the court to seal such records; or (2) failing to timely oppose a Challenging Party’s
27 motion to remove a “CONFIDENTIAL” designation to specified Protected Material.
28
1 7. ACCESS TO AND USE OF PROTECTED MATERIAL
2 7.1 Basic Principles. A Receiving Party may use Protected Material that is
3 disclosed or produced by another Party or by a Non-Party in connection with this
4 Action only for prosecuting, defending, or attempting to settle this Action. Such
5 Protected Material may be disclosed only to the categories of persons and under the
6 conditions prescribed in this Order. When the Action has been terminated, a Receiving
7 Party must comply with the provisions of section 13 below (FINAL DISPOSITION).
8 Protected Material must be stored and maintained by a Receiving Party at a
9 location and in a secure manner that ensures that access is limited to the persons
10 authorized under this Order.
11 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
12 otherwise ordered by the Court or permitted in writing by the Designating Party, a
13 Receiving Party may disclose any information or item designated “CONFIDENTIAL”
14 only to:
15 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well
16 as employees of such Counsel to whom it is reasonably necessary to disclose the
17 information for this Action;
18 (b) the officers, directors, and employees (including House Counsel) of the
19 Receiving Party to whom disclosure is reasonably necessary for this Action;
20 (c) Experts (as defined in this Order) of the Receiving Party to whom
21 disclosure is reasonably necessary for this Action and who have signed the
22 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
23 (d) the court and its personnel;
24 (e) court reporters and their staff;
25 (f) professional jury or trial consultants, mock jurors, and Professional
26 Vendors to whom disclosure is reasonably necessary for this Action and who have
27 signed the “ Acknowledgment and Agreement to Be Bound” (Exhibit A);
28 (g) the author or recipient of a document containing the information or a
1 custodian or other person who otherwise possessed or knew the information;
2 (h) during their depositions, witnesses, and attorneys for witnesses, in the
3 Action to whom disclosure is reasonably necessary provided: (1) the deposing party
4 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will
5 not be permitted to keep any confidential information unless they sign the
6 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed
7 by the Designating Party or ordered by the court. Pages of transcribed deposition
8 testimony or exhibits to depositions that reveal Protected Material may be separately
9 bound by the court reporter and may not be disclosed to anyone except as permitted
10 under this Stipulated Protective Order; and
11 (i) any mediator or settlement officer, and their supporting personnel,
12 mutually agreed upon by any of the parties engaged in settlement discussions.
13 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
14 IN OTHER LITIGATION
15 If a Party is served with a subpoena or a court order issued in other litigation that
16 compels disclosure of any information or items designated in this Action as
17 “CONFIDENTIAL,” that Party must:
18 (a) promptly notify in writing the Designating Party. Such notification shall
19 include a copy of the subpoena or court order;
20 (b) promptly notify in writing the party who caused the subpoena or order to
21 issue in the other litigation that some or all of the material covered by the subpoena or
22 order is subject to Protective Order. Such notification shall include a copy of this
23 Stipulated Protective Order; and
24 (c) cooperate with respect to all reasonable procedures sought to be pursued by
25 the Designating Party whose Protected Material may be affected.
26 If the Designating Party timely seeks a protective order, the Party served with
27 the subpoena or court order shall not produce any information designated in this action
28 as “CONFIDENTIAL” before a determination by the court from which the subpoena
1 or order issued, unless the Party has obtained the Designating Party’s permission. The
2 Designating Party shall bear the burden and expense of seeking protection in that court
3 of its confidential material and nothing in these provisions should be construed as
4 authorizing or encouraging a Receiving Party in this action to disobey a lawful directive
5 from another court.
6 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
7 PRODUCED IN THIS LITIGATION
8 (a) The terms of this Order are applicable to information produced by a Non-
9 Party in this Action and designated as “CONFIDENTIAL.” Such information produced
10 by Non-Parties in connection with this litigation is protected by the remedies and relief
11 provided by this Order. Nothing in these provisions should be construed as prohibiting
12 a Non-Party from seeking additional protections.
13 (b) In the event that a Party is required, by a valid discovery request, to
14 produce a Non-Party’s confidential information in its possession, and the Party is
15 subject to an agreement with the Non-Party not to produce the Non-Party’s confidential
16 information, then the Party shall:
17 (1) promptly notify in writing the Requesting Party and the Non-Party
18 that some or all of the information requested is subject to a confidentiality agreement
19 with a Non-Party;
20 (2) promptly provide the Non-Party with a copy of the Stipulated
21 Protective Order in this Action, the relevant discovery request(s), and a reasonably
22 specific description of the information requested; and
23 (3) make the information requested available for inspection by the
24 Non-Party, if requested.
25 (c) If the Non-Party fails to seek a protective order from this court within 14
26 days of receiving the notice and accompanying information, the Receiving Party may
27 produce the Non-Party’s confidential information responsive to the discovery request.
28 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce
1 any information in its possession or control that is subject to the confidentiality
2 agreement with the Non-Party before a determination by the court. Absent a court order
3 to the contrary, the Non-Party shall bear the burden and expense of seeking protection
4 in this court of its Protected Material.
5 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
6 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
7 Protected Material to any person or in any circumstance not authorized under this
8 Stipulation and Order, the Receiving Party must immediately: (a) notify in writing the
9 Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve all
10 unauthorized copies of the Protected Material, (c) inform the person or persons to
11 whom unauthorized disclosures were made of all the terms of this Order, and (d)
12 request such person or persons execute the Acknowledgement and Agreement to Be
13 Bound” that is attached hereto as Exhibit A.
14 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
15 PROTECTED MATERIAL
16 When a Producing Party gives notice to Receiving Parties that certain
17 inadvertently produced material is subject to a claim of privilege or other protection,
18 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
19 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
20 may be established in an e-discovery order that provides for production without prior
21 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
22 parties reach an agreement on the effect of disclosure of a communication or
23 information covered by the attorney-client privilege or work product protection, the
24 parties may incorporate their agreement in the stipulated protective order submitted to
25 the court.
26 12. MISCELLANEOUS
27 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
28 person to seek modification by the Court in the future.
1 12.2 Right to Assert Other Objections. By stipulating to the entry of this
2 Protective Order no Party waives any right it otherwise would have to object to
3 disclosing or producing any information or item on any ground not addressed in this
4 Stipulated Protective Order. Similarly, no Party waives any right to object on any
5 ground to use in evidence of any of the material covered by this Protective Order.
6 12.3 Filing of Protected Material. A party that seeks to file under seal any
7 Protected Material must comply with Civil Local Rule 79-5. Protected Material may
8 only be filed under seal pursuant to a court order authorizing the sealing of the specific
9 Protected Material at issue. If a Party’s request to file Protected Material under seal is
10 denied by the court, then the Receiving Party may file the information in the public
11 record unless otherwise instructed by the court.
12 13. FINAL DISPOSITION
13 After the final disposition of this Action, as defined in paragraph 4, within 60
14 days of a written request by the Designating Party, each Receiving Party must return
15 all Protected Material to the Producing Party or destroy such material. As used in this
16 subdivision, “all Protected Material” includes all copies, abstracts, compilations,
17 summaries, and any other format reproducing or capturing any of the Protected
18 Material. Whether the Protected Material is returned or destroyed, the Receiving Party
19 must submit a written certification to the Producing Party (and, if not the same person
20 or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by
21 category, where appropriate) all the Protected Material that was returned or destroyed
22 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
24 Protected Material. Notwithstanding this provision, Counsel are entitled to retain an
25 archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts,
26 legal memoranda, correspondence, deposition and trial exhibits, expert reports,
27 attorney work product, and consultant and expert work product, even if such materials
28 contain Protected Material. Any such archival copies that contain or constitute
1 |] Protected Material remain subject to this Protective Order as set forth in Section 4
2 || (DURATION).
3 Any violation of this Order may be punished by any and all appropriate measures
4 || including, without limitation, contempt proceedings and/or monetary sanctions.
5
6 || Respectfully submitted,
7
8 || Dated: July 31, 2025 GASTELUM LAW, APC
9 ae
10 By:
Denisse O. Gastélum, Esq.
11 Selene Estrada-Villela, Esq.
D Attorneys for Plaintiffs,
ESTATE OF MAXWELL AGUIRRE, by and
13 through successors in interest, Omar Aguirre and
14 Yvette Aguirre; OMAR AGUIRRE, individually; and
YVETTE AGUIRRE, individually
15
16 || Dated: July 31, 2025 O’HARA LAW, APC,
17 / p Y
18 By:
19 Kevifi O’ Hara, Esq.
Attorneys for Plaintiffs,
20 ESTATE OF MAXWELL AGUIRRE, by and
>] through successors in interest, Omar Aguirre and
Yvette Aguirre; OMAR AGUIRRE, individually; and
22 YVETTE AGUIRRE, individually
23
24 |! Dated: July 31, 2025 LAW OFFICES OF BRIAN HURWITZ
25
26 By: /s/ Brian Hurwitz
4 Brian Hurwitz, Esq.
Attorneys for Plaintiffs,
28
15
1 ESTATE OF MAXWELL AGUIRRE, by and
through successors in interest, Omar Aguirre and
2 Yvette Aguirre; OMAR AGUIRRE, individually; and
YVETTE AGUIRRE, individually
3
4
Dated: July 31, 2025 COLLINS + COLLINS LLP
5
6
By: /s/ Chandler A. Parker
7 Tomas A. Guterres, Esq.
Chandler A. Parker, Esq.
8
Attorneys for Defendants,
9 COUNTY OF LOS ANGELES, et al.
10
11
12
13
HAVING CONSIDERED THE STIPULATION OF THE PARTIES, AND
14
GOOD CAUSE APPEARING, IT IS SO ORDERED:
15
DATE: __________A_ug_u_s_t _1_, 2025 ____________________________________
16
The Hon. A. Joel Richlin
17
Magistrate Judge
18
19
20
21
22
23
24
25
26
27
28
1 EXHIBIT A
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
2
3 I, _____________________________ [print or type full name], of
4 _________________ [print or type full address], declare under penalty of perjury that
5 I have read in its entirety and understand the Stipulated Protective Order that was issued
6 by the United States District Court for the Central District of California on [date] in the
7 case of ___________ [insert formal name of the case and the number and initials
8 assigned to it by the court]. I agree to comply with and to be bound by all the terms of
9 this Stipulated Protective Order and I understand and acknowledge that failure to so
10 comply could expose me to sanctions and punishment in the nature of contempt. I
11 solemnly promise that I will not disclose in any manner any information or item that is
12 subject to this Stipulated Protective Order to any person or entity except in strict
13 compliance with the provisions of this Order. I further agree to submit to the
14 jurisdiction of the United States District Court for the Central District of California for
15 the purpose of enforcing the terms of this Stipulated Protective Order, even if such
16 enforcement proceedings occur after termination of this action. I hereby appoint
17 __________________________ [print or type full name] of
18 _______________________________________ [print or type full address and
19 telephone number] as my California agent for service of process in connection with
20 this action or any proceedings related to enforcement of this Stipulated Protective
21 Order.
22 Date: ______________________________________
23 City and State where sworn and signed: _________________________________
24
25 Printed name: _______________________________
26
Signature: __________________________________
27
28