The opinion
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UNITED STATES DISTRICT COURT
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CENTRAL DISTRICT OF CALIFORNIA -
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WESTERN DIVISION
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5 GINA YOUNGBLOOD, EUGENIA CASE NO. 2:25-cv-04413-WLH (MBK)
YOUNGBLOOD, JANEL [Assigned to Hon. Wesley L. Hsu, Dept. 9B1
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HERNDERSON, and JAMIE
7 HENDERSON, INDIVIDUALLY DISCOVERY MATTER
AND AS SUCCESSORS IN
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INTEREST TO EUGENE [PROPOSED] STIPULATED
9 YOUNGBLOOD, DECEASED, PROTECTIVE ORDER
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Plaintiffs,
11 Complaint Filed: 05/16/2025
VS. Trial Date: None
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13 COUNTY OF LOS ANGELES, and
DOES 1-10,
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15 Defendants.
16 Pursuant to Federal Rule of Civil
17 Procedure 26(cc), Plaintiffs Gina Youngblood, Eugenia Youngblood, Janel Henderson,
and Jamie Henderson and Defendant County of Los Angeles (collectively, the Parties)
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19 hereby stipulate to, and move the Court to enter, this Protective Order', on the grounds
that the discovery sought is highly sensitive.
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21 1. GENERAL
22 1.1 Purposes and Limitations
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 disclosure
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and from use for any purpose other than prosecuting this litigation may be warranted.
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Accordingly, the Parties hereby stipulate to and petition the Court to enter the following
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Stipulated Protective Order. The Parties acknowledge that this Order does
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1 This Stipulated Protective Order is substantially based on the motel protective order published and used throughout the
Central District.
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1 not confer blanket protections on all disclosures or responses to discovery and that the
2 protection it affords from public disclosure and use extends only to the limited
3 information or items that are entitled to confidential treatment under the applicable legal
4 principles. The Parties further acknowledge, as set forth in Section 12.3, below, that this
5 Stipulated Protective Order does not entitle them to file confidential information under
6 seal; Civil Local Rule 79-5 sets forth the procedures that must be followed and the
7 standards that will be applied when a Party seeks permission from the court to file material
8 under seal.
9 1.2 Good Cause Statement
10 This action involves the County of Los Angeles and peace officers employed by
11 Los Angeles Sheriff Department. Plaintiff will seek materials and information the
12 County of Los Angeles ("County") maintains as confidential, such as personnel files of
13 the officers involved in the Incident, Internal Affairs materials and information, video
14 recordings, local criminal history information, body work camera footage, criminal
15 investigative files, and other administrative materials and other information that the
16 County believes needs special protection from public disclosure and from use for any
17 purpose other than prosecuting this litigation is warranted. Such confidential and
18 proprietary materials and information consist of, among other things, confidential
19 business, information regarding confidential business practices, or other confidential
20 commercial information (including information implicating privacy rights of third
21 Parties), information otherwise generally unavailable to the public, or which may be
22 privileged or otherwise protected from disclosure under state or federal statutes, court
23 rules, case decisions, or common law. Accordingly, to expedite the flow of information,
24 to facilitate the prompt resolution of disputes over confidentiality of discovery materials,
25 to adequately protect information the Parties are entitled to keep confidential, to ensure
26 that the Parties are permitted reasonable necessary uses of such material in preparation
27 for and in the conduct of trial, to address their handling at the end of the litigation, and
28 serve the ends of justice, a protective order for such
1 information is justified in this matter. It is the intent of the Parties that information will
2 not be designated as confidential for tactical reasons and that nothing be so designated
3 without a good faith belief that it has been maintained in a confidential, non-public
4 manner, and there is good cause why it should not be part of the public record of this
5 case.
6 2. DEFINITIONS
7 2.1 Action: Gina Youngblood, et al., v. County of Los Angeles, et al.
8 2.2 Challenging Party: a Party or Non-Party that challenges the designation
9 of information or items under this Order.
10 2.3 "CONFIDENTIAL" Information or Items: information (regardless of
11 how it is generated, stored or maintained) or tangible things that qualify for protection
12 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good
13 Cause Statement.
14 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their
15 support staff).
16 2.5 Designating Party: a Party or Non-Party that designates information or
17 items that it produces in disclosures or in responses to discovery as
18 "CONFIDENTIAL."
19 2.6 Disclosure or Discovery Material: all items or information, regardless of
20 the medium or manner in which it is generated, stored, or maintained (including,
21 among other things, testimony, transcripts, and tangible things), that are produced or
22 generated in disclosures or responses to discovery in this matter.
23 2.7 Expert: a person with specialized knowledge or experience in a matter
24 pertinent to the litigation who has been retained by a Party or its counsel to serve as an
25 expert witness or as a consultant in this Action.
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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 to
7 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 that has
9 appeared on behalf of that Party, including support staff.
10 2.11 Party: any Party 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 designated
20 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 Counsel
28 that might reveal Protected Material.
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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 court-filed information to be introduced
5 that was previously designated as confidential or maintained pursuant to this protective
6 order becomes public and will be presumptively available to all members of the public,
7 including the press, unless compelling reasons supported by specific factual findings to
8 proceed otherwise are made to the trial judge in advance of the trial. See Kamakana v.
9 City and Cty. of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing "good
10 cause" showing for sealing documents produced in discovery from "compelling reasons"
11 standard when merits-related documents are part of court record). Accordingly, the terms
12 of this protective order do not extend beyond the commencement of the trial. The fact a
13 document was designated as confidential will not impact the admissibility of any trial
14 documents.
15 5. DESIGNATING PROTECTED MATERIAL
16 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each
17 Party or Non-Party that designates information or items for protection under this Order
18 must take care to limit any such designation to specific material that qualifies under the
19 appropriate standards. The Designating Party must designate for protection only those
20 parts of material, documents, items, or oral or written communications that qualify so
21 that other portions of the material, documents, items, or communications for which
22 protection is not warranted are not swept unjustifiably within the ambit of this Order. If
23 there is a challenge to the confidentiality designation the counsel making such
24 designation will have the burden of demonstrating that the document(s) is (are) actually
25 confidential.
26 Mass, indiscriminate, or routinized designations are prohibited. Designations that
27 are shown to be clearly unjustified or that have been made for an improper purpose (e.g.,
28 to unnecessarily encumber the case development process or to impose
1 unnecessary expenses and burdens on other parties) may expose the Designating Party
2 to sanctions.
3 If it comes to a Designating Party's attention that information or items that it
4 designated for protection do not qualify for protection, that Designating Party must
5 promptly notify all other Parties that it is withdrawing the inapplicable designation.
6 5.2 Manner and Timing of Designations. Except as otherwise provided in this
7 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated
8 or ordered, Disclosure or Discovery Material that qualifies for protection under this
9 Order must be clearly so designated before the material is disclosed or produced.
10 However, the designation shall not cover up any portion of the documents that are
11 designated as confidential.
12 Designation in conformity with this Order requires:
13 (a) for information in documentary form (e.g., paper or electronic
14 documents, but excluding transcripts of depositions or other pretrial or trial
15 proceedings), that the Producing Party affix, at a minimum, the legend
16 "CONFIDENTIAL" (hereinafter "CONFIDENTIAL legend"), to each page that
17 contains protected material. If only a portion or portions of the material on a page
18 qualifies for protection, the Producing Party also must clearly identify the protected
19 portion(s) (e.g., by making appropriate markings in the margins).
20 A Party or Non-Party that makes original documents available for inspection need
21 not designate them for protection until after the inspecting Party has indicated which
22 documents it would like copied and produced. During the inspection and before the
23 designation, all of the material made available for inspection shall be deemed
24 "CONFIDENTIAL." After the inspecting Party has identified the documents it wants
25 copied and produced, the Producing Party must determine which documents, or portions
26 thereof, qualify for protection under this Order. Then, before producing the specified
27 documents, the Producing Party must affix the "CONFIDENTIAL legend" to each page
28 that contains Protected Material. If only a portion or portions of the
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1 material on a page qualifies for protection, the Producing Party also must clearly identify
2 the protected portion(s) (e.g., by making appropriate markings in the margins).
3 (b) for testimony given in depositions that the Designating Party identify
4 the Disclosure or Discovery Material on the record, before the close of the deposition.
5 (c) for information produced in some form other than documentary and for
6 any other tangible items, that the Producing Party affix in a prominent place on the
7 exterior of the container or containers in which the information is stored the legend
8 "CONFIDENTIAL." If only a portion or portions of the information warrants protection,
9 the Producing Party, to the extent practicable, shall identify the protected portion(s).
10 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
11 failure to designate qualified information or items does not, standing alone, waive the
12 Designating Party's right to secure protection under this Order for such material. Upon
13 timely correction of a designation, the Receiving Party must make reasonable efforts to
14 assure that the material is treated in accordance with the provisions of this Order.
15 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
16 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
17 designation of confidentiality at any time that is consistent with the Court's Scheduling
18 Order.
19 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
20 resolution process under Local Rule 37-1, et seq, as modified by Judge Kaufman's
21 Procedures. See https://www.cacd.uscourts.gov/honorable-michael-b-kaufman. Any
22 discovery motion must strictly comply with these procedures.
23 6.3 Burden. The burden of persuasion in any such challenge proceeding shall
24 be on the Designating Party. Frivolous challenges, and those made for an improper
25 purpose (e.g., to harass or impose unnecessary expenses and burdens on other parties)
26 may expose the Challenging Party to sanctions. Unless the Designating Party has waived
27 or withdrawn the confidentiality designation, all parties shall continue to afford
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[PROPOSED] STIPULATED PROTECEIVE ORDER
1 the material in question the level of protection to which it is entitled under the
2 Producing Party's designation until the Court rules on the challenge.
3 7. ACCESS TO AND USE OF PROTECTED MATERIAL
4 7.1 Basic Principles. A Receiving Party may use Protected Material that is
5 disclosed or produced by another Party or by a Non-Party in connection with this Action
6 only for prosecuting, defending, or attempting to settle this Action. Such Protected
7 Material may be disclosed only to the categories of persons and under the conditions
8 described in this Order. When the Action has been terminated, a Receiving Party must
9 comply with the provisions of section 13 below (FINAL DISPOSITION).
10 Protected Material must be stored and maintained by a Receiving Party at a location
11 and in a secure manner that ensures that access is limited to the persons authorized under
12 this Order.
13 7.2 Disclosure of "CONFIDENTIAL" Information or Items. Unless
14 otherwise ordered by the Court or permitted in writing by the Designating Party, a
15 Receiving Party may disclose any information or item designated "CONFIDENTIAL"
16 only to:
17 (a) the Receiving Party's Outside Counsel of Record in this Action, as well
18 as employees of said Outside Counsel of Record to whom it is reasonably necessary to
19 disclose the information for this Action;
20 (b) the officers, directors, and employees (including House Counsel) of the
21 Receiving Party to whom disclosure is reasonably necessary for this Action as well as the
22 plaintiffs;
23 (c) Experts (as defined in this Order) of the Receiving Party to whom
24 disclosure is reasonably necessary for this Action and who have signed the
25 "Acknowledgment and Agreement to Be Bound" (Exhibit A);
26 (d) the Court and its personnel;
27 (e) court reporters and their staff
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1 (f) professional jury or trial consultants, mock jurors, and Professional
2 Vendors to whom disclosure is reasonably necessary for this Action and who have
3 signed the "Acknowledgment and Agreement to Be Bound" (Exhibit A);
4 (g) the author or recipient of a document containing the information or a
5 custodian or other person who otherwise possessed or knew the information;
6 (h) during their depositions, witnesses, and attorneys for witnesses, in the
7 Action to whom disclosure is reasonably necessary provided: (1) the deposing party
8 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will
9 not be permitted to keep any confidential information unless they sign the
10 "Acknowledgment and Agreement to Be Bound" (Exhibit A), unless otherwise agreed
11 by the Designating Party or ordered by the Court. Pages of transcribed deposition
12 testimony or exhibits to depositions that reveal Protected Material may be separately
13 bound by the court reporter and may not be disclosed to anyone except as permitted
14 under this Stipulated Protective Order; and
15 (i) any mediator or settlement officer, and their supporting personnel,
16 mutually agreed upon by any of the parties engaged in settlement discussions.
17 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
18 PRODUCED
19 IN OTHER LITIGATION
20 If a Party is served with a subpoena or a court order issued in other litigation that
21 compels disclosure of any information or items designated in this Action as
22 "CONFIDENTIAL," that Party must:
23 (a) promptly notify in writing the Designating Party. Such notification shall
24 include a copy of the subpoena or court order;
25 (b) promptly notify in writing the party who caused the subpoena or order to
26 issue in the other litigation that some or all of the material covered by the subpoena or
27 order is subject to this Protective Order. Such notification shall include a copy of this
28 Stipulated Protective Order; and
1 (c) cooperate with respect to all reasonable procedures sought to be pursued by
2 the Designating Party whose Protected Material may be affected.
3 If the Designating Party timely seeks a protective order, the Party served with the
4 subpoena or court order shall not produce any information designated in this action as
5 "CONFIDENTIAL" before a determination by the court from which the subpoena or
6 order issued, unless the Party has obtained the Designating Party's permission. The
7 Designating Party shall bear the burden and expense of seeking protection in that court of
8 its confidential material and nothing in these provisions should be construed as
9 authorizing or encouraging a Receiving Party in this Action to disobey a lawful directive
10 from another court. If there is a court order to produce documents in another case, the
11 party subject to that order shall comply with that order notwithstanding this protective
12 order.
13 9.A NON-PARTY'S PROTECTED MATERIAL SOUGHT TO BE PRODUCED
14 IN THIS LITIGATION
15 (a) The terms of this Order are applicable to information produced by a Non-
16 Party in this Action and designated as "CONFIDENTIAL." Such information produced
17 by Non-Parties in connection with this litigation is protected by the remedies and relief
18 provided by this Order. Nothing in these provisions should be construed as prohibiting
19 a Non-Party from seeking additional protections.
20 (b) In the event that a Party is required, by a valid discovery request, to produce
21 a Non-Party's confidential information in its possession, and the Party is subject to an
22 agreement with the Non-Party not to produce the Non-Party's confidential information,
23 then the Party shall:
24 (1)promptly notify in writing the Requesting Party and the Non-Party that
25 some or all of the information requested is subject to a confidentiality agreement with
26 a Non-Party;
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1 (2) promptly provide the Non-Party with a copy of the Stipulated
2 Protective Order in this Action, the relevant discovery request(s), and a reasonably
3 specific description of the information requested; and
4 (0) make the information requested available for inspection by the Non-
5 Party, if requested.
6 (c) If the Non-Party fails to seek a protective order from this Court within seven
7 days of receiving the notice and accompanying information, the Receiving Party may
8 produce the Non-Party's confidential information responsive to the discovery request. If
9 the Non-Party timely seeks a protective order, the Receiving Party shall not produce any
10 information in its possession or control that is subject to the confidentiality agreement
11 with the Non-Party before a determination by the Court. Absent a court order to the
12 contrary, the Non-Party shall bear the burden and expense of seeking protection in this
13 Court of its Protected Material.
14 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
15 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
16 Protected Material to any person or in any circumstance not authorized under this
17 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing
18 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve
19 all unauthorized copies of the Protected Material, (c) inform the person or persons to
20 whom unauthorized disclosures were made of all the terms of this Order, and (d) request
21 such person or persons to execute the "Acknowledgment and Agreement to Be Bound"
22 that is attached hereto as Exhibit A.
23 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
24 PROTECTED MATERIAL
25 When a Producing Party gives notice to Receiving Parties that certain
26 inadvertently produced material is subject to a claim of privilege or other protection,
27 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
28 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
1 may be established in an e-discovery order that provides for production without prior
2 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
3 parties reach an agreement on the effect of disclosure of a communication or information
4 covered by the attorney-client privilege or work product protection, the parties may
5 incorporate their agreement in the stipulated protective order submitted to the Court.
6 12. MISCELLANEOUS
7 12.1 Right to Further Relief. Nothing in this Order abridges the right of any person
8 to seek its modification by the Court in the future.
9 12.2 Right to Assert Other Objections. By stipulating to the entry of this Protective
10 Order, no Party waives any right it otherwise would have to object to disclosing or
11 producing any information or item on any ground not addressed in this Stipulated
12 Protective Order. Similarly, no Party waives any right to object on any ground to use in
13 evidence of any of the material covered by this Protective Order.
14 12.3 Filing Protected Material. A Party that seeks to file under seal any Protected
15 Material must comply with Civil Local Rule 79-5. Protected Material may only be filed
16 under seal pursuant to a court order authorizing the sealing of the specific Protected
17 Material at issue; good cause must be shown in the request to file under seal. If a Party's
18 request to file Protected Material under seal is denied by the Court, then the Receiving
19 Party may file the information in the public record unless otherwise instructed by the
20 Court.
21 13. FINAL DISPOSITION
22 After the final disposition of this Action, within 60 days of a written request by
23 the Designating Party, each Receiving Party must return all Protected Material to the
24 Producing Party or destroy such material. As used in this subdivision, "all Protected
25 Material" includes all copies, abstracts, compilations, summaries, and any other format
26 reproducing or capturing any of the Protected Material. Whether the Protected Material
27 is returned or destroyed, the Receiving Party must submit a written
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[PROPOSED] STIPULATED PROTECEIVE ORDER
1 |\certification to the Producing Party (and, if not the same person or entity, to the
2 ||Designating Party) by the 60 day deadline that (1) identifies (by category, where
3 llappropriate) all the Protected Material that was returned or destroyed, and (2) affirms
4 |\that the Receiving Party has not retained any copies, abstracts, compilations, summaries
|lor any other format reproducing or capturing any of the Protected Material.
© |\Notwithstanding this provision, counsel are entitled to retain an archival copy of all
|I\pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda,
% |\correspondence, deposition and trial exhibits, expert reports, attorney work product,
|land consultant and expert work product, even if such materials contain Protected
1U |/Material. Any such archival copies that contain or constitute Protected Material remain
11 |\subject to this Protective Order as set forth in Section 4 (DURATION).
TZ |i///
|i///
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[PROPOSED] STIPULATED PROTECEIVE ORDER
1 1/14. VIOLATION OF ORDER
2 Any violation of this Order may be punished by any and all appropriate measures
3 |lincluding, without limitation, contempt proceedings and/or monetary sanctions.
|ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD.
5
6 DATED: 9/16/25 BRAD GAGE LAW. AP
8 By:
\BRABEEY C. GAGE
9 \rtorneys for Plaintiffs
10 Gina Youngblood, Eugenia Youngblood, Janel
Henderson, & Jamie Henderson
DATED: [Category] COLLINS + COLLINS LLP
12 9/16/25
14 By: _MALTHA E, MARTINEZ
TOMAS A. GUTERRES
15 Attorneys for Defendant
16 COUNTY OF LOS ANGELES
47_||{T ISSO ORDERED.
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4g ||DATED: September 18, 2025 ~
MICHAEL B. KAUFMAN
20 UNITED STATES MAGISTRATE JUDGE
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[PROPOSED] STIPULATED PROTECEIVE ORDER
1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3 _____________________________________________ [print or type full name],
4 of _____________________ [print or type full address], declare under penalty of perjury
5 that I have read in its entirety and understand the Stipulated Protective Order that was
6 issued by the United States District Court for the Central District of California on [date]
7 in the case Of EUGENIA YOUNGBLOOD, ET AL., V, COUNTY OF LOS ANGELES,
8 ET AL., CASE NO. 2:25-cv-04413-WLH (MBK). I agree to comply with and to be
9 bound by all the terms of this Stipulated Protective Order and I understand and
10 acknowledge that failure to so comply could expose me to sanctions and punishment in
11 the nature of contempt. I solemnly promise that I will not disclose in any manner any
12 information or item that is subject to this Stipulated Protective Order to any person or
13 entity except in strict compliance with the provisions of this Order. I further agree to
14 submit to the jurisdiction of the United States District Court for the Central District of
15 California for the purpose of enforcing the terms of this Stipulated Protective Order, even
16 if such enforcement proceedings occur after termination of this
17 action. I hereby appoint ______________________________ [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 this
20 action or any proceedings related to enforcement of this Stipulated Protective Order.
21 Date:
22 City and State where sworn and signed:
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24 Printed name:
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Signature:
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[PROPOSED] STIPULATED PROTECEIVE ORDER
PROOF OF SERVICE
1 (CCP §§ 1013(a) and 2015.5; FRCP 5)
State of California,
2 SS.
County of Los Angeles.
3 I am employed in the County of Los Angeles. I am over the age of 18 and not a party to the within action. My business
4 address is 790 E. Colorado Boulevard, Suite 600, Pasadena, CA 91101.
On this date, I served the foregoing document described as PROPOSED] STIPULATED PROTECTIVE ORDER on the
5 interested parties in this action by placing same in a sealed envelope, addressed as follows:
6 SEE ATTACHED SERVICE LIST
e (BY MAIL.) - I caused such envelope(s) with postage thereon fully prepaid to be placed in the United States mail in Pasadena.
7 California to be served on the parties as indicated on the attached service list. | am "readily familiar" with the firm's practice of
collection and processing correspondence for mailing. Under that practice, it would be deposited with the U.S. Postal Service
8 on that same day with postage thereon fully prepaid at Pasadena, California in the ordinary course of business. I am aware that
on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day
9 after date of deposit for mailing in affidavit.
D{(BY CERTIFIED MAILI- I caused such envelope(s) with postage thereon fully prepaid via Certified Mail Return Receipt
10 Requested to be placed in the United States Mail in Pasadena, California.
11 O FEDERAL EXPRESS - I caused the envelope to be delivered to an authorized courier or driver authorized to receive documents
with delivery fees provided for.
12 x (BY ELECTRONIC FILING AND/OR SERVICE) -I I served a true copy, with all exhibits, electronically on designated
3 recipients listed on the attached service list.
e (ELECTRONIC SERVICE PER CODE CIV. PROC., 1010.6) - By prior consent or request or as required by rules of
14 court (Code Civ. Proc., § 1010.6 (amended Jan. 1, 2021); Code Civ. Proc., § 1013(g); Cal. Rules of Court, rule 2.251(a)).
15 e {BY PERSONAL SERVICEI - I caused such envelope(s) to be delivered by hand to the office(s) of the addressee(s).
16 Executed on 9/16/25 at Pasadena, California.
17 e (STATE) - I declare under penalty of perjury under the laws of the State of California that the above is true and correct.
e (FEDERAL) - I declare that Iam employed in the office of a member of the bar of this court at whose direction the service
18 was made.
19
20 Yesenia Ramirez
Yramirez@ccllp.law
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[PROPOSED] STIPULATED PROTECEIVE ORDER
1 GINA YOUCNaGseB NLuOmObDer V: 2. :C2O5-UcvN-0T4Y4 1O3F-W LLOHS (AMNBGKE)L ES
CCLLP File Number: 27432
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SERVICE LIST
3
Bradley C. Gage
Milad Sadr
4 BRAD GAGE LAW, APC
23002 Victory Boulevard
5 Woodland Hills, CA 91367
T: (818) 340-9252 - F: (818) 340-9088
6 brad@bradgagelaw.com
milad@bradgagelaw.com
yanira@bradgagelaw.com
7 sarah@bradgagelaw.com
gabriela@bradgagelaw.com
8 ATTORNEYS FOR PLAINTIFFS, GINA
YOUNGBLOOD, EUGENIA YOUNGBLOOD,
9 JANEL HERNDERSON, and JAMIE HENDERSON
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