a party’s privacy rights are to be protected 24 through a “carefully crafted protective order.”
How later courts described this case
- a party’s privacy rights are to be protected 24 through a “carefully crafted protective order.”
Written by the judges who cited it.
The opinion
1 Denisse O. Gastélum, SBN 282771 Christian Contreras, SBN 330269
2 Selene Estrada-Villela, SBN 354994 LAW OFFICES OF CHRISTIAN CONTRERAS
GASTÉLUM LAW, APC PROFESSIONAL LAW CORPORATION
3 A PROFESSIONAL CORPORATION 360 E. 2nd St., 8th Floor
3767 Worsham Ave. Los Angeles, California 90012
4 Long Beach, California 90808 Tel: (323) 435-8000
Tel: (213) 340-6112 Fax: (323) 597-0101
5 Fax: (213) 402-8622 Email: CC@Contreras-Law.com
Email: dgastelum@gastelumfirm.com
6
7 Attorneys for Plaintiffs,
ESTATE OF IGNACIO LEMUS, by and through successor in interest, MARIA
8 LUISA ROBLES DIAS; MARIA LUISA ROBLES DIAS, individually; JOSEFINA
SEGURA, individually
9
10 UNITED STATES DISTRICT COURT
11 THE CENTRAL DISTRICT OF CALIFORNIA
12
ESTATE OF IGNACIO LEMUS, by ) CASE NO.: 8:25-cv-00410-DOC-DFM
13 and through successor in interest, ) [Assigned to the Hon. David O. Carter,
MARIA LUISA ROBLES DIAS; ) District Judge; Referred to the Hon.
14 MARIA LUISA ROBLES DIAS, ) Douglas F. McCormick, Magistrate Judge]
individually; JOSEFINA SEGURA, )
15 individually, ) DISCOVERY MATTER
)
16 Plaintiffs, )
)
17 v. ) STIPULATED PROTECTIVE ORDER
)
18 ORANGE COUNTY SHERIFF’S )
DEPARTMENT; a public entity; )
19 ORANGE COUNTY, a public entity; )
SHERIFF DON BARNES, )
20 individually; DEPUTY S. WERT; )
individually; DEPUTY M. )
21 ANDREWS; individually; DEPUTY )
TREADWELL, individually; and )
22 DOES 1-20, individually, jointly and )
severally, )
23 Defendants. )
)
24 )
)
25 )
26
27
28
1 1. A. PURPOSES AND LIMITATIONS
2 Discovery in this action is likely to involve production of confidential,
3 proprietary, or private information for which special protection from public
disclosure and from use for any purpose other than prosecuting this litigation may be
4
warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter
5
the following Stipulated Protective Order. The parties acknowledge that this Order
6
does not confer blanket protections on all disclosures or responses to discovery and
7
that the protection it affords from public disclosure and use extends only to the limited
8
information or items that are entitled to confidential treatment under the applicable
9
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 a file confidential
11
information under seal; Civil Local Rule 79-5 sets forth the procedures that must be
12
followed and the standards that will be applied when a party seeks permission from
13
the court to file material under seal.
14
B. GOOD CAUSE STATEMENT
15 Plaintiffs and the individual Defendants may produce certain documents in this
16 case that contain personal medical, employment or financial information. Such
17 information may implicate the privacy interests of the party and are properly
18 protected through a Fed. R. Civ. P. 26(c) protective order. Seattle Times Co. v.
19 Rhinehart, 467 U.S. 20, 35 n.21 (1984) (“Rule 26(c) includes among its express
20 purposes the protection of a ‘party or person from annoyance, embarrassment,
21 oppression or undue burden or expense.’ Although the Rule contains no specific
22 reference to privacy or to other rights or interests that may be implicated, such matters
are implicit in the broad purpose and language of the Rule.”); Soto v. City of Concord,
23
162 F.R.D. 603, 617 (N.D. Cal. 1995) (a party’s privacy rights are to be protected
24
through a “carefully crafted protective order.”).
25
2. DEFINITIONS
26
2.1 Action: This pending federal lawsuit, Estate of Ignacio Lemus, et al. v.
27
Orange County Sheriff’s Department, et al.; Case No. 8:25-cv-00410-DOC-DFM.
28
1 2.2 Challenging Party: a Party or Non-Party that challenges the designation
2 of information or items under this Order.
3 2.3 “CONFIDENTIAL” Information or Items: information (regardless of
4 how it is generated, stored, or maintained) or tangible things that qualify for
5 protection under Federal Rule of Civil Procedure 26(c), and as specified above in the
6 Good Cause Statement.
7 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as
8 their support staff).
9 2.5 Designating Party: a Party or Non-Party that designates information or
10 items that it produces in disclosures or in responses to discovery as
11 “CONFIDENTIAL.”
12 2.6 Disclosure or Discovery Material: all items or information, regardless
13 of the medium or manner in which it is generated, stored, or maintained (including,
14 among other things, testimony, transcripts, and tangible things), that are produced or
15 generated in disclosures or responses to discovery in this matter.
16 2.7 Expert: a person with specialized knowledge or experience in a matter
17 pertinent to the litigation who has been retained by a Party or its counsel to serve as
18 an expert witness or as a consultant in this Action.
19 2.8 House Counsel: attorneys who are employees of a party to this Action.
20 House Counsel does not include Outside Counsel of Record or any other outside
21 counsel.
22 2.9 Non-Party: any natural person, partnership, corporation, association, or
23 other legal entity not named as a Party to this action.
24 2.10 Outside Counsel of Record: attorneys who are not employees of a party
25 to this Action but are retained to represent or advise a party to this Action and have
26 appeared in this Action on behalf of that party or are affiliated with a law firm which
27 has appeared on behalf of that party, including support staff.
28 2.11 Party: any party to this Action, including all of its officers, directors,
1 employees, consultants, retained experts, and Outside Counsel of Record (and their
2 support staffs).
3 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
4 Discovery Material in this Action.
5 2.13 Professional Vendors: persons or entities that provide litigation support
6 services (e.g., photocopying, videotaping, translating, preparing exhibits or
7 demonstrations, and organizing, storing, or retrieving data in any form or medium)
8 and their employees and subcontractors.
9 2.14 Protected Material: any Disclosure or Discovery Material that is
10 designated as “CONFIDENTIAL.”
11 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material
12 from a Producing Party.
13 3. SCOPE
14 The protections conferred by this Stipulation and Order cover not only
15 Protected Material (as defined above), but also (1) any information copied or
extracted from Protected Material; (2) all copies, excerpts, summaries, or
16
compilations of Protected Material; and (3) any testimony, conversations, or
17
presentations by Parties or their Counsel that might reveal Protected Material.
18
Any use of Protected Material at trial shall be governed by the orders of the
19
trial judge. This Order does not govern the use of Protected Material at trial.
20
4. DURATION
21
Once a case proceeds to trial, all of the information that was designated as
22
confidential or maintained pursuant to this protective order becomes public and will
23
be presumptively available to all members of the public, including the press, unless
24
compelling reasons supported by specific factual findings to proceed otherwise are
25
made to the trial judge in advance of the trial. See Kamakana v. City and County of
26
Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing “good cause”
27
showing for sealing documents produced in discovery from “compelling reasons”
28
1 standard when merits-related documents are part of court record). Accordingly, the
2 terms of this protective order do not extend beyond the commencement of the trial.
3 5. DESIGNATING PROTECTED MATERIAL
4 5.1 Exercise of Restraint and Care in Designating Material for Protection.
Each Party or Non-Party that designates information or items for protection under
5
this Order must take care to limit any such designation to specific material that
6
qualifies under the appropriate standards. The Designating Party must designate for
7
protection only those parts of material, documents, items, or oral or written
8
communications that qualify so that other portions of the material, documents, items,
9
or communications for which protection is not warranted are not swept unjustifiably
10
within the ambit of this Order.
11
Mass, indiscriminate, or routinized designations are prohibited. Designations
12
that are shown to be clearly unjustified or that have been made for an improper
13
purpose (e.g., to unnecessarily encumber the case development process or to impose
14
unnecessary expenses and burdens on other parties) may expose the Designating
15
Party to sanctions.
16 If it comes to a Designating Party’s attention that information or items that it
17 designated for protection do not qualify for protection, that Designating Party must
18 promptly notify all other Parties that it is withdrawing the inapplicable designation.
19 5.2 Manner and Timing of Designations. Except as otherwise provided in
20 this Order (see, e.g., second paragraph of Section 5.2(a) below), or as otherwise
21 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
22 under this Order must be clearly so designated before the material is disclosed or
23 produced.
24 Designation in conformity with this Order requires:
25 (a) for information in documentary form (e.g., paper or electronic
26 documents, but excluding transcripts of depositions or other pretrial or trial
27 proceedings), that the Producing Party affix at a minimum, the legend
28 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
1 contains protected material. If only a portion or portions of the material on a page
2 qualifies for protection, the Producing Party also must clearly identify the protected
portion(s) (e.g., by making appropriate markings in the margins).
3
A Party or Non-Party that makes original documents available for
4
inspection need not designate them for protection until after the inspecting Party has
5
indicated which documents it would like copied and produced. During the inspection
6
and before the designation, all of the material made available for inspection shall be
7
deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents
8
it wants copied and produced, the Producing Party must determine which documents,
9
or portions thereof, qualify for protection under this Order. Then, before producing
10
the specified documents, the Producing Party must affix the “CONFIDENTIAL
11
legend” to each page that contains Protected Material. If only a portion or portions of
12
the material on a page qualifies for protection, the Producing Party also must clearly
13
identify the protected portion(s) (e.g., by making appropriate markings in the
14 margins). Markings added to documents pursuant to this paragraph shall not obscure
15 the content or text of the documents produced.
16 (b) for testimony given in depositions that the Designating Party identify
17 the Disclosure or Discovery Material on the record, before the close of the deposition
18 all protected testimony. The court reporter must affix to each such transcript page
19 containing Protected Material the “CONFIDENTIAL legend”, as instructed by the
20 Designating Party.
21 (c) for information produced in some form other than documentary and
for any other tangible items, that the Producing Party affix in a prominent place on
22
the exterior of the container or containers in which the information is stored the
23
legend “CONFIDENTIAL.” If only a portion or portions of the information warrants
24
protection, the Producing Party, to the extent practicable, shall identify the protected
25
portion(s).
26
5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
27
failure to designate qualified information or items does not, standing alone, waive the
28
1 Designating Party’s right to secure protection under this Order for such material.
2 Upon timely correction of a designation, the Receiving Party must make reasonable
3 efforts to assure that the material is treated in accordance with the provisions of this
4 Order.
5 5.4 Privilege Log
6 If a party withholds information that is responsive to a discovery request by
7 claiming that it is privileged or otherwise protected from discovery, that party shall
8 promptly prepare and provide a privilege log that is sufficiently detailed and
9 informative for the opposing party to assess whether a document's designation as
10 privileged is justified. See Fed. R. Civ. P. 26(b)(5). The privilege log shall set forth
11 the privilege relied upon and specify separately for each document or for each category
12 of similarly situated documents:
13 (a) the title and description of the document, including number of pages
14 or Bates- number range;
15 (b) the subject matter addressed in the document;
16 (c) the identity and position of its author(s);
17 (d) the identity and position of all addressees and recipients;
18 (e) the date the document was prepared and, if different, the date(s) on
19 which it was sent to or shared with persons other than its author(s); and
20 (f) the specific basis for the claim that the document is privileged and
21 protected.
22 Communications involving counsel that post-date the filing of the complaint
23 need not be placed on a privilege log.
24 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
25 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
26 designation of confidentiality at any time that is consistent with the Court’s
27 Scheduling Order.
28 6.2 Meet and Confer. The Challenging Party Shall initiate the dispute
1 resolution process under Civil Local Rule 37-1 et seq.
2 6.3 Failing to Meet and Confer
3 Failing informal resolution between parties, the Designating Party may file and
4 serve a Motion for a Protective Order with the Court strictly pursuant to Local Rule
5 37, including the Joint Stipulation Procedure. The parties agree that if the Motion for
6 Protective Order is filed within 21 days of the written challenge (subject to extension
7 upon agreement of the Parties), the Material will retain its original designation until
8 the Court rules on the Motion for a Protective Order. If the Designating Party does
9 not file a motion within the 21-day period following a challenge, the material is no
10 longer designated as CONFIDENTIAL INFORMATION for purposes of this
11 Stipulation, but that change in designation does not bar the Producing Party from
12 subsequently filing a motion for a protective order.
13 6.4 Burden of Persuasion
14 The burden of persuasion in any such challenge proceeding shall be on the
15 Designating Party. Frivolous challenges, and those made for an improper purpose
16 (e.g., to harass or impose unnecessary expenses and burdens on other parties), may
17 expose the Challenging Party to sanctions. Unless the Designating Party has waived
18 or withdrawn the confidentiality designation, all parties shall continue to afford the
19 material in question the level of protection to which it is entitled under the
20 Producing Party’s designation until the Court rules on the challenge.
21 6.5 Withdrawal of “CONFIDENTIAL” Designation.
22 At its discretion, a Designating Party may remove Protected Material from some or
23 all of the protections and provisions of this Stipulated Protective Order at any time by
24 any of the following methods:
25 (a) Express Written Withdrawal. A Designating Party may withdraw a
26 “CONFIDENTIAL” designation made to any specified Protected Material from some
27 or all of the protections of this Stipulated Protective Order by an express withdrawal in
28 writing signed by the Designating Party or Designating Party’s counsel (but not
1 including staff of such counsel) that specifies and itemizes the Disclosure or Discovery
2 Material previously designated as Protected Material that shall not longer be subject to
3 some or all of the provisions of this Stipulated Protective Order. Such express
4 withdrawal shall be effective when transmitted or served upon the Receiving Party. If
5 a Designating Party is withdrawing Protected Material from only some of the
6 provisions/protections of this Stipulated Protective Order, the Designating Party must
7 state which specific provisions are no longer to be enforced as to the specified material
8 for which confidentiality protection hereunder is withdrawn: otherwise, such
9 withdrawal shall be construed as a withdrawal of such material from all of the
10 protections/provisions of this Stipulated Protective Order;
11 (b) Express Withdrawal on the Record. A Designating Party may withdraw
12 a “CONFIDENTIAL” designation made to any specified Protected Material from all
13 of the provisions/protections of this Stipulated Protective Order by verbally consenting
14 in court proceedings on the record to such withdrawal – provided that such withdrawal
15 specifies the Disclosure or Discovery Material previously designated as Protected
16 Material shall no longer be subject to any of the provisions of this Stipulation and
17 Order;
18 (c) Implicit Withdrawal by Publication or Failure to Oppose Challenge. A
19 Designating Party shall be construed to have withdrawn a “CONFIDENTIAL”
20 designation made to any specified Protected Material from all of the
21 provisions/protections of this Stipulated Protective Order by either (1) making such
22 Protected Material part of the public record – including but not limited to attaching
23 such as exhibits to any filing with the court without moving, prior to such filing, for
24 the court to seal such records; or (2) failing to timely oppose a Challenging Party’s
25 motion to remove a “CONFIDENTIAL” designation to specified Protected Material.
26 7. ACCESS TO AND USE OF PROTECTED MATERIAL
27 7.1 Basic Principles. A Receiving Party may use Protected Material that is
28 disclosed or produced by another Party or by a Non-Party in connection with this
1 Action only for prosecuting, defending, or attempting to settle this Action. Such
2 Protected Material may be disclosed only to the categories of persons and under the
3 conditions described in this Order. When the Action has been terminated, a
4 Receiving Party must comply with the provisions of Section 13 below (FINAL
5 DISPOSITION).
6 Protected Material must be stored and maintained by a Receiving Party at a
7 location and in a secure manner that ensures that access is limited to the persons
authorized under this Order.
8
7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
9
otherwise ordered by the Court or permitted in writing by the Designating Party, a
10
Receiving Party may disclose any information or item designated
11
“CONFIDENTIAL” only to:
12
(a) the Receiving Party’s Outside Counsel of Record in this Action, as
13
well as employees of said Outside Counsel of Record to whom it is reasonably
14
necessary to disclose the information for this Action;
15
(b) the officers, directors, and employees (including House Counsel) of
16
the Receiving Party to whom disclosure is reasonably necessary for this Action;
17
(c) Experts (as defined in this Order) of the Receiving Party to whom
18
disclosure is reasonably necessary for this Action and who have signed the
19
“Acknowledgment and Agreement to Be Bound” (Exhibit A);
20
(d) the Court and its personnel;
21
(e) court reporters and their staff;
22
(f) professional jury or trial consultants, mock jurors, and Professional
23 Vendors to whom disclosure is reasonably necessary for this Action and who have
24 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
25 (g) the author or recipient of a document containing the information or a
26 custodian or other person who otherwise possessed or knew the information;
27 (h) during their depositions, witnesses, and attorneys for witnesses, in the
28 Action to whom disclosure is reasonably necessary provided: (1) the deposing party
1 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will
2 not be permitted to keep any confidential information unless they sign the
“Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
3
agreed by the Designating Party or ordered by the Court. Pages of transcribed
4
deposition testimony or exhibits to depositions that reveal Protected Material may be
5
separately bound by the court reporter and may not be disclosed to anyone except as
6
permitted under this Stipulated Protective Order; and
7
(i) any mediator or settlement officer, and their supporting personnel,
8
mutually agreed upon by any of the parties engaged in settlement discussions.
9
8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
10
PRODUCED IN OTHER LITIGATION
11
If a Party is served with a subpoena or a court order issued in other litigation
12
that compels disclosure of any information or items designated in this Action as
13
“CONFIDENTIAL,” that Party must:
14
(a) promptly notify in writing the Designating Party. Such notification
15
shall include a copy of the subpoena or court order;
16 (b) promptly notify in writing the party who caused the subpoena or order
17 to issue in the other litigation that some or all of the material covered by the subpoena
18 or order is subject to this Protective Order. Such notification shall include a copy of
19 this Stipulated Protective Order; and
20 (c) cooperate with respect to all reasonable procedures sought to be
21 pursued by the Designating Party whose Protected Material may be affected.
22 If the Designating Party timely seeks a protective order, the Party served with
23 the subpoena or court order shall not produce any information designated in this
action as “CONFIDENTIAL” before a determination by the court from which the
24
subpoena or order issued, unless the Party has obtained the Designating Party’s
25
permission. The Designating Party shall bear the burden and expense of seeking
26
protection in that court of its confidential material, and nothing in these provisions
27
should be construed as authorizing or encouraging a Receiving Party in this Action
28
1 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
2 PRODUCED IN THIS LITIGATION
3 (a) The terms of this Order are applicable to information produced by a
4 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
produced by Non-Parties in connection with this litigation is protected by the
5
remedies and relief provided by this Order. Nothing in these provisions should be
6
construed as prohibiting a Non-Party from seeking additional protections.
7
(b) In the event that a Party is required, by a valid discovery request, to
8
produce a Non-Party’s confidential information in its possession, and the Party is
9
subject to an agreement with the Non-Party not to produce the Non-Party’s
10
confidential information, then the Party shall:
11
(1) promptly notify in writing the Requesting Party and the Non-Party
12
that some or all of the information requested is subject to a confidentiality agreement
13
with a Non-Party;
14
(2) promptly provide the Non-Party with a copy of the Stipulated
15
Protective Order in this Action, the relevant discovery request(s), and a reasonably
16 specific description of the information requested; and
17 (3) make the information requested available for inspection by the Non-
18 Party, if requested.
19 (c) If the Non-Party fails to seek a protective order from this Court within
20 14 days of receiving the notice and accompanying information, the Receiving Party
21 may produce the Non-Party’s confidential information responsive to the discovery
22 request. If the Non-Party timely seeks a protective order, the Receiving Party shall
23 not produce any information in its possession or control that is subject to the
confidentiality agreement with the Non-Party before a determination by the Court.
24
Absent a court order to the contrary, the Non-Party shall bear the burden and expense
25
of seeking protection in this Court of its Protected Material.
26
///
27
///
28
1 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
2 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
3 Protected Material to any person or in any circumstance not authorized under this
Stipulated Protective Order, the Receiving Party must immediately (a) notify in
4
writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
5
to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
6
persons to whom unauthorized disclosures were made of all the terms of this Order,
7
and (d) request such person or persons to execute the “Acknowledgment and
8
Agreement to Be Bound” that is attached hereto as Exhibit A.
9
11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
10
PROTECTED MATERIAL
11
When a Producing Party gives notice to Receiving Parties that certain
12
inadvertently produced material is subject to a claim of privilege or other protection,
13
the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
14
Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
15
may be established in an e-discovery order that provides for production without prior
16
privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
17 parties reach an agreement on the effect of disclosure of a communication or
18 information covered by the attorney-client privilege or work product protection, the
19 parties may incorporate their agreement in the stipulated protective order submitted
20 to the Court.
21 12. MISCELLANEOUS
22 12.1 Right to Relief. Nothing in this Order abridges the right of any person
23 to seek its modification by the Court in the future.
24 12.2 Right to Assert Other Objections. By stipulating to the entry of this
25 Protective Order, no Party waives any right it otherwise would have to object to
26 disclosing or producing any information or item on any ground not addressed in this
27 Stipulated Protective Order. Similarly, no Party waives any right to object on any
28 ground to use in evidence of any of the material covered by this Protective Order.
1 12.3 Filing Protected Material. A Party that seeks to file under seal any
2 Protected Material must comply with Civil Local Rule 79-5. Protected Material may
3 only be filed under seal pursuant to a court order authorizing the sealing of the specific
4 Protected Material at issue. If a Party’s request to file Protected Material under seal
5 is denied by the court, then the Receiving Party may file the information in the public
6 record unless otherwise instructed by the court.
7 13. FINAL DISPOSITION
8 After the final disposition of this Action, as defined in paragraph 4, within 60
9 days of a written request by the Designating Party, each Receiving Party must return
all Protected Material to the Producing Party or destroy such material. As used in
10
this subdivision, “all Protected Material” includes all copies, abstracts, compilations,
11
summaries, and any other format reproducing or capturing any of the Protected
12
Material. Whether the Protected Material is returned or destroyed, the Receiving
13
Party must submit a written certification to the Producing Party (and, if not the same
14
person or entity, to the Designating Party) by the 60 day deadline that (1) identifies
15
(by category, where appropriate) all the Protected Material that was returned or
16
destroyed; and (2) affirms that the Receiving Party has not retained any copies,
17
abstracts, compilations, summaries, or any other format reproducing or capturing any
18
of the Protected Material. Notwithstanding this provision, Counsel are entitled to
19
retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing
20
transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
21 reports, attorney work product, and consultant and expert work product, even if such
22 materials contain Protected Material. Any such archival copies that contain or
23 constitute Protected Material remain subject to this Protective Order as set forth in
24 Section 4 (DURATION).
25 14. Any violation of this Order may be punished by any and all appropriate
26 measures including, without limitation, contempt proceedings and/or monetary
27 sanctions.
28
1 {| ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD.
2
3 || DATED: September 15, 2025 GASTELUM LAW, APC
4
5 /s/ Selene Estrada-Villela
Denisse O. Gastélum, Esq.
6 Selene Estrada-Villela, Esq.
7 Attorneys for Plaintiff
8
DATED: September 15, 2025 LAW OFFICES OF CHRISTIAN
? CONTRERAS
10
11 /s/ Christian Contreras
1 Christian Contreras, Esq.
Attorneys for Plaintiff
13
14 || DATED: September 15, 2025 COLLINS + COLLINS LLP
15
16 /s/ Bonnie J. Bennett
17 Michael L. Wroniak, Esq.
Bonnie J. Bennett, Esq.
18 Attorneys for Defendants
19
20
21 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
22
93 || DATED: September 18, 2025
25
HonoraWle Douglas F. McCormick
26 || United States Magistrate Judge
27
28
15
1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
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
6
issued by the United States District Court for the Central District of California on
7
[date] in the case of Estate of Ignacio Lemus, et al. v. Orange County Sheriff’s
8
Department, et al.; Case No. 8:25-cv-00410-DOC-DFM. I agree to comply with
9
and to be bound by all the terms of this Stipulated Protective Order, and I understand
10
and acknowledge that failure to so comply could expose me to sanctions and
11
punishment in the nature of contempt. I solemnly promise that I will not disclose in
12
any manner any information or item that is subject to this Stipulated Protective Order
13
to any person or entity except in strict compliance with the provisions of this Order.
14 I further agree to submit to the jurisdiction of the United States District Court
15 for the Central District of California for the purpose of enforcing the terms of this
16 Stipulated Protective Order, even if such enforcement proceedings occur after
17 termination of this action. I hereby appoint __________________________ [print or
18 type full name] of _______________________________________ [print or type full
19 address and telephone number] as my California agent for service of process in
20 connection with this action or any proceedings related to enforcement of this
21 Stipulated Protective Order.
Date: ______________________________________
22
City and State where sworn and signed: _________________________________
23
24
Printed name: _______________________________
25
26
Signature: __________________________________
27
28