The opinion
1 | Angela M. Powell, SBN 191876
eee SS
2 | Helen O. Kim, Esq., SBN 254560
hok@jones-mayer.com
3 | JON ES MAYER
3777 North Harbor Boulevard
4 | Fullerton, CA 92835
Telephone: (714) 446-1400
5 | Facsimile: (714) 446-1448
6 Attorneys for Defendants,
CITY OF FONTANA, FONTANA POLICE
7 | DEPARTMENT, OFFICER CHAD EBLI,
and OFFICER NICHOLAS STRAKA
8
Eduardo M. Madrid, SBN 82395
9 | Ed@madridlawfirm.com
Erica L. Madrid, SBN 229327
10 | Erica@madridlawfirm.com
MADRID LAW FIRM
11 | A Professional Law Corporation
12612 Central Avenue
12 | Chino, CA 91710
Telephone: (909) 628-0068
13 | Facsimile: (909) 628-0067
14 | Attorneys for Plaintiff,
LORETTA GURROLA
15
16 UNITED STATES DISTRICT COURT
7 CENTRAL DISTRICT OF CALIFORNIA
18 | LORETTA GURROLA Case No. 5:25-cv-02221 SSS (Ex)
19 Plaintiff, Honorable Sunshine Suzanne Sykes
0 Courtroom 2
V.
1 Magistrate Judge Charles F. Eick
CITY OF FONTANA, FONTANA
POLICE DEPARTMENT, POLICE STIPULATED PROTECTIVE
OFFICER CHAD EBLI, POLICE ORDER
3 OFFICER NICHOLAS STRAKA,
individually and in their official Complaint Filed: August 25, 2025
04 capacity as police officers with the City | First Amended Complaint Filed:
of Fontana/Fontana Police October 20, 2025
95 Department, DOES 8 to 10,
individually and in their official
%6 capacity as police officers and/or
employees of the City of
7 Fontana/Fontana Police Department,
Inclusive,
28 Defendants.
STIPULATED PROTECTIVE ORDER
1] 1. GENERAL
2 1.1 Purposes and Limitations. Discovery in this action is likely to involve
3 | production of confidential, proprietary, or private information for which special
4 | protection from public disclosure and from use for any purpose other than
5 | prosecuting this litigation may be warranted. Accordingly, the parties hereby
6 | stipulate to and petition the Court to enter the following Stipulated Protective
7 | Order. The parties acknowledge that this Order does not confer blanket
8 | protections on all disclosures or responses to discovery and that the protection it
9 | affords from public disclosure and use extends only to the limited information or
10 | items that are entitled to confidential treatment under the applicable legal
11 | principles. The parties further acknowledge, as set forth in Section 12.3, below,
12 | that this Stipulated Protective Order does not entitle them to file confidential
13 | information under seal; Civil Local Rule 79-5 sets forth the procedures that must
14 | be followed and the standards that will be applied when a party seeks permission
15 | from the court to file material under seal.
16 1.2. Good Cause Statement. This action is likely to involve discovery that
17 | is confidential and privileged for which special protection from public disclosure
18 | and from use for any purpose other than prosecution of this action may be
19 | warranted. Such confidential and proprietary materials and information consist
29 | of, among other things, information pertaining to the investigation from Fontana
91 | Police Department and San Bernardino County Sherrifs Department of the
99 | underlying criminal activities, as well as peace officer personnel file information
93 | and/or documents which the parties agree include (1) Personal data, including
94 | marital status, family members, educational and employment history, home
25 addresses, or similar information; (2) Medical history; (8) Election of employee
%6 benefits; (4) Employee advancement, appraisal or discipline; and (5) Complaints,
97 | investigations of complaints, if any, concerning an event or transaction in which
| 2 peace officer participated, or which a peace officer perceived, and pertaining to
the manner in which the peace officer performed his or her duties.
STIPULATED PROTECTIVE ORDER
1 Such confidential materials and information consist of, among other things,
2 | materials which may be entitled to privileges and/or protections under the
3 | following: United States Constitution, First Amendment; the California
4 | Constitution, Article I, Section 1; California Penal Code §§ 832.5, 832.7 and 832.8;
5 | California Evidence Code §§ 1040 and 1048 et. seq; the Privacy Act of 1974, 5
6 | U.S.C. § 552; Health Insurance Portability and Accountability Act of 1996
7 | CHIPPA); the right to privacy; decisional law relating to such provisions; and
8 | information otherwise generally unavailable to the public, or which may be
9 | privileged or otherwise protected from disclosure under state or federal statutes,
10 | court rules, case decisions, or common law.
11 Defendants also contend that such confidential materials and information
12 | are entitled to the Official Information Privilege. Sanchez v. City of Santa Ana,
13 | 986 F.2d 1027, 1033 (9th Cir. Cal.1990); see also Kerr v. United States Dist. Ct.
14 | for.N.D. Cal., 511 F.2d 192, 198 (9th Cir. Cal. 1975). Affd, 426 U.S. 394, 96S. Ct.
15 | 3229, 48 L.Ed.2d 725 (1976). The information otherwise may be generally
16 unavailable to the public, or may be privileged or otherwise protected from
17 disclosure under state or federal statutes, court rules, case decisions, or common
18 law.
19 Further, discovery may require depositions, written discovery and/or the
0 production of certain information the public disclosure of which could comprise
>] officer safety, and/or raise security issues. Additionally, public disclosure of such
9 information poses a substantial risk of embarrassment, oppression, and/or
74 physical harm to peace officers whose confidential information is disclosed. The
risk of harm to peace officers is greater than with other government employees
35 due to the nature of their profession. The benefit of public disclosure of
confidential information 1s minimal while the potential disadvantages are great.
*6 Accordingly, to expedite the flow of information, to facilitate the prompt
a resolution of disputes over confidentiality of discovery materials, to adequately
28 protect information the parties are entitled to keep confidential, to ensure that
STIPULATED PROTECTIVE ORDER
| | the parties are permitted reasonable necessary uses of such material in
2 | preparation for and in the conduct of trial, to address their handling at the end of
3 | the litigation, and serve the ends of justice, a protective order for such information
4 | is justified in this matter. It is the intent of the parties that information will not
5 | be designated as confidential for tactical reasons and that nothing be so
6 | designated without a good faith belief that it has been maintained in a
7 | confidential, non-public manner, and there is good cause why it should not be part
8 | of the public record of this case.
2. DEFINITIONS
10 2.1 Action: Loretta Gurrola v, City of Fontana, Fontana Police
I Department, Police Officer Chad Ebli, Police Officer Nicholas Straka, individually
12 | and in their official capacity as police officers with the City of Fontana/Fontana
13 | Police Department, DOES 8 to 10, individually and in their official capacity as
14 police officers and/or employees of the City of Fontana/Fontana Police
15 Department, Inclusive.
16 2.2 Challenging Party: a Party or Non-Party that challenges the
17 designation of information or items under this Order.
18 2.8 “CONFIDENTIAL” Information or Items: information (regardless of
19 | how it is generated, stored or maintained) or tangible things that qualify for
20 protection under Federal Rule of Civil Procedure 26(c), and as specified above in
21 | the Good Cause Statement.
22 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as
23 | their support staff).
24 2.5 Designating Party: a Party or Non-Party that designates information
25 | or items that it produces in disclosures or in responses to discovery as
26 | “CONFIDENTIAL.”
27 2.6 Disclosure or Discovery Material: all items or information, regardless
28 | of the medium or manner in which it is generated, stored, or maintained
□□
STIPULATED PROTECTIVE ORDER
1 | Gncluding, among other things, testimony, transcripts, and tangible things), that
2 | are produced or generated in disclosures or responses to discovery in this matter.
3 2.7 Expert: a person with specialized knowledge or experience in a
4 | matter pertinent to the litigation who has been retained by a Party or its counsel
5 | to serve as an expert witness or as a consultant in this Action.
6 2.8 House Counsel: attorneys who are employees of a party to this Action.
7 | House Counsel does not include Outside Counsel of Record or any other outside
8 | counsel.
9 2.9 Non-Party: any natural person, partnership, corporation,
10 | association, or other legal entity not named as a Party to this action.
11 2.10 Outside Counsel of Record: attorneys who are not employees of a
12 | party to this Action but are retained to represent or advise a party to this Action
13 | and have appeared in this Action on behalf of that party or are affiliated with a
14 | law firm that has appeared on behalf of that party, including support staff.
15 2.11 Party: any party to this Action, including all of its officers, directors,
16 | employees, consultants, retained experts, and Outside Counsel of Record (and
17 | their support staffs).
18 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
19 | Discovery Material in this Action.
20 2.13 Professional Vendors: persons or entities that provide litigation
21 | support services (e.g., photocopying, videotaping, translating, preparing exhibits
22 | or demonstrations, and organizing, storing, or retrieving data in any form or
23 | medium) and their employees and subcontractors.
24 2.14 Protected Material: any Disclosure or Discovery Material that is
25 | designated as “CONFIDENTIAL.”
26 2.15 Receiving Party: a Party that receives Disclosure or Discovery
27 | Material from a Producing Party.
28 | 3. SCOPE
5.
STIPULATED PROTECTIVE ORDER
1 The protections conferred by this Stipulation and Order cover not only
2 | Protected Material (as defined above), but also (1) any information copied or
3 | extracted from Protected Material; (2) all copies, excerpts, summaries, or
4 | compilations of Protected Material; and (3) any testimony, conversations, or
5 | presentations by Parties or their Counsel that might reveal Protected Material.
6 Any use of Protected Material at trial shall be governed by the orders of the
7 | trial judge. This Order does not govern the use of Protected Material at trial.
8 | 4. DURATION
9 Once a case proceeds to trial, all of the court-filed information to be
10 | introduced that was previously designated as confidential or maintained
11 | pursuant to this protective order becomes public and will be presumptively
12 | available to all members of the public, including the press, unless compelling
13 | reasons supported by specific factual findings to proceed otherwise are made to
14 | the trial judge in advance of the trial. See Kamakana v. City and Cty. of Honolulu,
15 | 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing “good cause” showing for
16 | sealing documents produced in discovery from “compelling reasons” standard
17 | when merits-related documents are part of court record). Accordingly, the terms
18 | of this protective order do not extend beyond the commencement of the trial.
19 | 5. DESIGNATING PROTECTED MATERIAL
20 5.1 Exercise of Restraint and Care in Designating Material for
21 | Protection. Each Party or Non-Party that designates information or items for
22 | protection under this Order must take care to limit any such designation to
23 | specific material that qualifies under the appropriate standards. The Designating
24 | Party must designate for protection only those parts of material, documents,
25 | items, or oral or written communications that qualify so that other portions of the
26 | material, documents, items, or communications for which protection 1s not
27 | warranted are not swept unjustifiably within the ambit of this Order.
28
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STIPULATED PROTECTIVE ORDER
1 Mass, indiscriminate, or routinized designations are prohibited.
2 | Designations that are shown to be clearly unjustified or that have been made for
3 | an improper purpose (e.g., to unnecessarily encumber the case development
4 | process or to impose unnecessary expenses and burdens on other parties) may
5 | expose the Designating Party to sanctions.
6 If it comes to a Designating Party’s attention that information or items that
7 | it designated for protection do not qualify for protection, that Designating Party
8 | must promptly notify all other Parties that it is withdrawing the inapplicable
9 | designation.
10 5.2. Manner and Timing of Designations. Except as otherwise provided
11 | in this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
12 | stipulated or ordered, Disclosure or Discovery Material that qualifies for
13 | protection under this Order must be clearly so designated before the material is
14 | disclosed or produced.
15 Designation in conformity with this Order requires:
16 (a) for information in documentary form (e.g., paper or electronic
17 | documents, but excluding transcripts of depositions or other pretrial or trial
18 | proceedings), that the Producing Party affix, at a minimum, the legend
19 | “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
20 | contains protected material. If only a portion or portions of the material on a page
21 | qualifies for protection, the Producing Party also must clearly identify the
22 | protected portion(s) (e.g., by making appropriate markings in the margins).
23 A Party or Non-Party that makes original documents available for
24 | inspection need not designate them for protection until after the inspecting Party
25 | has indicated which documents it would like copied and produced. During the
26 | inspection and before the designation, all of the material made available for
27 | inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has
28 | identified the documents it wants copied and produced, the Producing Party must
1:
STIPULATED PROTECTIVE ORDER
1 | determine which documents, or portions thereof, qualify for protection under this
2 | Order. Then, before producing the specified documents, the Producing Party must
3 | affix the “CONFIDENTIAL legend” to each page that contains Protected Material.
4 | If only a portion or portions of the material on a page qualifies for protection, the
5 | Producing Party also must clearly identify the protected portion(s) (e.g., by
6 | making appropriate markings in the margins).
7 (b) for testimony given in depositions that the Designating Party
8 | identify the Disclosure or Discovery Material on the record, before the close of the
9 | deposition.
10 (c) for information produced in some form other than documentary
11 | and for any other tangible items, that the Producing Party affix in a prominent
12 | place on the exterior of the container or containers in which the information is
13 | stored the legend “CONFIDENTIAL.” If only a portion or portions of the
14 | information warrants protection, the Producing Party, to the extent practicable,
15 | shall identify the protected portion(s).
16 5.3 Inadvertent Failures to Designate. If timely corrected, an
17 | inadvertent failure to designate qualified information or items does not, standing
18 | alone, waive the Designating Party’s right to secure protection under this Order
19 | for such material. Upon timely correction of a designation, the Receiving Party
20 | must make reasonable efforts to assure that the material is treated in accordance
21 | with the provisions of this Order.
22 | 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
23 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
24 | designation of confidentiality at any time that is consistent with the Court’s
25 | Scheduling Order.
26 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
27 | resolution process under Local Rule 37-1, et seq. Any discovery motion must
28 | strictly comply with the procedures set forth in Local Rules 37-1, 37-2, and 37-3.
8.
STIPULATED PROTECTIVE ORDER
1 6.3. Burden. The burden of persuasion in any such challenge proceeding
2 | shall be on the Designating Party. Frivolous challenges, and those made for an
3 | improper purpose (e.g., to harass or impose unnecessary expenses and burdens on
4 | other parties) may expose the Challenging Party to sanctions. Unless the
5 | Designating Party has waived or withdrawn the confidentiality designation, all
6 | parties shall continue to afford the material in question the level of protection to
7 | which it is entitled under the Producing Party’s designation until the Court rules
8 | on the challenge.
9} 7. ACCESS TO AND USE OF PROTECTED MATERIAL
10 7.1 Basic Principles. A Receiving Party may use Protected Material that
11 | is disclosed or produced by another Party or by a Non-Party in connection with
12 | this Action only for prosecuting, defending, or attempting to settle this Action.
13 | Such Protected Material may be disclosed only to the categories of persons and
14 | under the conditions described in this Order. When the Action has been
15 | terminated, a Receiving Party must comply with the provisions of section 13 below
16 | (FINAL DISPOSITION).
17 Protected Material must be stored and maintained by a Receiving Party at
18 | a location and in a secure manner that ensures that access is limited to the
19 | persons authorized under this Order.
20 7.2. Disclosure _of “CONFIDENTIAL” Information or Items. Unless
21 | otherwise ordered by the Court or permitted in writing by the Designating Party,
22 | a Receiving Party may disclose any information or item designated
23 | “CONFIDENTIAL?” only to:
24 (a) the Receiving Party’s Outside Counsel of Record in this Action, as
25 | well as employees of said Outside Counsel of Record to whom it is reasonably
26 | necessary to disclose the information for this Action;
27 (b) the officers, directors, and employees (including House Counsel)
28 | of the Receiving Party to whom disclosure is reasonably necessary for this Action;
9.
STIPULATED PROTECTIVE ORDER
1 (c) Experts (as defined in this Order) of the Receiving Party to whom
2 | disclosure is reasonably necessary for this Action and who have signed the
3 | “Acknowledgment and Agreement to Be Bound” (Exhibit A);
4 (d) the Court and its personnel;
5 (e) court reporters and their staff;
6 (f) professional jury or trial consultants, mock jurors, and
7 | Professional Vendors to whom disclosure is reasonably necessary for this Action
8 | and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit
9 | A);
10 (g) the author or recipient of a document containing the information
11 | or a custodian or other person who otherwise possessed or knew the information;
12 (h) during their depositions, witnesses, and attorneys for witnesses,
13 | in the Action to whom disclosure is reasonably necessary provided: (1) the
14 | deposing party requests that the witness sign the form attached as Exhibit A
15 | hereto; and (2) they will not be permitted to keep any confidential information
16 | unless they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A),
17 | unless otherwise agreed by the Designating Party or ordered by the Court. Pages
18 | of transcribed deposition testimony or exhibits to depositions that reveal
19 | Protected Material may be separately bound by the court reporter and may not be
20 | disclosed to anyone except as permitted under this Stipulated Protective Order;
21 | and
22 (i) any mediator or settlement officer, and their supporting personnel,
23 | mutually agreed upon by any of the parties engaged in settlement discussions.
24 | 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
25 | PRODUCED IN OTHER LITIGATION
26 If a Party is served with a subpoena or a court order issued in other
27 | litigation that compels disclosure of any information or items designated in this
28 | Action as “CONFIDENTIAL,” that Party must:
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STIPULATED PROTECTIVE ORDER
1 (a) promptly notify in writing the Designating Party. Such notification
2 | shall include a copy of the subpoena or court order;
3 (b) promptly notify in writing the party who caused the subpoena or order
4 | to issue in the other litigation that some or all of the material covered by the
5 | subpoena or order is subject to this Protective Order. Such notification shall
6 | include a copy of this Stipulated Protective Order; and
7 (c) cooperate with respect to all reasonable procedures sought to be pursued
8 | by the Designating Party whose Protected Material may be affected.
9 If the Designating Party timely seeks a protective order, the Party served
10 | with the subpoena or court order shall not produce any information designated in
11 | this action as “CONFIDENTIAL” before a determination by the court from which
12 | the subpoena or order issued, unless the Party has obtained the Designating
13 | Party’s permission. The Designating Party shall bear the burden and expense of
14 | seeking protection in that court of its confidential material and nothing in these
15 | provisions should be construed as authorizing or encouraging a Receiving Party
16 | in this Action to disobey a lawful directive from another court.
17 | 9. A _NON-PARTYS PROTECTED MATERIAL SOUGHT TO BE
18 PRODUCED IN THIS LITIGATION
19 (a) The terms of this Order are applicable to information produced by a
20 | Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
21 | produced by Non-Parties in connection with this litigation is protected by the
22 | remedies and relief provided by this Order. Nothing in these provisions should
23 | be construed as prohibiting a Non-Party from seeking additional protections.
24 (b) In the event that a Party is required, by a valid discovery request, to
25 | produce a Non-Party’s confidential information in its possession, and the Party is
26 | subject to an agreement with the Non-Party not to produce the Non-Party’s
27 | confidential information, then the Party shall:
28
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STIPULATED PROTECTIVE ORDER
1 (1) promptly notify in writing the Requesting Party and the Non-
2 | Party that some or all of the information requested is subject to a confidentiality
3 | agreement with a Non-Party;
4 (2) promptly provide the Non-Party with a copy of the Stipulated
5 | Protective Order in this Action, the relevant discovery request(s), and a
6 | reasonably specific description of the information requested; and
7 (3) make the information requested available for inspection by the
8 | Non-Party, if requested.
9 (c) If the Non-Party fails to seek a protective order from this Court within
10 | 14 days of receiving the notice and accompanying information, the Receiving
11 | Party may produce the Non-Party’s confidential information responsive to the
12 | discovery request. If the Non-Party timely seeks a protective order, the Receiving
13 | Party shall not produce any information in its possession or control that is subject
14 | to the confidentiality agreement with the Non-Party before a determination by
15 | the Court. Absent a court order to the contrary, the Non-Party shall bear the
16 | burden and expense of seeking protection in this Court of its Protected Material.
17 | 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
18 If a Receiving Party learns that, by inadvertence or otherwise, it has
19 | disclosed Protected Material to any person or in any circumstance not authorized
20 | under this Stipulated Protective Order, the Receiving Party must immediately (a)
21 | notify in writing the Designating Party of the unauthorized disclosures, (b) use
22 | its best efforts to retrieve all unauthorized copies of the Protected Material, (c)
23 | inform the person or persons to whom unauthorized disclosures were made of all
24 | the terms of this Order, and (d) request such person or persons to execute the
25 | “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit
26 | A.
27 | 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
28 PROTECTED MATERIAL
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STIPULATED PROTECTIVE ORDER
1 When a Producing Party gives notice to Receiving Parties that certain
2 | inadvertently produced material is subject to a claim of privilege or other
3 | protection, the obligations of the Receiving Parties are those set forth in Federal
4 | Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify
5 | whatever procedure may be established in an e-discovery order that provides for
6 | production without prior privilege review. Pursuant to Federal Rule of Evidence
7 | 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure
8 | of acommunication or information covered by the attorney-client privilege or work
9 | product protection, the parties may incorporate their agreement in the stipulated
10 | protective order submitted to the Court.
11 | 12. MISCELLANEOUS
12 12.1 Right to Further Relief. Nothing in this Order abridges the right of
13 | any person to seek its modification by the Court in the future.
14 12.2 Right to Assert Other Objections. By stipulating to the entry of this
15 | Protective Order, no Party waives any right it otherwise would have to object to
16 | disclosing or producing any information or item on any ground not addressed in
17 | this Stipulated Protective Order. Similarly, no Party waives any right to object
18 | on any ground to use in evidence of any of the material covered by this Protective
19 | Order.
20 12.3 Filing Protected Material. A Party that seeks to file under seal any
21 | Protected Material must comply with Civil Local Rule 79-5. Protected Material
22 | may only be filed under seal pursuant to a court order authorizing the sealing of
23 | the specific Protected Material at issue; good cause must be shown in the request
24 | to file under seal. If a Party’s request to file Protected Material under seal is
25 | denied by the Court, then the Receiving Party may file the information in the
26 | public record unless otherwise instructed by the Court.
27 | 18. FINAL DISPOSITION
28
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STIPULATED PROTECTIVE ORDER
1 After the final disposition of this Action, within 60 days of a written request
2 | by the Designating Party, each Receiving Party must return all Protected
3 | Material to the Producing Party or destroy such material. As used in this
4 | subdivision, “all Protected Material” includes all copies, abstracts, compilations,
5 | summaries, and any other format reproducing or capturing any of the Protected
6 | Material. Whether the Protected Material is returned or destroyed, the Receiving
7 | Party must submit a written certification to the Producing Party (and, if not the
8 || same person or entity, to the Designating Party) by the 60 day deadline that (1)
9 | identifies (by category, where appropriate) all the Protected Material that was
10 | returned or destroyed, and (2) affirms that the Receiving Party has not retained
11 | any copies, abstracts, compilations, summaries or any other format reproducing
12 | or capturing any of the Protected Material. Notwithstanding this provision,
13 | counsel are entitled to retain an archival copy of all pleadings, motion papers,
14 | trial, deposition, and hearing transcripts, legal memoranda, correspondence,
15 | deposition and trial exhibits, expert reports, attorney work product, and
16 | consultant and expert work product, even if such materials contain Protected
17 | Material. Any such archival copies that contain or constitute Protected Material
18 | remain subject to this Protective Order as set forth in Section 4 (DURATION).
19 | 14. VIOLATION OF ORDER
20 Any violation of this Order may be punished by any and all appropriate
21 | measures including, without limitation, contempt proceedings and/or monetary
22 | sanctions.
23 | ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD.
24 MADRID LAW FIRM
25
DATED: November 11, 2025 /s/ Eduardo M. Madrid
26 Eduardo M. Madrid, Esq.
Erica L. Madrid, Esq.
27 Attorneys for Plaintiff Loretta Gurrola
28
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STIPULATED PROTECTIVE ORDER
1 JONES MAYER
2
DATED: November 11, 2025 /s/ Helen O. Kim
3 Angela M. Powell, Esq.
Helen O. Kim, Esq.
4 Attorneys for Defendants City of
Fontana, Fontana Police Department,
5 Police Officer Chad Ebli and Police
Officer Nicholas Straka
7 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
DATED: November 12, 2025
9 HON. CHARLES F. EICK
10 United States Magistrate Judge
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STIPULATED PROTECTIVE ORDER
l EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3 I, [full name], of (full
4 | address], declare under penalty of perjury that I have read in its entirety and
5 | understand the Stipulated Protective Order that was issued by the United
6 | States District Court for the Central District of California on
7 | [date] in the case of [insert case name and number]. I agree to
8 | comply with and to be bound by all the terms of this Stipulated Protective Order
9 | I understand and acknowledge that failure to so comply could expose me to
10 | sanctions and punishment in the nature of contempt. I solemnly promise that I
11 | will not disclose in any manner any information or item that is subject to this
12 | Stipulated Protective Order to any person or entity except in strict compliance
13 | with the provisions of this Order.
14 I further agree to submit to the jurisdiction of the United States District
15 | Court for the Central District of California for the purpose of enforcing the terms
16 | of this Stipulated Protective Order, even if such enforcement proceedings occur
17 | after termination of this action. I hereby appoint
18 | [full name] of [full address and
19 | telephone number] as my California agent for service of process in connection
20 | with this action or any proceedings related to enforcement of this Stipulated
21 | Protective Order.
22
23 | Date:
24 | City and State where signed:
25
26 | Printed name:
27
28 | Signature:
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STIPULATED PROTECTIVE ORDER