The opinion
1 Boris Treyzon, Esq. (SBN 188893)
btreyzon@actslaw.com
2 Pinar Kermani, Esq. (SBN 355486)
pkermani@actslaw.com
3 Michael Zuzo, Esq. (SBN 356667)
mzuzo@actslaw.com
4 ABIR COHEN TREYZON SALO, LLP
16001 Ventura Blvd., Ste. 200
5 Encino, CA 91436
6 Attorneys for Plaintiff, JOHN BB ROE
(Additional Counsel on Signature Page)
7
Rick Richmond (SBN 194962)
8 rrichmond@larsonllp.com
Andrew E. Calderón (SBN 316673)
9 acalderon@larsonllp.com
Andrew S. Bledsoe (SBN 332171)
10 abledsoe@larsonllp.com
LARSON LLP
11 555 South Flower Street, 30th Floor
Los Angeles, California 90071
12
Attorneys for Defendant The Church of
13 Jesus Christ of Latter-day Saints and
Temple Corporation of The Church of
14 Jesus Christ of Latter-day Saints
15
16 UNITED STATES DISTRICT COURT
17 CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION
18
19 JOHN BB ROE, Case No. 2:25-cv-08691-WLH (MARx)
20 Plaintiff, DISCOVERY MATTER
Magistrate: Hon. Margo A. Rocconi
21 vs.
STIPULATED PROTECTIVE
22 THE CHURCH OF JESUS CHRIST ORDER
OF LATTER-DAY SAINTS, a
23 nonprofit corporation; TEMPLE
CORPORATION OF THE CHURCH
24 OF LATTER-DAY SAINTS, a
nonprofit corporation; CERRITOS
25 CALIFORNIA STAKE OF THE
CHURCH OF LATTER-DAY
26 SATINS, an entity of unknown form;
and DOES 1 to 100,
27
Defendants.
1 1. INTRODUCTION
2 1.1 PURPOSES AND LIMITATIONS
3 Discovery in this action is likely to involve production of confidential,
4 proprietary, or private information for which special protection from public
5 disclosure and from use for any purpose other than prosecuting this litigation may
6 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to
7 enter the following Stipulated Protective Order. The parties acknowledge that this
8 Order does not confer blanket protections on all disclosures or responses to
9 discovery and that the protection it affords from public disclosure and use extends
10 only to the limited information or items that are entitled to confidential treatment
11 under the applicable legal principles. The parties further acknowledge, as set forth in
12 Section 12.3, below, that this Stipulated Protective Order does not entitle them to
13 file confidential information under seal; Civil Local Rule 79-5 sets forth the
14 procedures that must be followed and the standards that will be applied when a party
15 seeks permission from the court to file material under seal.
16 1.2 GOOD CAUSE STATEMENT
17 This Action arises from allegations of childhood sexual abuse and is likely to
18 involve medical records, psychiatric records, confidential church membership
19 records, and other private information implicating the privacy rights of third parties
20 for which special protection from public disclosure and from use for any purpose
21 other than prosecution of this action is warranted. Accordingly, to expedite the flow
22 of information, to facilitate the prompt resolution of disputes over confidentiality of
23 discovery materials, to adequately protect information the parties are entitled to keep
24 confidential, to ensure that the parties are permitted reasonable necessary uses of
25 such material in preparation for and in the conduct of trial, to address their handling
26 at the end of the litigation, and serve the ends of justice, a protective order for such
27 information is justified in this matter. It is the intent of the parties that information
1 designated without a good faith belief that it has been maintained in a confidential,
2 non-public manner, and there is good cause why it should not be part of the public
3 record of this case.
4 2. DEFINITIONS
5 2.1 Action: John BB Roe v. The Church of Jesus Christ of Latter-day
6 Saints, et. al., 2:25-cv-08691-WLH (MARx) (C.D. Cal.)
7 2.2 Challenging Party: a Party or Non-Party that challenges the
8 designation of information or items under this Order.
9 2.3 “CONFIDENTIAL” Information or Items: information (regardless of
10 how it is generated, stored or maintained) or tangible things that qualify for
11 protection under Federal Rule of Civil Procedure 26(c), and as specified above in
12 the Good Cause Statement.
13 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as
14 their support staff).
15 2.5 Designating Party: a Party or Non-Party that designates information or
16 items that it produces in disclosures or in responses to discovery as
17 “CONFIDENTIAL.”
18 2.6 Disclosure or Discovery Material: all items or information, regardless
19 of the medium or manner in which it is generated, stored, or maintained (including,
20 among other things, testimony, transcripts, and tangible things), that are produced or
21 generated in disclosures or responses to discovery in this matter.
22 2.7 Expert: a person with specialized knowledge or experience in a matter
23 pertinent to the litigation who has been retained by a Party or its counsel to serve as
24 an expert witness or as a consultant in this Action.
25 2.8 House Counsel: attorneys who are employees of a party to this Action,
26 and, for purposes of Defendants, attorneys from Kirton McConkie and their staff.
27 House Counsel does not include Outside Counsel of Record or any other outside
1 counsel.
2 2.9 Non-Party: any natural person, partnership, corporation, association, or
3 other legal entity not named as a Party to this action.
4 2.10 Outside Counsel of Record: attorneys who are not employees of a
5 party to this Action but are retained to represent or advise a party to this Action and
6 have appeared in this Action on behalf of that party or are affiliated with a law firm
7 which has appeared on behalf of that party, and includes support staff.
8 2.11 Party: any party to this Action, including all of its officers, directors,
9 employees, consultants, retained experts, and Outside Counsel of Record (and their
10 support staffs).
11 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
12 Discovery Material in this Action.
13 2.13 Professional Vendors: persons or entities that provide litigation
14 support services (e.g., photocopying, videotaping, translating, preparing exhibits or
15 demonstrations, and organizing, storing, or retrieving data in any form or medium)
16 and their employees and subcontractors.
17 2.14 Protected Material: any Disclosure or Discovery Material that is
18 designated as “CONFIDENTIAL.”
19 2.15 Receiving Party: a Party that receives Disclosure or Discovery
20 Material from a Producing Party.
21 3. SCOPE
22 The protections conferred by this Stipulation and Order cover not only
23 Protected Material (as defined above), but also (1) any information copied or
24 extracted from Protected Material; (2) all copies, excerpts, summaries, or
25 compilations of Protected Material; and (3) any testimony, conversations, or
26 presentations by Parties or their Counsel that might reveal Protected Material.
27 Any use of Protected Material at trial will be governed by the orders of the
1 4. DURATION
2 Once a case proceeds to trial, all of the information that was designated as
3 confidential or maintained pursuant to this protective order becomes public and will
4 be presumptively available to all members of the public, including the press, unless
5 compelling reasons supported by specific factual findings to proceed otherwise are
6 made to the trial judge in advance of the trial. See Kamakana v. City and County of
7 Honolulu, 447 F.3d 1172, 1180–81 (9th Cir. 2006) (distinguishing “good cause”
8 showing for sealing documents produced in discovery from “compelling reasons”
9 standard when merits-related documents are part of court record). Accordingly, the
10 terms of this protective order do not extend beyond the commencement of the trial
11 in this matter as to the Protected Material used or introduced as an exhibit at trial.
12 Information that remains confidential and is not made available to the public
13 at trial shall remain subject to the confidentiality obligations imposed by this Order
14 until a Designating Party agrees otherwise in writing or a court order otherwise
15 directs, even after final disposition of this litigation. Even after final disposition of
16 this litigation, the confidentiality obligations imposed by this Order will remain in
17 effect until a Designating Party agrees otherwise in writing or a court order
18 otherwise directs. Final disposition will be deemed to be the later of (1) dismissal of
19 all claims and defenses in this Action, with or without prejudice; and (2) final
20 judgment herein after the completion and exhaustion of all appeals, rehearings,
21 remands, trials, or reviews of this Action, including the time limits for filing any
22 motions or applications for extension of time pursuant to applicable law.
23 5. DESIGNATING PROTECTED MATERIAL
24 5.1 Exercise of Restraint and Care in Designating Material for Protection.
25 Each Party or Non-Party that designates information or items for protection
26 under this Order must take care to limit any such designation to specific material
27 that qualifies under the appropriate standards. The Designating Party must designate
1 communications that qualify so that other portions of the material, documents,
2 items, or communications for which protection is not warranted are not swept
3 unjustifiably within the ambit of this Order.
4 Mass, indiscriminate, or routinized designations are prohibited. Designations
5 that are shown to be clearly unjustified or that have been made for an improper
6 purpose (e.g., to unnecessarily encumber the case development process or to impose
7 unnecessary expenses and burdens on other parties) may expose the Designating
8 Party to sanctions.
9 If it comes to a Designating Party’s attention that information or items that it
10 designated for protection do not qualify for protection, that Designating Party must
11 promptly notify all other Parties that it is withdrawing the inapplicable designation.
12 5.2 Manner and Timing of Designations. Except as otherwise provided in
13 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
14 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
15 under this Order must be clearly so designated before the material is disclosed or
16 produced.
17 Designation in conformity with this Order requires:
18 (a) for information in documentary form (e.g., paper or electronic
19 documents, but excluding transcripts of depositions or other pretrial or trial
20 proceedings), that the Producing Party affix at a minimum, the legend
21 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
22 contains protected material. If only a portion or portions of the material on a page
23 qualifies for protection, the Producing Party also must clearly identify the protected
24 portion(s) (e.g., by making appropriate markings in the margins).
25 A Party or Non-Party that makes original documents available for inspection
26 need not designate them for protection until after the inspecting Party has indicated
27 which documents it would like copied and produced. During the inspection and
1 deemed “CONFIDENTIAL.” After the inspecting Party has identified the
2 documents it wants copied and produced, the Producing Party must determine which
3 documents, or portions thereof, qualify for protection under this Order. Then, before
4 producing the specified documents, the Producing Party must affix the
5 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a
6 portion or portions of the material on a page qualifies for protection, the Producing
7 Party also must clearly identify the protected portion(s) (e.g., by making appropriate
8 markings in the margins).
9 (b) for testimony given in depositions that the Designating Party identify
10 the Disclosure or Discovery Material on the record, before the close of the
11 deposition all protected testimony.
12 (c) for information produced in some form other than documentary and
13 for any other tangible items, that the Producing Party affix in a prominent place on
14 the exterior of the container or containers in which the information is stored the
15 legend “CONFIDENTIAL.” If only a portion or portions of the information
16 warrants protection, the Producing Party, to the extent practicable, will identify the
17 protected portion(s).
18 5.3 Inadvertent Failures to Designate.
19 If timely corrected, an inadvertent failure to designate qualified information
20 or items does not, standing alone, waive the Designating Party’s right to secure
21 protection under this Order for such material. Upon timely correction of a
22 designation, the Receiving Party must make reasonable efforts to assure that the
23 material is treated in accordance with the provisions of this Order.
24 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
25 6.1 Timing of Challenges.
26 Any Party or Non-Party may challenge a designation of confidentiality at any
27 time that is consistent with the Court’s Scheduling Order.
1 6.2 Meet and Confer.
2 The Challenging Party will initiate the dispute resolution process under Local
3 Rule 37.1 et seq.
4 6.3 Burden.
5 The burden of persuasion in any such challenge proceeding will be on the
6 Designating Party. Frivolous challenges, and those made for an improper purpose
7 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may
8 expose the Challenging Party to sanctions. Unless the Designating Party has waived
9 or withdrawn the confidentiality designation, all parties will continue to afford the
10 material in question the level of protection to which it is entitled under the
11 Producing Party’s designation until the Court rules on the challenge.
12 7. ACCESS TO AND USE OF PROTECTED MATERIAL
13 7.1 Basic Principles. A Receiving Party may use Protected Material that is
14 disclosed or produced by another Party or by a Non-Party in connection with this
15 Action only for prosecuting, defending, or attempting to settle this Action. Such
16 Protected Material may be disclosed only to the categories of persons and under the
17 conditions described in this Order. When the Action has been terminated, a
18 Receiving Party must comply with the provisions of section 13 below (FINAL
19 DISPOSITION).
20 Protected Material must be stored and maintained by a Receiving Party at a
21 location and in a secure manner that ensures that access is limited to the persons
22 authorized under this Order.
23 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
24 otherwise ordered by the court or permitted in writing by the Designating Party, a
25 Receiving Party may disclose any information or item designated
26 “CONFIDENTIAL” only to:
27 (a) the Receiving Party’s Outside Counsel of Record in this Action, as
1 necessary to disclose the information for this Action;
2 (b) the officers, directors, and employees (including House Counsel) of
3 the Receiving Party to whom disclosure is reasonably necessary for this Action;
4 (c) Experts (as defined in this Order) of the Receiving Party to whom
5 disclosure is reasonably necessary for this Action and who have signed the
6 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
7 (d) the Court and its personnel;
8 (e) court reporters and their staff;
9 (f) professional jury or trial consultants, mock jurors, and Professional
10 Vendors to whom disclosure is reasonably necessary for this Action and who have
11 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
12 (g) the author or recipient of a document containing the information or a
13 custodian or other person who otherwise possessed or knew the information;
14 (h) during their depositions, witnesses, and attorneys for witnesses, in the
15 Action to whom disclosure is reasonably necessary provided: (1) the deposing party
16 requests that the witness sign the form attached as Exhibit A hereto; and (2) they
17 will not be permitted to keep any confidential information unless they sign the
18 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
19 agreed by the Designating Party or ordered by the court. Pages of transcribed
20 deposition testimony or exhibits to depositions that reveal Protected Material may
21 be separately bound by the court reporter and may not be disclosed to anyone except
22 as permitted under this Stipulated Protective Order; and
23 (i) any mediator or settlement officer, and their supporting personnel,
24 mutually agreed upon by any of the parties engaged in settlement discussions.
25 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
26 IN OTHER LITIGATION
27 If a Party is served with a subpoena or a court order issued in other litigation
1 “CONFIDENTIAL,” that Party must:
2 (a) promptly notify in writing the Designating Party. Such notification
3 will include a copy of the subpoena or court order;
4 (b) promptly notify in writing the party who caused the subpoena or order
5 to issue in the other litigation that some or all of the material covered by the
6 subpoena or order is subject to this Protective Order. Such notification will include a
7 copy of this Stipulated Protective Order; and
8 (c) cooperate with respect to all reasonable procedures sought to be
9 pursued by the Designating Party whose Protected Material may be affected.
10 If the Designating Party timely seeks a protective order, the Party served with
11 the subpoena or court order will not produce any information designated in this
12 action as “CONFIDENTIAL” before a determination by the court from which the
13 subpoena or order issued, unless the Party has obtained the Designating Party’s
14 permission. The Designating Party will bear the burden and expense of seeking
15 protection in that court of its confidential material and nothing in these provisions
16 should be construed as authorizing or encouraging a Receiving Party in this Action
17 to disobey a lawful directive from another court.
18 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
19 PRODUCED IN THIS LITIGATION
20 (a) The terms of this Order are applicable to information produced by a
21 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
22 produced by Non-Parties in connection with this litigation is protected by the
23 remedies and relief provided by this Order. Nothing in these provisions should be
24 construed as prohibiting a Non-Party from seeking additional protections.
25 (b) In the event that a Party is required, by a valid discovery request, to
26 produce a Non-Party’s confidential information in its possession, and the Party is
27 subject to an agreement with the Non-Party not to produce the Non-Party’s
1 (1) promptly notify in writing the Requesting Party and the Non-Party
2 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 reasonably
6 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 Party
11 may produce the Non-Party’s confidential information responsive to the discovery
12 request. If the Non-Party timely seeks a protective order, the Receiving Party shall
13 not produce any information in its possession or control that is subject to the
14 confidentiality agreement with the Non-Party before a determination by the court.
15 Absent a court order to the contrary, the Non-Party shall bear the burden and
16 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 disclosed
19 Protected Material to any person or in any circumstance not authorized under this
20 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
21 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
22 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
23 persons to whom unauthorized disclosures were made of all the terms of this Order,
24 and (d) request such person or persons to execute the “Acknowledgment and
25 Agreement to Be Bound” that is attached hereto as Exhibit A.
26 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
27 PROTECTED MATERIAL
1 inadvertently produced material is subject to a claim of privilege or other protection,
2 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
3 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
4 may be established in an e-discovery order that provides for production without
5 prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar
6 as the parties reach an agreement on the effect of disclosure of a communication or
7 information covered by the attorney-client privilege or work product protection, the
8 parties may incorporate their agreement in the stipulated protective order submitted
9 to the court.
10 12. MISCELLANEOUS
11 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
12 person to seek its modification by the Court in the future.
13 12.2 Right to Assert Other Objections. By stipulating to the entry of this
14 Protective Order no Party waives any right it otherwise would have to object to
15 disclosing or producing any information or item on any ground not addressed in this
16 Stipulated Protective Order. Similarly, no Party waives any right to object on any
17 ground to use in evidence of any of the material covered by this Protective Order.
18 12.3 Filing Protected Material. A Party that seeks to file under seal any
19 Protected Material must comply with Civil Local Rule 79-5. Protected Material may
20 only be filed under seal pursuant to a court order authorizing the sealing of the
21 specific Protected Material at issue. If a Party’s request to file Protected Material
22 under seal is denied by the court, then the Receiving Party may file the information
23 in the public record unless otherwise instructed by the court.
24 13. FINAL DISPOSITION
25 After the final disposition of this Action, as defined in paragraph 4, within 60
26 days of a written request by the Designating Party, each Receiving Party must return
27 all Protected Material to the Producing Party or destroy such material. As used in
1 summaries, and any other format reproducing or capturing any of the Protected
2 Material. Whether the Protected Material is returned or destroyed, the Receiving
3 Party must submit a written certification to the Producing Party (and, if not the same
4 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies
5 (by category, where appropriate) all the Protected Material that was returned or
6 destroyed and (2) affirms that the Receiving Party has not retained any copies,
7 abstracts, compilations, summaries or any other format reproducing or capturing any
8 of the Protected Material. Notwithstanding this provision, Counsel are entitled to
9 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing
10 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
11 reports, attorney work product, and consultant and expert work product, even if such
12 materials contain Protected Material. Any such archival copies that contain or
13 constitute Protected Material remain subject to this Protective Order as set forth in
14 Section 4 (DURATION).
15 14. Any willful violation of this Order may be punished by civil or criminal
16 contempt proceedings, financial or evidentiary sanctions, reference to disciplinary
17 authorities, or other appropriate action at the discretion of the Court.
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19 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
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1 Dated: November 5, 2025 ABIR COHEN TREYZON SALO, LLP &
MOTLEY RICE, LLC
2
3 By: /s/Jonathan Orent
4 Jonathan Orent
5 Jonathan Orent (Pro Hac Vice Forthcoming)
jorent@motleyrice.com
6 MOTLEY RICE, LLC
40 Westminster Street, 5th Floor
7 Providence, RI 02903
8 Daniel R. Lapinski (Pro Hac Vice Forthcoming)
dlapinski@motleyrice.com
9 MOTLEY RICE, LLC
210 Lake Drive East, Suite 101
10 Cherry Hill, NJ 08002
Carmen Scott (Pro Hac Vice Forthcoming)
11 cscott@motleyrice.com
MOTLEY RICE, LLC
12 28 Bridgeside Boulevard
Mount Pleasant, SC 29464
13
Attorneys for Plaintiff John BB Roe
14
15 Dated: November 5, 2025 LARSON LLP
16
By: /s/Rick Richmond
17
Rick Richmond1
18 Andrew E. Calderón
Andrew S. Bledsoe
19 Attorneys for Defendant The Church of Jesus
Christ of Latter-day Saints and Temple
20 Corporation of The Church of Jesus Christ of
Latter-day Saints
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1 Pursuant to Local Rule 5-4.3.4(a)(2)(i), filer hereby attests that all signatories
27 listed, and on whose behalf the filing is submitted, concur in the filing’s content and
have authorized the filing.
1 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
3||DATED: 11/25/2025
4 HON. MARGO A. ROCCONI
United States Magistrate Judge
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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
5 that I have read in its entirety and understand the Stipulated Protective Order that
6 was issued by the United States District Court for the Central District of California
7 on _________ [date] in the case of John BB Roe v. The Church of Jesus Christ of
8 Latter-day Saints, et. al., 2:25-cv-08691-WLH (MARx) (C.D. Cal.). I agree to
9 comply with and to be bound by all the terms of this Stipulated Protective Order and
10 I understand and acknowledge that failure to so comply could expose me to
11 sanctions and punishment in the nature of contempt. I solemnly promise that I will
12 not disclose in any manner any information or item that is subject to this Stipulated
13 Protective Order to any person or entity except in strict compliance with the
14 provisions of this Order.
15 I further agree to submit to the jurisdiction of the United States District Court
16 for the Central District of California for the purpose of enforcing the terms of this
17 Stipulated Protective Order, even if such enforcement proceedings occur after
18 termination of this action. I hereby appoint __________________________ [print
19 or type full name] of _______________________________________ [print or type
20 full address and telephone number] as my California agent for service of process in
21 connection with this action or any proceedings related to enforcement of this
22 Stipulated Protective Order.
23 Date: ______________________________________
24 City and State where signed: _________________________________
25
26 Printed name: _______________________________
27