Opinion

Court: District Court, C.D. California
Filed: Jan 9, 2026
Cited by: 0 cases
Authority: More cited than 38.6%

distinguishing “good cause” showing for sealing 1144 documents produced in discovery from “compelling reasons” standard when 1155 merits-related documents are part of court record

How later courts described this case

distinguishing “good cause” showing for sealing 1144 documents produced in discovery from “compelling reasons” standard when 1155 merits-related documents are part of court record

Written by the judges who cited it.

The opinion

11 THE SEHAT LAW FIRM, PLC

Nicholas Brosamle, Esq. (SBN 356492)

22 Cameron Sehat, Esq. (SBN: 256535)

Jeffrey Mikel, Esq (SBN: 350671)

33 5100 Campus Dr., Suite 200

Newport Beach, CA 92660

44 Telephone: (949) 825-5200

Facsimile: (949) 313-5001

55 Cameron@sehatlaw.com

n.brosamle@sehatlaw.com

j.mikel@sehatlaw.com

Attorney for Plaintiffs, L.J., K.J., Raya Johnson-Kelly and Chris Kelly

UNITED STATES DISTRICT COURT

1100 CENTRAL DISTRICT OF CALIFORNIA

1111

L.J. a minor, individually and as Case No: 2:25-cv-03751 MRA (Ex)

1122 personal representative of the Estate of

Rhaquan Johnson, by her mother and Hon. Monica Ramirez Almadani

1133

guardian ad litem Mia Tafoya, K.J. a

1144 minor, individually and as personal STIPULATED PROTECTIVE

representative of the Estate of Rhaquan ORDER

1155

Johnson, by her mother and guardian

1166 ad litem Mia Tafoya, Raya Johnson-

Kelly individually, Chris Kelly,

1177

individually,

1188

Plaintiffs,

1199

vs.

2200

CITY OF LOS ANGELES, a

2211

government entity, Michael Meiser,

2222 and DOES 1-10 inclusive

2233

Defendants.

2244

2255

1. A. PURPOSES AND LIMITATIONS

2266

Discovery in this action is likely to involve production of confidential,

2277

proprietary, or private information for which special protection from public

disclosure and from use for any purpose other than prosecuting this litigation

may be warranted. Accordingly, the parties hereby stipulate to and petition the

Court to enter the following Stipulated Protective Order. The parties

acknowledge that this Order does not confer blanket protections on all disclosures

or responses to discovery and that the protection it affords from public

disclosure and use extends only to the limited information or items that are

entitled to confidential treatment under the applicable legal principles. The parties

further acknowledge, as set forth in Section 12.3, below, that this Stipulated

Protective Order does not entitle them to file confidential information under seal;

1100

Civil Local Rule 79-5 sets forth the procedures that must be followed and the

1111

standards that will be applied when a party seeks permission from the Court to file

1122

material under seal. The parties must also comply with any pertinent orders from

1133

District Judge Monica Ramirez Almadani and Magistrate Judge Charles F. Eick.

1144

1155

B. GOOD CAUSE STATEMENT

1166

The Parties represent that pre-trial discovery in this case is likely to include

1177

the production of information and/or documents that are confidential and/or

1188

privileged, including the production of peace officer personnel file information

1199

and/or documents which the Parties agree includes: (1) Personal data, including

2200

marital status, family members, educational and employment history, home

2211

addresses, or similar information; (2) Medical history; (3) Police officer employee

2222

personnel file; (4) Employee advancement, appraisal, or discipline; (5) Evidence

2233

gathered by law enforcement as part of an ongoing criminal investigation (6)

2244

Complaints, or investigations of complaints, concerning an event or transaction in

2255

which a peace officer participated, or which a peace officer perceived, and

2266

pertaining to the manner in which the peace officer performed his or her duties

2277

including compelled statements by peace officers unless specifically denoted as

“not confidential” pursuant to Penal Code section 832.7; (7) internal investigative

files and documents; (8) email and written correspondence records; (8)

confidential information with financial records; (9) video footage and/or

photographs related to the incident; (10) psychological and medical notes,

evaluations, reports, and treatment plans; and (11) policies and procedures that are

kept from the public in the ordinary course of business, as well as other

information that is not generally available to the public and Defendants contend is

subject to the Official Information Privilege and other privileges. Sanchez v. City

of Santa Ana, 936 F.2d 1027, 1033 (9th Cir. Cal. 1990); see also Kerr v. United

1100

States Dist. Ct. for N.D. Cal., 511 F.2d 192, 198 (9th Cir.1975), aff'd, 426 U.S.

1111

394 (1976).

1122

Testimony taken at a deposition may be designated as Confidential by making

1133

a statement to that effect on the record at the deposition. Arrangements shall be made

1144

with the court reporter transcribing the deposition to separately bind such portions

1155

of the transcript containing information designated as Confidential, and to label such

1166

portions appropriately. Confidential photographs, video or audio footage obtained

1177

through the course of discovery or otherwise may not be used for any purpose other

1188

than litigating this lawsuit. The parties agree to refrain from directly or indirectly

1199

disclosing or publicly disseminating confidential deposition testimony, and/or

2200

photographs, video or audio footage obtained through the course of discovery or

2211

otherwise, specifically including, but not limited to, dissemination via billboard

2222

advertisements, print and online media organizations, or any other internet posting

2233

or social media. If any party intends to use such confidential materials for any

2244

purpose other than litigating this lawsuit, the party seeking public disclosure must

2255

first seek approval from the Court.

2266

The incident at issue in this action involves events that include the alleged

2277

illicit smuggling of narcotics into the Pitchess Detention Center at the North

County Correctional Facility, operated by the Los Angeles County Sheriff’s

Department. Defendant Meiser and at least 18 other individuals have been

indicted pursuant to a joint and ongoing investigation by the Los Angeles County

Sheriff’s Department and the FBI’s San Gabriel Valley Safe Streets Task Force in

regards to drug smuggling within the County jail system. Discovery may require

the production of certain Los Angeles County Sheriff’s Department’s

investigative findings and materials that are privileged and confidential during the

pendency of the criminal prosecution. This information and materials are not

available to the public and public disclosure at this time could risk compromising

1100

the underlying criminal prosecution, and/or impeding further investigation. In

1111

addition to the aforesaid investigative findings and materials, Peace officer

1122

personnel file information and/or documents and security-sensitive policies and

1133

procedures are hereinafter referred to as "Confidential Information".

1144

The parties contend that that public disclosure of such material poses a

1155

substantial risk and jeopardy to the underlying criminal prosecution. Finally, the

1166

parties contend that the benefit of public disclosure of Confidential Information is

1177

minimal while the potential disadvantages are great.

1188

In light of the nature of the claims and allegations in this case and the parties’

1199

representations that discovery in this case will involve the production of confidential

2200

records, and in order to expedite the flow of information, to facilitate the prompt

2211

resolution of disputes over confidentiality of discovery materials, to adequately

2222

protect information the parties are entitled to keep confidential, to ensure that the

2233

parties are permitted reasonable necessary uses of such material in connection with

2244

this action, to address their handling of such material at the end of the litigation, and

2255

to serve the ends of justice, a protective order for such information is justified in this

2266

matter. The parties shall not designate any information/documents as confidential

2277

without a good faith belief that such information/documents have been maintained

in a confidential, non-public manner, and that there is good cause or a compelling

reason why it should not be part of the public record of this case.

Accordingly, good cause exists for entry of this Protective Order to

facilitate pre-trial disclosure to allow the parties to support their claims and

defenses while assuring the safety of these sensitive disclosures. See Fed. R. Civ.

Proc. 26(c).

2. DEFINITIONS

2.1 Action: L.J., et al. v. County of Los Angeles, et al., Case No. 2:25-cv-

03751 MRA (Ex)

1100

2.2 Challenging Party: a Party or Non-Party that challenges the

1111

designation of information or items under this Order.

1122

2.3 “CONFIDENTIAL” Information or Items: information (regardless of how

1133

it is generated, stored, or maintained) or tangible things that qualify for protection

1144

under Federal Rule of Civil Procedure 26(c), and as specified above in the

1155

Good Cause Statement.

1166

2.4 Counsel: Outside Counsel of Record and House Counsel (as well as

1177

their support staff).

1188

2.5 Designating Party: a Party or Non-Party that designates information or

1199

items that it produces in disclosures or in responses to discovery as

2200

“CONFIDENTIAL.”

2211

2.6 Disclosure or Discovery Material: all items or information, regardless of

2222

the medium or manner in which it is generated, stored, or maintained (including,

2233

among other things, testimony, transcripts, and tangible things), that are produced

2244

or generated in disclosures or responses to discovery in this matter.

2255

2.7 Expert: a person with specialized knowledge or experience in a matter

2266

pertinent to the litigation who has been retained by a Party or its counsel to serve

2277

as an expert witness or as a consultant in this Action.

2.8 House Counsel: attorneys who are employees of a party to this Action.

House Counsel does not include Outside Counsel of Record or any other

outside counsel.

2.9 Non-Party: any natural person, partnership, corporation, association, or

other legal entity not named as a Party to this action.

2.10 Outside Counsel of Record: attorneys who are not employees of a

party to this Action but are retained to represent or advise a party to this Action

and have appeared in this Action on behalf of that party or are affiliated with a

law firm which has appeared on behalf of that party, and includes support staff.

1100

2.11 Party: any party to this Action, including all of its officers, directors,

1111

employees, consultants, retained experts, and Outside Counsel of Record (and

1122

their support staffs).

1133

2.12 Producing Party: a Party or Non-Party that produces Disclosure or

1144

Discovery Material in this Action.

1155

2.13 Professional Vendors: persons or entities that provide litigation support

1166

services (e.g., photocopying, videotaping, translating, preparing exhibits or

1177

demonstrations, and organizing, storing, or retrieving data in any form or

1188

medium) and their employees and subcontractors.

1199

2.14 Protected Material: any Disclosure or Discovery Material that is designated

2200

as “CONFIDENTIAL.”

2211

2.15 Receiving Party: a Party that receives Disclosure or Discovery Material

2222

from a Producing Party.

2233

2244

3. SCOPE

2255

The protections conferred by this Stipulation and Order cover not only Protected

2266

Material (as defined above), but also (1) any information copied or extracted from

2277

Protected Material; (2) all copies, excerpts, summaries, or compilations of

Protected Material; and (3) any testimony, conversations, or presentations by

Parties or their Counsel that might reveal Protected Material.

Any use of Protected Material at trial shall be governed by the orders of the trial

judge. This Order does not govern the use of Protected Material at trial.

4. DURATION

Once a case proceeds to trial, all of the court-filed information to be introduced

that was previously designated as confidential or maintained pursuant to this

protective order becomes public and will be presumptively available to all

1100

members of the public, including the press, unless compelling reasons supported

1111

by specific factual findings to proceed otherwise are made to the trial judge in

1122

advance of the trial. See Kamakana v. City and County of Honolulu, 447 F.3d

1133

1172, 1180-81 (9th Cir. 2006) (distinguishing “good cause” showing for sealing

1144

documents produced in discovery from “compelling reasons” standard when

1155

merits-related documents are part of court record). Accordingly, the terms of this

1166

protective order do not extend beyond the commencement of the trial.

1177

1188

5. DESIGNATING PROTECTED MATERIAL

1199

5.1 Exercise of Restraint and Care in Designating Material for Protection. Each

2200

Party or Non-Party that designates information or items for protection under this

2211

Order must take care to limit any such designation to specific material that

2222

qualifies under the appropriate standards. The Designating Party must designate

2233

for protection only those parts of material, documents, items, or oral or written

2244

communications that qualify so that other portions of the material, documents, or

2255

communications for which protection is not warranted are not swept unjustifiably

2266

within the ambit of this Order.

2277

Mass, indiscriminate, or routinized designations are prohibited. Designations that

are shown to be clearly unjustified or that have been made for an improper

purpose (e.g., to unnecessarily encumber the case development process or to

impose unnecessary expenses and burdens on other parties) may expose the

Designating Party to sanctions.

If it comes to a Designating Party’s attention that information or items that it

designated for protection do not qualify for protection, that Designating Party

must promptly notify all other Parties that it is withdrawing the inapplicable

designation.

5.2 Manner and Timing of Designations. Except as otherwise provided in this

1100

Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise

1111

stipulated or ordered, Disclosure or Discovery Material that qualifies for

1122

protection under this Order must be clearly so designated before the material is

1133

disclosed or produced.

1144

Designation in conformity with this Order requires:

1155

(a) for information in documentary form (e.g., paper or electronic documents,

1166

but excluding transcripts of depositions or other pretrial or trial proceedings), that

1177

the Producing Party affix at a minimum, the legend “CONFIDENTIAL”

1188

(hereinafter “CONFIDENTIAL legend”), to each page that contains protected

1199

material. If only a portion or portions of the material on a page qualifies for

2200

protection, the Producing Party also must clearly identify the protected portion(s)

2211

(e.g., by making appropriate markings in the margins).

2222

A Party or Non-Party that makes original documents available for inspection need

2233

not designate them for protection until after the inspecting Party has indicated

2244

which documents it would like copied and produced. During the inspection and

2255

before the designation, all of the material made available for inspection shall be

2266

deemed “CONFIDENTIAL.” After the inspecting Party has identified

2277

the documents, it wants copied and produced, the Producing Party must determine

which documents, or portions thereof, qualify for protection under this Order.

Then, before producing the specified documents, the Producing Party must affix

the “CONFIDENTIAL legend” to each page that contains Protected Material. If

only a portion or portions of the material on a page qualifies for protection, the

Producing Party also must clearly identify the protected portion(s) (e.g., by

making appropriate markings in the margins).

(b) for testimony given in depositions that the Designating Party (or if the

Designating party is a non-party not present at the deposition, the Receiving Party)

identify the Disclosure or Discovery Material on the record, before the close of

1100

the deposition all protected testimony.

1111

1122

any other tangible items, that the Producing Party affix in a prominent place on

1133

the exterior of the container or containers in which the information is stored

1144

the legend “CONFIDENTIAL.” If only a portion or portions of the information

1155

warrants protection, the Producing Party, to the extent practicable, shall identify

1166

the protected portion(s).

1177

5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent

1188

failure to designate qualified information or items does not, standing alone,

1199

waive the Designating Party’s right to secure protection under this Order for such

2200

material. Upon timely correction of a designation, the Receiving Party must make

2211

reasonable efforts to assure that the material is treated in accordance with the

2222

provisions of this Order.

2233

2244

6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

2255

6.1 Timing of Challenges. Any Party or Non-Party may challenge a

2266

designation of confidentiality at any time that is consistent with the Court’s

2277

Scheduling Order.

6.2 Meet and Confer. The Challenging Party shall initiate the dispute

resolution process under Local Rule 37.1 et seq. Any discovery motion must

strictly comply with the procedures set forth in Local Rules 37-1, 37-2, and 37-

3, or follow the procedures for informal, telephonic discovery hearings on the

Court's website.

6.3 The burden of persuasion in any such challenge proceeding shall be on the

Designating Party. Frivolous challenges, and those made for an improper

purpose (e.g., to harass or impose unnecessary expenses and burdens on other

parties) may expose the Challenging Party to sanctions. Unless the Designating

1100

Party has waived or withdrawn the confidentiality designation, all parties shall

1111

continue to afford the material in question the level of protection to which it is

1122

entitled under the Producing Party’s designation until the Court rules on the

1133

challenge.

1144

1155

7. ACCESS TO AND USE OF PROTECTED MATERIAL

1166

7.1 Basic Principles. A Receiving Party may use Protected Material that is

1177

disclosed or produced by another Party or by a Non-Party in connection with this

1188

Action only for prosecuting, defending, or attempting to settle this Action. Such

1199

Protected Material may be disclosed only to the categories of persons and under

2200

the conditions described in this Order. When the Action has been terminated, a

2211

Receiving Party must comply with the provisions of section 13 below (FINAL

2222

DISPOSITION).

2233

2244 Protected Material must be stored and maintained by a Receiving Party at a

2255 location and in a secure manner that ensures that access is limited to the persons

2266 authorized under this Order.

2277 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise

ordered by the Court or permitted in writing by the Designating Party, a Receiving

Party may disclose any information or item designated “CONFIDENTIAL” only

to:

(a) the Receiving Party’s Outside Counsel of Record in this Action, as well as

employees of said Outside Counsel of Record to whom it is reasonably necessary

to disclose the information for this Action;

b) the officers, directors, and employees (including House Counsel) of the

Receiving Party to whom disclosure is reasonably necessary for this Action;

disclosure is reasonably necessary for this Action and who have signed the

1100

“Acknowledgment and Agreement to Be Bound” (Exhibit A);

1111

(d) the Court and its personnel;

1122

(e) court reporters and their staff;

1133

(f) professional jury or trial consultants, mock jurors, and Professional Vendors

1144

to whom disclosure is reasonably necessary for this Action and who have signed

1155

the “Acknowledgment and Agreement to Be Bound” (Exhibit A);

1166

(g) the author or recipient of a document containing the information or a

1177

custodian or other person who otherwise possessed or knew the information;

1188

(h) during their depositions, witnesses ,and attorneys for witnesses, in the Action

1199

to whom disclosure is reasonably necessary provided: (1) the deposing party

2200

requests that the witness sign the form attached as Exhibit A hereto; and (2) they

2211

will not be permitted to keep any confidential information unless they sign the

2222

“Acknowledgment and Agreement to Be Bound” (Exhibit A), unless

2233

otherwise agreed by the Designating Party or ordered by the Court. Pages of

2244

transcribed deposition testimony or exhibits to depositions that reveal Protected

2255

Material may be separately bound by the court reporter and may not be disclosed

2266

to anyone except as permitted under this Stipulated Protective Order; and

2277

(i) any mediator or settlement officer, and their supporting personnel, mutually

agreed upon by any of the parties engaged in settlement discussions, or appointed

by the Court

8. PROTECTED MATERIAL SUBPOENAED OR ORDERED

PRODUCED IN OTHER LITIGATION

If a Party is served with a subpoena or a court order issued in other litigation that

compels disclosure of any information or items designated in this Action as

“CONFIDENTIAL,” that Party must:

(a) promptly notify in writing the Designating Party. Such notification shall

1100

include a copy of the subpoena or court order;

1111

(b) promptly notify in writing the party who caused the subpoena or order to

1122

issue in the other litigation that some or all of the material covered by the

1133

subpoena or order is subject to this Protective Order. Such notification shall

1144

include a copy of this Stipulated Protective Order; and

1155

1166

the Designating Party whose Protected Material may be affected.

1177

If the Designating Party timely seeks a protective order, the Party served with the

1188

subpoena or court order shall not produce any information designated in this

1199

action as “CONFIDENTIAL” before a determination by the court from which the

2200

subpoena or order issued, unless the Party has obtained the Designating Party’s

2211

permission. The Designating Party shall bear the burden and expense of seeking

2222

protection in that court of its confidential material and nothing in these provisions

2233

should be construed as authorizing or encouraging a Receiving Party in this

2244

Action to disobey a lawful directive from another court.

2255

2266

9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

2277

PRODUCED IN THIS LITIGATION

(a) The terms of this Order are applicable to information produced by a Non-

Party in this Action and designated as “CONFIDENTIAL.” Such information

produced by Non-Parties in connection with this litigation is protected by the

remedies and relief provided by this Order. Nothing in these provisions should be

construed as prohibiting a Non-Party from seeking additional protections.

(b) In the event that a Party is required, by a valid discovery request, to produce

a Non-Party’s confidential information in its possession, then the Party shall:

(1) promptly notify in writing the Requesting Party and the Non-Party that some

or all of the information requested is subject to a confidentiality agreement with a

1100

Non-Party;

1111

(2) promptly provide the Non-Party with a copy of the Stipulated Protective

1122

Order in this Action, the relevant discovery request(s), and a reasonably specific

1133

description of the information requested; and

1144

(3) make the information requested available for inspection by the

1155

Non-Party, if requested.

1166

1177

14 days of receiving the notice and accompanying information, the Receiving

1188

Party may produce the Non-Party’s confidential information responsive to the

1199

discovery request. If the Non-Party timely seeks a protective order, the Receiving

2200

Party shall not produce any information in its possession or control that is subject

2211

to this order, or any confidentiality agreement with the Non-Party, before a

2222

determination by the Court. Absent a court order to the contrary, the Non-Party

2233

shall bear the burden and expense of seeking protection in this Court of its

2244

Protected Material.

2255

2266

10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

2277

If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed

Protected Material to any person or in any circumstance not authorized under this

Stipulated Protective Order, the Receiving Party must immediately (a) notify in

writing the Designating Party of the unauthorized disclosures, (b) use its best

efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the

person or persons to whom unauthorized disclosures were made of all the terms of

this Order, and (d) request such person or persons to execute the

“Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit

11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

1100

PROTECTED MATERIAL

1111

When a Producing Party gives notice to Receiving Parties that certain

1122

inadvertently produced material is subject to a claim of privilege or other

1133

protection, the obligations of the Receiving Parties are those set forth in Federal

1144

Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify

1155

whatever procedure may be established in an e-discovery order that provides

1166

for production without prior privilege review. Pursuant to Federal Rule of

1177

Evidence 502(d) and (e), insofar as the parties reach an agreement on the effect of

1188

disclosure of a communication or information covered by the attorney-client

1199

privilege or work product protection, the parties may incorporate their agreement

2200

in the stipulated protective order submitted to the Court.

2211

2222

12. MISCELLANEOUS

2233

12.1 Right to Further Relief. Nothing in this Order abridges the right of any

2244

person to seek its modification by the Court in the future.

2255

12.2 Right to Assert Other Objections. By stipulating to the entry of this

2266

Protective Order, no Party waives any right it otherwise would have to object to

2277

disclosing or producing any information or item on any ground not addressed in

this Stipulated Protective Order. Similarly, no Party waives any right to object on

any ground to use in evidence of any of the material covered by this Protective

Order.

12.3 Filing Protected Material. A Party that seeks to file under seal any

Protected Material must comply with Civil Local Rule 79-5. Protected Material

may only be filed under seal pursuant to a court order authorizing the sealing of

the specific Protected Material at issue. If a Party's request to file Protected

Material under seal is denied by the Court, then the Receiving Party may file the

information in the public record only after providing the designating party with

1100

notice and opportunity to object, and unless otherwise instructed by the Court.

1111

1122

13. FINAL DISPOSITION

1133

1144

After the final disposition of this Action, as defined in paragraph 4, within 60 days

1155

of a written request by the Designating Party, each Receiving Party must return all

1166

Protected Material to the Producing Party or destroy such material. As used in

1177

this subdivision, “all Protected Material” includes all copies, abstracts,

1188

compilations, summaries, and any other format reproducing or capturing any of

1199

the Protected Material. Whether the Protected Material is returned or destroyed,

2200

the Receiving Party must submit a written certification to the Producing Party

2211

(and, if not the same person or entity, to the Designating Party) by the 60 day

2222

deadline that (1) identifies (by category, where appropriate) all the Protected

2233

Material that was returned or destroyed, and (2)affirms that the Receiving

2244

Party has not retained any copies, abstracts, compilations, summaries or any

2255

other format reproducing or capturing any of the Protected Material.

2266

Notwithstanding this provision, Counsel are entitled to retain an archival copy of

2277

all pleadings, motion papers, trial, deposition, and hearing transcripts, legal

memoranda, correspondence, deposition and trial exhibits, expert reports, attorney

work product, and consultant and expert work product, even if such materials

contain Protected Material. Any such archival copies that contain or constitute

Protected Material remain subject to this Protective Order as set forth in Section 4

(DURATION).

14. VIOLATION OF ORDER

1100 Any violation of this Order may be punished by any and all appropriate measures

1111 including, without limitation, contempt proceedings sanctions and/or monetary

1122 sanctions.

1133

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD

1144

1155

1166 DATED: 1/7/2026 THE SEHAT LAW FIRM, PLC

1177 s/ Cameron Sehat

1188 Cameron Sehat, Esq.

Jeffrey Mikel, Esq.

1199 Attorneys for Plaintiffs

2200

DATED: 1/7/2026

2211

2222 s/ Christina Gasparian

Thomas C. Hurrell, Esq.

2233 Christina Gasparian, Esq.

2244 Angela S. Parayno, Esq.

Attorneys for Defendant, County

2255 of Los Angeles

2266

2277

11 DATED: 1/7/2026

s/ Tiffany L. Salayer

33 Tomas A. Guterres, Esq.

Tiffany L. Salayer, Esq.

Attorneys for Defendant

55 Michael Meiser

88 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

DATED: 1/9/2026

1100

__________________________________

1111 Hon. Charles F. Eick

United States Magistrate Judge

1122

1133

1144

1155

1166

1177

1188

1199

2200

2211

2222

2233

2244

2255

2266

2277

11 EXHIBIT A

22 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

I, [print or type full name], of____________________

[full address], declare under penalty of perjury that I have read in its entirety

and understand the Stipulated Protective Order that was issued by the United

States District Court for the Central District of California on _________ [date] in

the case of L.J. v. City of Los Angeles; Case No: 2:25-cv-03751 MRA-Ex. I

agree to comply with and to be bound by all the terms of this Stipulated Protective

Order and I understand and acknowledge that failure to so comply could expose

1100

me to sanctions and punishment in the nature of contempt. I solemnly promise that

1111

I will not disclose in any manner any information or item that is subject to this

1122

Stipulated Protective Order to any person or entity except in strict compliance

1133

with the provisions of this Order.

1144

I further agree to submit to the jurisdiction of the United States District Court for

1155

the Central District of California for the purpose of enforcing the terms of this

1166

Stipulated Protective Order, even if such enforcement proceedings occur after

1177

termination of this action. I hereby appoint [print

1188

or type full name] of [print or

1199

type full address and telephone number] as my California agent for service of

2200

process in connection with this action or any proceedings related to enforcement

2211

of this Stipulated Protective Order.

2222

2233

Date:

2244

City and State where sworn and signed:

2255

2266

Printed name:

2277

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.