# Opinion

> District Court, C.D. California · January 21, 2026

URL: https://www.frixlaw.com/law-library/cases/11311183

## Case

- **Full name:** Douglas Malo and Jomaira Jaime v. County of Los Angeles, Deputy Fujino, and Deputies 1-10
- **Court:** District Court, C.D. California
- **Decided:** January 21, 2026
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

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## Opinion text

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7 UNITED STATES DISTRICT COURT
8 CENTRAL DISTRICT OF CALIFORNIA
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10 DOUGLAS MALO, and JOMAIRA Case No. 2:25-cv-10321-SPG (RAO)
JAIME, District Judge: Sherilyn P. Garnett
11 Magistrate Judge: Rozella A. Oliver
Plaintiffs,
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v.
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COUNTY OF LOS ANGELES,
14 DEPUTY FUJINO, and DEPUTIES 1-
10,
15 STIPULATED PROTECTIVE
Defendants. ORDER
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[Discovery Document: Referred to
20 Magistrate Judge Rozella A. Oliver]
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1. A. PURPOSES AND LIMITATIONS
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Discovery in this action is likely to involve production of confidential,
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proprietary, or private information for which special protection from public
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1 disclosure and from use for any purpose other than prosecuting this litigation may
2 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to
3 enter the following Stipulated Protective Order. The parties acknowledge that this
4 Order does not confer blanket protections on all disclosures or responses to
5 discovery and that the protection it affords from public disclosure and use extends
6 only to the limited information or items that are entitled to confidential treatment
7 under the applicable legal principles.
8 B. GOOD CAUSE STATEMENT
9 The parties contend that this action is likely to involve trade secrets, other
10 valuable research, development, commercial, financial, technical and/or proprietary
11 information for which special protection from public disclosure and from use for
12 any purpose other than prosecution of this action is warranted. Such confidential and
13 proprietary materials and information consist of, among other things, Plaintiff’s
14 medical records, personally identifiable information, confidential communication
15 and records, Defendant Deputies’ training and personnel records, and internal
16 investigation materials and findings, confidential business or financial information,
17 information regarding confidential business practices, or other confidential research,
18 development, or commercial information (including information implicating privacy
19 rights of third parties), information otherwise generally unavailable to the public, or
20 which may be privileged or otherwise protected from disclosure under state or
21 federal statutes, court rules, case decisions, or common law. Accordingly, to
22 expedite the flow of information, to facilitate the prompt resolution of disputes over
23 confidentiality of discovery materials, to adequately protect information the parties
24 are entitled to keep confidential, to ensure that the parties are permitted reasonable
25 necessary uses of such material in preparation for and in the conduct of trial, to
26 address their handling at the end of the litigation, and serve the ends of justice, a
27 protective order for such information is justified in this matter. It is the intent of the
28 parties that information will not be designated as confidential for tactical reasons
1 and that nothing be so designated without a good faith belief that it has been
2 maintained in a confidential, non-public manner, and there is good cause why it
3 should not be part of the public record of this case.
C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL
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The parties further acknowledge, as set forth in Section 12.3, below, that this
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Stipulated Protective Order does not entitle them to file confidential information
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under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed
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and the standards that will be applied when a party seeks permission from the court
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to file material under seal.
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There is a strong presumption that the public has a right of access to judicial
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proceedings and records in civil cases. In connection with non-dispositive motions,
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good cause must be shown to support a filing under seal. See Kamakana v. City and
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County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006); Phillips v. Gen. Motors
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Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002); Makar-Welbon v. Sony Electrics,
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Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders
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require good cause showing), and a specific showing of good cause or compelling
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reasons with proper evidentiary support and legal justification, must be made with
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respect to Protected Material that a party seeks to file under seal. The parties’ mere
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designation of Disclosure or Discovery Material as CONFIDENTIAL does not—
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without the submission of competent evidence by declaration, establishing that the
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material sought to be filed under seal qualifies as confidential, privileged, or
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otherwise protectable—constitute good cause.
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Further, if a party requests sealing related to a dispositive motion or trial, then
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compelling reasons, not only good cause, for the sealing must be shown, and the relief
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sought shall be narrowly tailored to serve the specific interest to be protected. See
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Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For each item
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or type of information, document, or thing sought to be filed or introduced under seal
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in connection with a dispositive motion or trial, the party seeking protection must
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1 articulate compelling reasons, supported by specific facts and legal justification, for
2 the requested sealing order. Again, competent evidence supporting the application to
3 file documents under seal must be provided by declaration.
4 Any document that is not confidential, privileged, or otherwise protectable in
5 its entirety will not be filed under seal if the confidential portions can be redacted. If
6 documents can be redacted, then a redacted version for public viewing, omitting only
7 the confidential, privileged, or otherwise protectable portions of the document shall
8 be filed. Any application that seeks to file documents under seal in their entirety
9 should include an explanation of why redaction is not feasible.
10 2. DEFINITIONS
11 2.1 Action: [this pending federal law suit]. [*Option: consolidated or
12 related actions.]
13 2.2 Challenging Party: a Party or Non-Party that challenges the
14 designation of information or items under this Order.
15 2.3 “CONFIDENTIAL” Information or Items: information (regardless of
16 how it is generated, stored, or maintained) or tangible things that qualify for
17 protection under Federal Rule of Civil Procedure 26(c), and as specified above in
18 the Good Cause Statement.
19 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as
20 their support staff).
21 2.5 Designating Party: a Party or Non-Party that designates information
22 or items that it produces in disclosures or in responses to discovery as
23 “CONFIDENTIAL.”
24 2.6 Disclosure or Discovery Material: all items or information, regardless
25 of the medium or manner in which it is generated, stored, or maintained (including,
26 among other things, testimony, transcripts, and tangible things), that are produced
27 or generated in disclosures or responses to discovery in this matter.
28 2.7 Expert: a person with specialized knowledge or experience in a matter
1 pertinent to the litigation who has been retained by a Party or its counsel to serve as
2 an expert witness or as a consultant in this Action.
3 2.8 House Counsel: attorneys who are employees of a party to this Action.
4 House Counsel does not include Outside Counsel of Record or any other outside
5 counsel.
6 2.9 Non-Party: any natural person, partnership, corporation, association,
7 or other legal entity not named as a Party to this action.
8 2.10 Outside Counsel of Record: attorneys who are not employees of a
9 party to this Action but are retained to represent or advise a party to this Action and
10 have appeared in this Action on behalf of that party or are affiliated with a law firm
11 which has appeared on behalf of that party, including support staff.
12 2.11 Party: any party to this Action, including all of its officers, directors,
13 employees, consultants, retained experts, and Outside Counsel of Record (and their
14 support staffs).
15 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
16 Discovery Material in this Action.
17 2.13 Professional Vendors: persons or entities that provide litigation
18 support services (e.g., photocopying, videotaping, translating, preparing exhibits or
19 demonstrations, and organizing, storing, or retrieving data in any form or medium)
20 and their employees and subcontractors.
21 2.14 Protected Material: any Disclosure or Discovery Material that is
22 designated as “CONFIDENTIAL.”
23 2.15 Receiving Party: a Party that receives Disclosure or Discovery
24 Material from a Producing Party.
25 3. SCOPE
26 The protections conferred by this Stipulation and Order cover not only
27 Protected Material (as defined above), but also (1) any information copied or
28 extracted from Protected Material; (2) all copies, excerpts, summaries, or
1 compilations of Protected Material; and (3) any testimony, conversations, or
2 presentations by Parties or their Counsel that might reveal Protected Material.
3 Any use of Protected Material at trial shall be governed by the orders of the
4 trial judge. This Order does not govern the use of Protected Material at trial.
5 4. DURATION
6 Once a case proceeds to trial, information that was designated as
7 CONFIDENTIAL or maintained pursuant to this protective order used or introduced
8 as an exhibit at trial becomes public and will be presumptively available to all
9 members of the public, including the press, unless compelling reasons supported by
10 specific factual findings to proceed otherwise are made to the trial judge in advance
11 of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause”
12 showing for sealing documents produced in discovery from “compelling reasons”
13 standard when merits-related documents are part of court record). Accordingly, the
14 terms of this protective order do not extend beyond the commencement of the trial.
15 5. DESIGNATING PROTECTED MATERIAL
16 5.1 Exercise of Restraint and Care in Designating Material for Protection.
17 Each Party or Non-Party that designates information or items for protection under
18 this Order must take care to limit any such designation to specific material that
19 qualifies under the appropriate standards. The Designating Party must designate for
20 protection only those parts of material, documents, items, or oral or written
21 communications that qualify so that other portions of the material, documents,
22 items, or communications for which protection is not warranted are not swept
23 unjustifiably within the ambit of this Order.
24 Mass, indiscriminate, or routinized designations are prohibited. Designations
25 that are shown to be clearly unjustified or that have been made for an improper
26 purpose (e.g., to unnecessarily encumber the case development process or to impose
27 unnecessary expenses and burdens on other parties) may expose the Designating
28 Party to sanctions.
1 If it comes to a Designating Party’s attention that information or items that it
2 designated for protection do not qualify for protection, that Designating Party must
3 promptly notify all other Parties that it is withdrawing the inapplicable designation.
4 5.2 Manner and Timing of Designations. Except as otherwise provided in
5 this Order (see, e.g., second paragraph of Section 5.2(a) below), or as otherwise
6 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
7 under this Order must be clearly so designated before the material is disclosed or
8 produced.
9 Designation in conformity with this Order requires:
10 (a) for information in documentary form (e.g., paper or electronic
11 documents, but excluding transcripts of depositions or other pretrial or trial
12 proceedings), that the Producing Party affix at a minimum, the legend
13 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
14 contains protected material. If only a portion or portions of the material on a page
15 qualifies for protection, the Producing Party also must clearly identify the protected
16 portion(s) (e.g., by making appropriate markings in the margins).
17 A Party or Non-Party that makes original documents available for
18 inspection need not designate them for protection until after the inspecting Party has
19 indicated which documents it would like copied and produced. During the
20 inspection and before the designation, all of the material made available for
21 inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has
22 identified the documents it wants copied and produced, the Producing Party must
23 determine which documents, or portions thereof, qualify for protection under this
24 Order. Then, before producing the specified documents, the Producing Party must
25 affix the “CONFIDENTIAL legend” to each page that contains Protected Material.
26 If only a portion or portions of the material on a page qualifies for protection, the
27 Producing Party also must clearly identify the protected portion(s) (e.g., by making
28 appropriate markings in the margins).
1 (b) for testimony given in depositions that the Designating Party identify
2 the Disclosure or Discovery Material on the record, before the close of the
3 deposition all protected testimony.
4 (c) for information produced in some form other than documentary and
5 for any other tangible items, that the Producing Party affix in a prominent place on
6 the exterior of the container or containers in which the information is stored the
7 legend “CONFIDENTIAL.” If only a portion or portions of the information
8 warrants protection, the Producing Party, to the extent practicable, shall identify the
9 protected portion(s).
10 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
11 failure to designate qualified information or items does not, standing alone, waive
12 the Designating Party’s right to secure protection under this Order for such material.
13 Upon timely correction of a designation, the Receiving Party must make reasonable
14 efforts to assure that the material is treated in accordance with the provisions of this
15 Order.
16 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
17 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
18 designation of confidentiality at any time that is consistent with the Court’s
19 Scheduling Order.
20 6.2 Meet and Confer. The Challenging Party Shall initiate the dispute
21 resolution process under Civil Local Rule 37-1 et seq.
22 6.3 The burden of persuasion in any such challenge proceeding shall be on
23 the Designating Party. Frivolous challenges, and those made for an improper
24 purpose (e.g., to harass or impose unnecessary expenses and burdens on other
25 parties), may expose the Challenging Party to sanctions. Unless the Designating
26 Party has waived or withdrawn the confidentiality designation, all parties shall
27 continue to afford the material in question the level of protection to which it
28 is entitled under the Producing Party’s designation until the Court rules on the
1 challenge.
2 7. ACCESS TO AND USE OF PROTECTED MATERIAL
3 7.1 Basic Principles. A Receiving Party may use Protected Material that is
4 disclosed or produced by another Party or by a Non-Party in connection with this
5 Action only for prosecuting, defending, or attempting to settle this Action. Such
6 Protected Material may be disclosed only to the categories of persons and under
7 the conditions described in this Order. When the Action has been terminated, a
8 Receiving Party must comply with the provisions of Section 13 below (FINAL
9 DISPOSITION).
10 Protected Material must be stored and maintained by a Receiving Party at
11 a location and in a secure manner that ensures that access is limited to the
12 persons authorized under this Order.
13 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
14 otherwise ordered by the Court or permitted in writing by the Designating Party, a
15 Receiving Party may disclose any information or item designated
16 “CONFIDENTIAL” only to:
17 (a) the Receiving Party’s Outside Counsel of Record in this Action, as
18 well as employees of said Outside Counsel of Record to whom it is reasonably
19 necessary to disclose the information for this Action;
20 (b) the officers, directors, and employees (including House Counsel) of
21 the Receiving Party to whom disclosure is reasonably necessary for this Action;
22 (c) Experts (as defined in this Order) of the Receiving Party to whom
23 disclosure is reasonably necessary for this Action and who have signed the
24 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
25 (d) the Court and its personnel;
26 (e) court reporters and their staff;
27 (f) professional jury or trial consultants, mock jurors, and Professional
28 Vendors to whom disclosure is reasonably necessary for this Action and who have
1 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
2 (g) the author or recipient of a document containing the information or a
3 custodian or other person who otherwise possessed or knew the information;
4 (h) during their depositions, witnesses, and attorneys for witnesses, in
5 the Action to whom disclosure is reasonably necessary provided: (1) the deposing
6 party requests that the witness sign the form attached as Exhibit A hereto; and (2)
7 they will not be permitted to keep any confidential information unless they sign the
8 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
9 agreed by the Designating Party or ordered by the Court. Pages of transcribed
10 deposition testimony or exhibits to depositions that reveal Protected Material may
11 be separately bound by the court reporter and may not be disclosed to anyone except
12 as permitted under this Stipulated Protective Order; and
13 (i) any mediator or settlement officer, and their supporting personnel,
14 mutually agreed upon by any of the parties engaged in settlement discussions.
15 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
16 PRODUCED IN OTHER LITIGATION
17 If a Party is served with a subpoena or a court order issued in other litigation
18 that compels disclosure of any information or items designated in this Action as
19 “CONFIDENTIAL,” that Party must:
20 (a) promptly notify in writing the Designating Party. Such notification
21 shall include a copy of the subpoena or court order;
22 (b) promptly notify in writing the party who caused the subpoena or order
23 to issue in the other litigation that some or all of the material covered by the
24 subpoena or order is subject to this Protective Order. Such notification shall include
25 a copy of this Stipulated Protective Order; and
26 (c) cooperate with respect to all reasonable procedures sought to be
27 pursued by the Designating Party whose Protected Material may be affected.
28 If the Designating Party timely seeks a protective order, the Party served with
1 the subpoena or court order shall not produce any information designated in this
2 action as “CONFIDENTIAL” before a determination by the court from which the
3 subpoena or order issued, unless the Party has obtained the Designating Party’s
4 permission. The Designating Party shall bear the burden and expense of seeking
5 protection in that court of its confidential material, and nothing in these provisions
6 should be construed as authorizing or encouraging a Receiving Party in this Action
7 to disobey a lawful directive from another court.
8 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
9 PRODUCED IN THIS LITIGATION
10 (a) The terms of this Order are applicable to information produced by a
11 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
12 produced by Non-Parties in connection with this litigation is protected by the
13 remedies and relief provided by this Order. Nothing in these provisions should be
14 construed as prohibiting a Non-Party from seeking additional protections.
15 (b) In the event that a Party is required, by a valid discovery request, to
16 produce a Non-Party’s confidential information in its possession, and the Party is
17 subject to an agreement with the Non-Party not to produce the Non-Party’s
18 confidential information, then the Party shall:
19 (1) promptly notify in writing the Requesting Party and the Non-Party
20 that some or all of the information requested is subject to a confidentiality agreement
21 with a Non-Party;
22 (2) promptly provide the Non-Party with a copy of the Stipulated
23 Protective Order in this Action, the relevant discovery request(s), and a reasonably
24 specific description of the information requested; and
25 (3) make the information requested available for inspection by the Non-
26 Party, if requested.
27 (c) If the Non-Party fails to seek a protective order from this Court within
28 14 days of receiving the notice and accompanying information, the Receiving Party
1 may produce the Non-Party’s confidential information responsive to the discovery
2 request. If the Non-Party timely seeks a protective order, the Receiving Party shall
3 not produce any information in its possession or control that is subject to the
4 confidentiality agreement with the Non-Party before a determination by the Court.
5 Absent a court order to the contrary, the Non-Party shall bear the burden and
6 expense of seeking protection in this Court of its Protected Material.
7 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
8 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
9 Protected Material to any person or in any circumstance not authorized under this
10 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
11 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
12 to retrieve all unauthorized copies of the Protected Material, (c) inform the person
13 or persons to whom unauthorized disclosures were made of all the terms of this
14 Order, and (d) request such person or persons to execute the “Acknowledgment and
15 Agreement to Be Bound” that is attached hereto as Exhibit A.
16 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
17 PROTECTED MATERIAL
18 When a Producing Party gives notice to Receiving Parties that certain
19 inadvertently produced material is subject to a claim of privilege or other protection,
20 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
21 Procedure 26(b)(5)(B). This provision is not intended to modify whatever
22 procedure may be established in an e-discovery order that provides for production
23 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and
24 (e), insofar as the parties reach an agreement on the effect of disclosure of a
25 communication or information covered by the attorney-client privilege or work
26 product protection, the parties may incorporate their agreement in the stipulated
27 protective order submitted to the Court.
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1 12. MISCELLANEOUS
2 12.1 Right to Relief. Nothing in this Order abridges the right of any person
3 to seek its modification by the Court in the future.
4 12.2 Right to Assert Other Objections. By stipulating to the entry of this
5 Protective Order, no Party waives any right it otherwise would have to object to
6 disclosing or producing any information or item on any ground not addressed in
7 this Stipulated Protective Order. Similarly, no Party waives any right to object on
8 any ground to use in evidence of any of the material covered by this Protective
9 Order.
10 12.3 Filing Protected Material. A Party that seeks to file under seal any
11 Protected Material must comply with Civil Local Rule 79-5. Protected Material
12 may only be filed under seal pursuant to a court order authorizing the sealing of the
13 specific Protected Material at issue. If a Party’s request to file Protected Material
14 under seal is denied by the court, then the Receiving Party may file the information
15 in the public record unless otherwise instructed by the court.
16 13. FINAL DISPOSITION
17 Final disposition shall be deemed to be the later of (1) dismissal of all claims
18 and defenses in this Action, with or without prejudice; and (2) final judgment herein
19 after the completion and exhaustion of all appeals, rehearings, remands, trials, or
20 reviews of this Action, including the time limits for filing any motions or
21 applications for extension of time pursuant to applicable law. After the final
22 disposition of this Action, within 60 days of a written request by the Designating
23 Party, each Receiving Party must return all Protected Material to the Producing
24 Party or destroy such material. As used in this subdivision, “all Protected Material”
25 includes all copies, abstracts, compilations, summaries, and any other format
26 reproducing or capturing any of the Protected Material. Whether the Protected
27 Material is returned or destroyed, the Receiving Party must submit a written
28 certification to the Producing Party (and, if not the same person or entity, to the
1 Designating Party) by the 60 day deadline that (1) identifies (by category, where
2 appropriate) all the Protected Material that was returned or destroyed; and (2)
3 affirms that the Receiving Party has not retained any copies, abstracts, compilations,
4 summaries, or any other format reproducing or capturing any of the Protected
5 Material. Notwithstanding this provision, Counsel are entitled to retain an archival
6 copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal
7 memoranda, correspondence, deposition and trial exhibits, expert reports, attorney
8 work product, and consultant and expert work product, even if such materials
9 contain Protected Material. Any such archival copies that contain or constitute
10 Protected Material remain subject to this Protective Order as set forth in Section 4
11 (DURATION).
12 14. VIOLATION
13 Any violation of this Order may be punished by any and all appropriate
14 measures including, without limitation, contempt proceedings and/or monetary
15 sanctions.
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17 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
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Dated: January 21, 2026 KIRAKOSIAN LAW, APC
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21 /s/ Greg L. Kirakosian, Esq.
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Greg L. Kirakosian, Esq.
23 Raffi S. Batanian, Esq.
Attorney For Plaintiffs,
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Douglas Michael Malo, Jomaira Jaime
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1 Dated: January 21, 2026 MANNING & KASS, ELLROD, RAMIREZ, TRESTER,
LLP
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/s/ Kelly A. Duncan
4 Eugene P. Ramirez
5 Geoffrey Plowden
Kelly A. Duncan
6 Attorney for Defendants County Of Los Angeles;
7 Deputy Fujino
g |7?]}]s
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FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

4) Darep: 1/21/2026 Rael OA. OL
Id Honorable Rozella A. Oliver
16 United States Magistrate Judge
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1&

1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3
4 I, _____________________________ [print or type full name], of
5 _________________ [print or type full address], declare under penalty of perjury
6 that I have read in its entirety and understand the Stipulated Protective Order that
7 was issued by the United States District Court for the Central District of California
8 on [date] in the case of Mark Thorn, an individual. et. al. v. County of Los Angeles,
9 a public entity, et. al., Case No.: 2:25-cv-09247-GW-SK. I agree to comply with
10 and to be bound by all the terms of this Stipulated Protective Order, and I understand
11 and acknowledge that failure to so comply could expose me to sanctions and
12 punishment in the nature of contempt. I solemnly promise that I will not disclose in
13 any manner any information or item that is subject to this Stipulated Protective
14 Order to any person or entity except in strict compliance with the provisions of this
15 Order.
16 I further agree to submit to the jurisdiction of the United States District Court
17 for the Central District of California for the purpose of enforcing the terms of this
18 Stipulated Protective Order, even if such enforcement proceedings occur after
19 termination of this action. I hereby appoint __________________________ [print
20 or type full name] of _______________________________________ [print or type
21 full address and telephone number] as my California agent for service of process in
22 connection with this action or any proceedings related to enforcement of this
23 Stipulated Protective Order.
24 Date: ____________________ Signature: ______________________
25 Printed name: ___________________
26 City and State where sworn and signed: _______________________
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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/11311183. Public record. Not legal advice.