Opinion

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7 UNITED STATES DISTRICT COURT

8 CENTRAL DISTRICT OF CALIFORNIA

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10 KLOII HOLLIS, an individual, CASE NO. 2:25-cv-06319-SK

Hon. Steve Kim– Ctrm. 540

11 Plaintiff,

12 v. STIPULATED PROTECTIVE

ORDER

13 CITY OF LOS ANGELES, a

municipality; and DOES 1-10, inclusive,

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Defendants.

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16 1. A. PURPOSES AND LIMITATIONS

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

18 proprietary, or private information for which special protection from public disclosure

19 and from use for any purpose other than prosecuting this litigation may be warranted.

20 Accordingly, the parties hereby stipulate to and petition the Court to enter the following

21 Stipulated Protective Order. The parties acknowledge that this Order does not confer

22 blanket protections on all disclosures or responses to discovery and that the protection it

23 affords from public disclosure and use extends only to the limited information or items

24 that are entitled to confidential treatment under the applicable legal principles. The

25 parties further acknowledge, as set forth in Section 12.3 (Filing Protected Material),

26 below, that this Stipulated Protective Order does not entitle them to file confidential

27 information under seal; Civil Local Rule 79-5 sets forth the procedures that must be

1 court to file material under seal.

2 B. GOOD CAUSE STATEMENT

3 This case involves an alleged encounter between Plaintiff Kloii Hollis and Los

4 Angeles Police Department officers during a protest that occurred on or about June 23,

5 2024. While attending a protest near 8900 block of West Pico Blvd., Ms. Hollis alleges

6 that she was struck in the face by a police baton and that she has suffered injuries as a

7 result. As such, there may be voluminous materials that the City deems sensitive,

8 including police reports, videos, and other law enforcement records, which may be

9 protected pursuant to Government Code § 6254(f), Penal Code §§ 832.5, 832.7, 832.8

10 and 11105, and Evidence Code § 1040. Further, it is possible the parties in this action

11 may seek confidential information relating to individual police officers and as such their

12 privacy rights may also be implicated pursuant to Evidence Code § 1043, and Pitchess

13 v. Superior Court (1974) 11 Cal.3d 531, 535. See also Green v. Baca, 226 F.R.D. 624,

14 653 (C.D. Cal. 2005) and A. Farber and Partners, Inc. v. Garber, 234 F.R.D. 186, 189-

15 90 (C.D. Cal. 2006). Federal law also recognizes a qualified privilege for official

16 information. Kerr v. United States District Court for the Northern District of California,

17 511 F.2d 192, 198 (9th Cir.1975), aff’d, 426 U.S. 394 (1976); Sanchez v. City of Santa

18 Ana, 936 F.2d 1027, 1033 (9th Cir. 1990), cert. denied, 502 U.S. 957 (1991). It is the

19 position of the City of Los Angeles and the Los Angeles Police Department that the

20 release of such records cannot be considered absent a protective order and, in some

21 cases, a court order. Plaintiff’s medical records may also be produced during discovery,

22 which may be of a sensitive or graphic nature, and contain both Personally Identifiable

23 Information (PII) and Protected Health Information (PHI).

24 Accordingly, to expedite the flow of information, to facilitate the prompt

25 resolution of disputes over confidentiality of discovery materials, to adequately protect

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

27 permitted reasonable necessary uses of such material in preparation for and in the

1 intent of the parties that information will not be designated as confidential for tactical

2 reasons and that nothing be so designated without a good faith belief that it has been

3 maintained in a confidential, non-public manner, and there is good cause why it should

4 not be part of the public record of this case.

5 2. DEFINITIONS

6 2.1 Action: Khloii Hollis vs. City of Los Angeles, et al. (Case No. 2:25-cv-

7 06319-SK).

8 2.2 Challenging Party: a Party or Non-Party that challenges the designation

9 of information or items under this Order.

10 2.3 “CONFIDENTIAL” Information or Items: information (regardless of

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

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

13 Statement.

14 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as

15 their support staff).

16 2.5 Designating Party: a Party or Non-Party that designates information or

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

18 “CONFIDENTIAL.”

19 2.6 Disclosure or Discovery Material: all items or information, regardless of

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

21 other things, testimony, transcripts, and tangible things), that are produced or generated

22 in disclosures or responses to discovery in this matter.

23 2.7 Expert: a person with specialized knowledge or experience in a matter

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

25 expert witness or as a consultant in this Action.

26 2.8 House Counsel: attorneys who are employees of a party to this Action.

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

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

2 2.10 Outside Counsel of Record: attorneys who are not employees of a party

3 to this Action but are retained to represent or advise a party to this Action and have

4 appeared in this Action on behalf of that party or are affiliated with a law firm which

5 has appeared on behalf of that party, including support staff.

6 2.11 Party: any party to this Action, including all of its officers, directors,

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

8 support staffs).

9 2.12 Producing Party: a Party or Non-Party that produces Disclosure or

10 Discovery Material in this Action.

11 2.13 Professional Vendors: persons or entities that provide litigation support

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

13 demonstrations, and organizing, storing, or retrieving data in any form or medium) and

14 their employees and subcontractors.

15 2.14 Protected Material: any Disclosure or Discovery Material that is

16 designated as “CONFIDENTIAL.”

17 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material

18 from a Producing Party.

19 3. SCOPE

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

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

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

23 Material; and (3) any testimony, conversations, or presentations by Parties or their

24 Counsel that might reveal Protected Material.

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

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

27 4. DURATION

1 members of the public, including the press, once it becomes part of the judicial record,

2 either as part of a dispositive filing and/or once a case proceeds to trial, unless

3 compelling reasons supported by specific factual findings to proceed otherwise are

4 made to the trial judge in advance of the trial or pursuant to an application for filing

5 under seal as pertains to dispositive motions. See Kamakana v. City and County of

6 Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing “good cause”

7 showing for sealing documents produced in discovery from “compelling reasons”

8 standard when merits-related documents are part of court record). Accordingly, the

9 terms of this protective order do not extend beyond the commencement of the trial.

10 5. DESIGNATING PROTECTED MATERIAL

11 5.1 Exercise of Restraint and Care in Designating Material for Protection.

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

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

14 under the appropriate standards. The Designating Party must designate for protection

15 only those parts of material, documents, items, or oral or written communications that

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

17 which protection is not warranted are not swept unjustifiably within the ambit of this

18 Order.

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

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

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

22 unnecessary expenses and burdens on other parties) may expose the Designating Party

23 to sanctions.

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

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

26 promptly notify all other Parties that it is withdrawing the inapplicable designation.

27 5.2 Manner and Timing of Designations. Except as otherwise provided in

1 under this Order must be clearly so designated before the material is disclosed or

2 produced.

3 Designation in conformity with this Order requires:

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

5 documents, but excluding transcripts of depositions or other pretrial

6 or trial proceedings), that the Producing Party affix at a minimum,

7 the legend “CONFIDENTIAL” (hereinafter “CONFIDENTIAL

8 legend”), to each page that contains protected material. If only a

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

10 the Producing Party also must clearly identify the protected

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

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

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

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

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

16 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants

17 copied and produced, the Producing Party must determine which documents, or portions

18 thereof, qualify for protection under this Order. Then, before producing the specified

19 documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page

20 that 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 protected

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

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

24 identify the Disclosure or Discovery Material on the record, before

25 the close of the deposition all protected testimony.

26 (c) for information produced in some form other than documentary and

27 for any other tangible items, that the Producing Party affix in a

1 only a portion or portions of the information warrants protection, the

2 Producing Party, to the extent practicable, shall identify the

3 protected portion(s).

4 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent

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

6 Designating Party’s right to secure protection under this Order for such material. Upon

7 timely correction of a designation, the Receiving Party must make reasonable efforts to

8 assure that the material is treated in accordance with the provisions of this Order.

9 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

10 6.1 Timing of Challenges. Any Party or Non-Party may challenge a

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

12 Scheduling Order.

13 6.2 Meet and Confer. The Challenging Party Shall initiate the dispute

14 resolution process under Civil Local Rule 37-1 et seq.

15 6.3 The burden of persuasion in any such challenge proceeding shall be on

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

17 (e.g., to harass or impose unnecessary expenses and burdens on other parties), may

18 expose the Challenging Party to sanctions. Unless the Designating Party has waived or

19 withdrawn the confidentiality designation, all parties shall continue to afford the

20 material in question the level of protection to which it is entitled under the

21 Producing Party’s designation until the Court rules on the challenge.

22 7. ACCESS TO AND USE OF PROTECTED MATERIAL

23 7.1 Basic Principles. A Receiving Party may use Protected Material that is

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

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

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

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

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

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

3 authorized under this Order.

4 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless

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

6 Receiving Party may disclose any information or item designated “CONFIDENTIAL”

7 only to:

8 (a) the Parties to this Action;

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

10 well as employees of said Outside Counsel of Record to whom it is

11 reasonably necessary to disclose the information for this Action;

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

13 the Receiving Party to whom disclosure is reasonably necessary for

14 this Action;

15 (d) Experts (as defined in this Order) of the Receiving Party to whom

16 disclosure is reasonably necessary for this Action and who have

17 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit

18 A);

19 (e) the Court and its personnel;

20 (f) court reporters and their staff;

21 (g) professional jury or trial consultants, mock jurors, and Professional

22 Vendors to whom disclosure is reasonably necessary for this Action

23 and who have signed the “Acknowledgment and Agreement to Be

24 Bound” (Exhibit A);

25 (h) the author or recipient of a document containing the information or a

26 custodian or other person who otherwise possessed or knew the

27 information;

1 the deposing party requests that the witness sign the form attached as

2 Exhibit A hereto; and (2) they will not be permitted to keep any

3 confidential information unless they sign the “Acknowledgment and

4 Agreement to Be Bound” (Exhibit A), unless otherwise agreed by

5 the Designating Party or ordered by the Court. Pages of transcribed

6 deposition testimony or exhibits to depositions that reveal Protected

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

8 be disclosed to anyone except as permitted under this Stipulated

9 Protective Order; and

10 (j) any mediator or settlement officer, and their supporting personnel,

11 mutually agreed upon by any of the parties engaged in settlement

12 discussions.

13 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN

14 OTHER LITIGATION

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

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

17 “CONFIDENTIAL,” that Party must:

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

19 shall include a copy of the subpoena or court order;

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

21 order to issue in the other litigation that some or all of the material

22 covered by the subpoena or order is subject to this Protective Order.

23 Such notification shall include a copy of this Stipulated Protective

24 Order; and

25 (c) cooperate with respect to all reasonable procedures sought to be

26 pursued by the Designating Party whose Protected Material may be

27 affected.

1 “CONFIDENTIAL” before a determination by the court from which the subpoena or

2 order issued, unless the Party has obtained the Designating Party’s permission. The

3 Designating Party shall bear the burden and expense of seeking protection in that court

4 of its confidential material, and nothing in these provisions should be construed as

5 authorizing or encouraging a Receiving Party in this Action to disobey a lawful

6 directive from another court.

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

8 IN THIS LITIGATION

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

10 Non-Party in this Action and designated as “CONFIDENTIAL.”

11 Such information produced by Non-Parties in connection with this

12 litigation is protected by the remedies and relief provided by this

13 Order. Nothing in these provisions should be construed as

14 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,

17 and the Party is subject to an agreement with the Non-Party not to

18 produce the Non-Party’s confidential information, then the Party

19 shall:

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

21 Party that some or all of the information requested is subject

22 to a confidentiality agreement with a Non-Party;

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

24 Protective Order in this Action, the relevant discovery

25 request(s), and a reasonably specific description of the

26 information requested; and

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

1 within 14 days of receiving the notice and accompanying

2 information, the Receiving Party may produce the Non-Party’s

3 confidential information responsive to the discovery request. If the

4 Non-Party timely seeks a protective order, the Receiving Party shall

5 not produce any information in its possession or control that is

6 subject to the confidentiality agreement with the Non-Party before a

7 determination by the Court. Absent a court order to the contrary, the

8 Non-Party shall bear the burden and expense of seeking protection

9 in this Court of its Protected Material.

10 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

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

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

14 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve

15 all unauthorized copies of the Protected Material, (c) inform the person or persons to

16 whom unauthorized disclosures were made of all the terms of this Order, and (d)

17 request such person or persons to execute the “Acknowledgment and Agreement to Be

18 Bound” that is attached hereto as Exhibit A.

19 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

20 PROTECTED MATERIAL

21 When a Producing Party gives notice to Receiving Parties that certain

22 inadvertently produced material is subject to a claim of privilege or other protection, the

23 obligations of the Receiving Parties are those set forth in Federal Rule of Civil

24 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure

25 may be established in an e-discovery order that provides for production without prior

26 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the

27 parties reach an agreement on the effect of disclosure of a communication or

1 the Court.

2 12. MISCELLANEOUS

3 12.1 Right to Relief. Nothing in this Order abridges the right of any person to

4 seek its modification by the Court in the future.

5 12.2 Right to Assert Other Objections. By stipulating to the entry of this

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

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

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

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

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

13 Protected Material at issue. If a Party’s request to file Protected Material under seal is

14 denied by the court, then the Receiving Party may file the information in the public

15 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 applications

21 for extension of time pursuant to applicable law. After the final disposition of this

22 Action, within 60 days of a written request by the Designating Party, each Receiving

23 Party must return all Protected Material to the Producing Party or destroy such material.

24 As used in this subdivision, “all Protected Material” includes all copies, abstracts,

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

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

27 Receiving Party must submit a written certification to the Producing Party (and, if not

1 or destroyed; and (2) affirms that the Receiving Party has not retained any copies,

2 abstracts, compilations, summaries, or any other format reproducing or capturing any of

3 the Protected Material. Notwithstanding this provision, Counsel are entitled to retain an

4 archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts,

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

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

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

8 Material remain subject to this Protective Order as set forth in Section 4 (DURATION).

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14. Any violation of this Order may be punished by any and all appropriate

1 |lmeasures including, without limitation, contempt proceedings and/or monetary

2 || sanctions.

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4 ||IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

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6 ||/DATED: _ 01/27/2026 LAW OFFICES OF MELANIE PARTOW

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8 By: __/s/ Melanie T. Partow

9 Melanie T. Partow

Attorneys for Plaintiff

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12 Dated: January 27, 2026 HYDEE FELDSTEIN SOTO, City Attorney

13 DENISE C. MILLS, Chief Deputy City Attorney

KATHLEEN KENEALY, Chief Assistant City Attorne

14 CHRISTIAN BOJORQUEZ, Deputy City Attorney

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SASHA O. LAZAREVICH, Deputy City Attorney

17 Attorneys for Defendant, CITY OF LOS ANGELES

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209 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

97 || DATED:__January 28, 2026

73 HONORABLE STEVE KIM

UNITED STATES MAGISTRATE JUDGE

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1 EXHIBIT A

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

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I, _____________________________ [print or type full name], of

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_________________ [print or type full address], declare under penalty of perjury that I

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have read in its entirety and understand the Stipulated Protective Order that was issued

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

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case of Kloii Hollis v. City of Los Angeles, et al. (Case No. 2:25-cv-06319-SK).. I

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

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

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sanctions and punishment in the nature of contempt. I solemnly promise that I will not

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disclose in any manner any information or item that is subject to this Stipulated

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Protective Order to any person or entity except in strict compliance with the provisions

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of this Order.

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

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

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Stipulated Protective Order, even if such enforcement proceedings occur after

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termination of this action. I hereby appoint __________________________ [print or

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type full name] of _______________________________________ [print or type full

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address and telephone number] as my California agent for service of process in

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connection with this action or any proceedings related to enforcement of this Stipulated

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Protective Order.

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Date: ______________________________________

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City and State where sworn and signed: _________________________________

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Printed name: _______________________________

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Signature: __________________________________