a party’s privacy rights are to 11 be protected through a “carefully crafted protective order.”
How later courts described this case
- a party’s privacy rights are to 11 be protected through a “carefully crafted protective order.”
- even stipulated protective orders require good cause showing
Written by the judges who cited it.
The opinion
1 PAUL B. BEACH, State Bar No. 166265
pbeach@lbaclaw.com
2 JAMES S. EICHER, JR., State Bar No. 213796
jeicher@lbaclaw.com
3 ROCCO ZAMBITO, JR., State Bar No. 306115
rzambito@lbaclaw.com
4 LAWRENCE BEACH ALLEN & CHOI, PC
150 South Los Robles Avenue, Suite 660
5 Pasadena, California 91101
Telephone No. (818) 545-1925
6
Attorneys for Defendants
7 County of Ventura and Ventura County Sheriff’s Office (erroneously sued and
served as Ventura County and Ventura County Sheriff’s Department)
8
9 UNITED STATES DISTRICT COURT
10 CENTRAL DISTRICT OF CALIFORNIA
11
12 JAMES MEDINA, an individual, ) Case No. 2:25-cv-06274-SVW-SSC
)
13 Plaintiffs, ) Magistrate Judge Stephanie S.
) Christensen
14 vs. )
)
15 VENTURA COUNTY SHERIFF'S )
DEPARTMENT, a public entity; ) STIPULATED PROTECTIVE
16 VENTURA COUNTY; a public entity; ) ORDER1
DOES 1-10, individuals, )
17 )
Defendants. )
18 ) Complaint filed: July 9, 2025
)
19 )
20
21 1. INTRODUCTION
22 1.1 Purposes and Limitations. Discovery in this action is likely to
23 involve production of confidential, proprietary, or private information for which
24 special protection from public disclosure and from use for any purpose other than
25 prosecuting this litigation may be warranted. Accordingly, the parties hereby
26
27 1 This Stipulated Protective Order is substantially based on the model protective
28 order provided under Magistrate Judge Stephanie S. Christensen’s Procedures as
1 stipulate to and petition the court to enter the following Stipulated Protective
2 Order. The parties acknowledge that this Order does not confer blanket
3 protections on all disclosures or responses to discovery and that the protection it
4 affords from public disclosure and use extends only to the limited information or
5 items that are entitled to confidential treatment under the applicable legal
6 principles.
7 1.2 Good Cause Statement. The parties may produce certain documents,
8 items, materials, law enforcement information, medical records, personnel
9 information, and other information in this case that may contain sensitive and
10 confidential information that derives actual or potential value from not being
11
generally known to the public, are the subject of reasonable efforts to maintain
12
their confidentiality, and for which special protection from public disclosure and
13
from use for any purpose other than prosecution of this action is warranted. Such
14
records include materials relating to the investigation of the incident at issue,
15
material relating to or regarding the personnel files and/or records of County of
16
Ventura employees, medical records, photographs, material, and information
17
relating to incidents involving Plaintiff containing sensitive or private
18
information, including regarding third parties, County of Ventura Wellpath
19
policies, procedures, manuals, and/or training materials which are not publicly
20
available, Internal Affairs materials and information, sensitive and private
21
22 information regarding third parties, and other video recordings, photographs,
23 audio recordings, materials and information generally unavailable to the public or
24 which may be privileged or otherwise protected from disclosure under state or
25 federal statutes, court rules, case decisions, or common law, and any other
26 materials and information the parties agree believe need special attention from
27 public disclosure and from use for any purpose other than prosecuting this
28 litigation. This action is also expected to include the use of sensitive information
1 and recordings relating to Plaintiff’s physical health, mental health, substance use,
2 and treatment, as well as criminal records involving Plaintiff. Such materials and
3 information may implicate the privacy interests of the parties and are properly
4 protected through a Fed. R. Civ. P. 26(c) protective order. Seattle Times Co. v.
5
Rhinehart, 467 U.S. 20, 35 n.21 (1984) (“Rule 26(c) includes among its express
6
purposes the protection of a ‘party or person from annoyance, embarrassment,
7
oppression or undue burden or expense.’ Although the Rule contains no specific
8
reference to privacy or to other rights or interests that may be implicated, such
9
matters are implicit in the broad purpose and language of the Rule.”); Soto v. City
10
of Concord, 162 F.R.D. 603, 617 (N.D. Cal. 1995) (a party’s privacy rights are to
11
be protected through a “carefully crafted protective order.”).
12
Furthermore, Plaintiff is seeking and Defendants may produce, among
13
other things, internal, security sensitive, third party and law enforcement private
14
and confidential information, administrative, personnel and institutional
15
16 documents, which contain sensitive information that Defendants believe need
17 special protection from public disclosure.
18 Defendants contend that the documents identified in this Protective Order,
19 which Defendants believe in good faith constitute or embody confidential
20 information which Defendants maintain as strictly confidential and are otherwise
21 generally unavailable to the public, or which may be privileged or otherwise
22 protected from disclosure under state or federal statutes, court rules, case
23 decisions, or common law, are therefore entitled to heightened protection from
24
disclosure.
25
Defendants further contend that such confidential materials and
26
information consist of, among other things, documents and/or writings protected
27
by the Official Information Privilege, the right to privacy guaranteed by in the
28
Federal Constitution, First Amendment, California Constitution, Article I, Section
1 I, and various California Government, Penal, and Evidence Code section, as well
2 as information otherwise generally unavailable to the public, or which may be
3 privileged or otherwise protected from disclosure under state or federal statutes,
4 court rules, case decisions, or common law.
5
Accordingly, to expedite the flow of information, to facilitate the prompt
6
resolution of disputes over confidentiality of discovery materials, to adequately
7
protect information the parties are entitled to keep confidential, to ensure that the
8
parties are permitted reasonable necessary uses of such material in preparation for
9
and in the conduct of trial, to address their handling at the end of the litigation,
10
and serve the ends of justice, a protective order for such information is justified in
11
this matter. It is the intent of the parties that information will not be designated as
12
confidential for tactical reasons and that nothing be so designated without a good
13
faith belief that it has been maintained in a confidential, non-public manner, and
14
there is good cause why it should not be part of the public record of this case.
15
16 1.3 Acknowledgment of Procedure for Filing Under Seal. The parties
17 further acknowledge, as set forth in Section 12.3, below, that this Stipulated
18 Protective Order does not entitle them to file confidential information under seal;
19 Local Rule 79-5 sets forth the procedures that must be followed and the standards
20 that will be applied when a party seeks permission from the court to file material
21 under seal.
22 There is a strong presumption that the public has a right of access to
23 judicial proceedings and records in civil cases. In connection with non-
24
dispositive motions, good cause must be shown to support a filing under seal. See
25
Kamakana v. City and Cnty. of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006),
26
Phillips ex rel. Ests. of Byrd v. Gen. Motors Corp., 307 F.3d 1206, 1210–11 (9th
27
Cir. 2002), Makar-Welbon v. Sony Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis.
28
1999) (even stipulated protective orders require good cause showing), and a
1 specific showing of good cause or compelling reasons with proper evidentiary
2 support and legal justification, must be made with respect to Protected Material
3 that a party seeks to file under seal. The parties’ mere designation of Disclosure
4 or Discovery Material as CONFIDENTIAL does not—without the submission of
5
competent evidence by declaration, establishing that the material sought to be
6
filed under seal qualifies as confidential, privileged, or otherwise protectable—
7
constitute good cause.
8
Further, if a party requests sealing related to a dispositive motion or trial,
9
then compelling reasons, not only good cause, for the sealing must be shown, and
10
the relief sought shall be narrowly tailored to serve the specific interest to be
11
protected. See Pintos v. Pac. Creditors Ass’n, 605 F.3d 665, 677–79 (9th Cir.
12
2010). For each item or type of information, document, or thing sought to be
13
filed or introduced under seal in connection with a dispositive motion or trial, the
14
party seeking protection must articulate compelling reasons, supported by specific
15
16 facts and legal justification, for the requested sealing order. Again, competent
17 evidence supporting the application to file documents under seal must be
18 provided by declaration.
19 Any document that is not confidential, privileged, or otherwise protectable
20 in its entirety will not be filed under seal if the confidential portions can be
21 redacted. If documents can be redacted, then a redacted version for public
22 viewing, omitting only the confidential, privileged, or otherwise protectable
23 portions of the document, shall be filed. Any application that seeks to file
24
documents under seal in their entirety should include an explanation of why
25
redaction is not feasible.
26
27
28
1 2. DEFINITIONS
2 2.1 Action: James Medina v. Ventura County Sheriff’s Department, et
3 al., 2:25-cv-06274-SVW-SSC.
4 2.2 Challenging Party: a Party or Non-Party that challenges the
5
designation of information or items under this Order.
6
2.3 “CONFIDENTIAL” Information or Items: information (regardless of
7
how it is generated, stored or maintained) or tangible things that qualify for
8
protection under Rule 26(c) of the Federal Rules of Civil Procedure, and as
9
specified above in the Good Cause Statement.
10
2.4 Counsel: Outside Counsel of Record and House Counsel (as well as
11
their support staff).
12
2.5 Designating Party: a Party or Non-Party that designates information
13
or items that it produces in disclosures or in responses to discovery as
14
“CONFIDENTIAL.”
15
16 2.6 Disclosure or Discovery Material: all items or information,
17 regardless of the medium or manner in which it is generated, stored, or
18 maintained (including, among other things, testimony, transcripts, and tangible
19 things), that are produced or generated in disclosures or responses to discovery in
20 this matter.
21 2.7 Expert: a person with specialized knowledge or experience in a
22 matter pertinent to the litigation who has been retained by a Party or its counsel to
23 serve as an expert witness or as a consultant in this Action.
24 2.8 Final Disposition: the later of (1) dismissal of all claims and
25
defenses in this Action, with or without prejudice; and (2) final judgment herein
26
after the completion and exhaustion of all appeals, rehearings, remands, trials, or
27
reviews of this Action, including the time limits for filing any motions or
28
applications for extension of time pursuant to applicable law.
1 2.9 In-House Counsel: attorneys who are employees of a party to this
2 Action. In-House Counsel does not include Outside Counsel of Record or any
3 other outside counsel.
4 2.10 Non-Party: any natural person, partnership, corporation, association,
5
or other legal entity not named as a Party to this action.
6
2.11 Outside Counsel of Record: attorneys who are not employees of a
7
party to this Action but are retained to represent or advise a party to this Action
8
and have appeared in this Action on behalf of that party or are affiliated with a
9
law firm which has appeared on behalf of that party, and includes support staff.
10
2.12 Party: any party to this Action, including all of its officers, directors,
11
employees, consultants, retained experts, and Outside Counsel of Record (and
12
their support staffs).
13
2.13 Producing Party: a Party or Non-Party that produces Disclosure or
14
Discovery Material in this Action.
15
16 2.14 Professional Vendors: persons or entities that provide litigation-
17 support services (e.g., photocopying, videotaping, translating, preparing exhibits
18 or demonstrations, and organizing, storing, or retrieving data in any form or
19 medium) and their employees and subcontractors.
20 2.15 Protected Material: any Disclosure or Discovery Material that is
21 designated as “CONFIDENTIAL.”
22 2.16 Receiving Party: a Party that receives Disclosure or Discovery
23 Material from a Producing Party.
24
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 Stipulated Protective Order does not govern the use of Protected
5
Material at trial.
6
7
4. TRIAL AND DURATION
8
Once a case proceeds to trial, all of the court-filed information to be
9
introduced that was previously designated as confidential or maintained pursuant
10
to this protective order becomes public and will be presumptively available to all
11
members of the public, including the press, unless compelling reasons supported
12
by specific factual findings to proceed otherwise are made to the trial judge in
13
advance of the trial. See Kamakana v. City and Cty. of Honolulu, 447 F.3d 1172,
14
1180-81 (9th Cir. 2006) (distinguishing “good cause” showing for sealing
15
16 documents produced in discovery from “compelling reasons” standard when
17 merits-related documents are part of court record). Even after final disposition of
18 this litigation, the confidentiality obligations imposed by this Order shall remain
19 in effect as to materials which do not become part of the court record, until a
20 Designating Party agrees otherwise in writing or a court order otherwise directs.
21
22 5. DESIGNATING PROTECTED MATERIAL
23 5.1 Exercise of Restraint and Care in Designating Material for
24
Protection. Each Party or Non-Party that designates information or items for
25
protection under this Order must take care to limit any such designation to
26
specific material that qualifies under the appropriate standards. The Designating
27
Party must designate for protection only those parts of material, documents,
28
items, or oral or written communications that qualify so that other portions of the
1 material, documents, items, or communications for which protection is not
2 warranted are not swept unjustifiably within the ambit of this Order.
3 Mass, indiscriminate, or routinized designations are prohibited.
4 Designations that are shown to be clearly unjustified or that have been made for
5
an improper purpose (e.g., to unnecessarily encumber the case development
6
process or to impose unnecessary expenses and burdens on other parties) may
7
expose the Designating Party to sanctions.
8
If it comes to a Designating Party’s attention that information or items that
9
it designated for protection do not qualify for protection, that Designating Party
10
must promptly notify all other Parties that it is withdrawing the inapplicable
11
designation.
12
5.2 Manner and Timing of Designations. Except as otherwise provided
13
in this Stipulated Protective Order (see, e.g., second paragraph of section 5.2(a)
14
below), or as otherwise stipulated or ordered, Disclosure or Discovery Material
15
16 that qualifies for protection under this Stipulated Protective Order must be clearly
17 so designated before the material is disclosed or produced.
18 Designation in conformity with this Stipulated Protective Order requires:
19 (a) for information in documentary form (e.g., paper or electronic
20 documents, but excluding transcripts of depositions or other pretrial or trial
21 proceedings), that the Producing Party affix at a minimum, the legend
22 “CONFIDENTIAL” to each page that contains protected material. If only a
23 portion or portions of the material on a page qualifies for protection, the
24
Producing Party also must clearly identify the protected portion(s) (e.g., by
25
making appropriate markings in the margins).
26
A Party or Non-Party that makes original documents available for
27
inspection need not designate them for protection until after the inspecting Party
28
has indicated which documents it would like copied and produced. During the
1 inspection and before the designation, all of the material made available for
2 inspection shall be deemed CONFIDENTIAL. After the inspecting Party has
3 identified the documents it wants copied and produced, the Producing Party must
4 determine which documents, or portions thereof, qualify for protection under this
5
Stipulated Protective Order. Then, before producing the specified documents, the
6
Producing Party must affix the “CONFIDENTIAL” legend to each page that
7
contains Protected Material. If only a portion or portions of the material on a
8
page qualifies for protection, the Producing Party also must clearly identify the
9
protected portion(s) (e.g., by making appropriate markings in the margins).
10
(b) for testimony given in depositions that the Designating Party identify
11
the Disclosure or Discovery Material on the record, before the close of the
12
deposition all protected testimony.
13
(c) for information produced in some form other than documentary and
14
for any other tangible items, that the Producing Party affix in a prominent place
15
16 on the exterior of the container or containers in which the information is stored
17 the “CONFIDENTIAL” legend. If only a portion or portions of the information
18 warrants protection, the Producing Party, to the extent practicable, shall identify
19 the protected portion(s).
20 (d) in the case of depositions, Designating Party may designate all or
21 any portion of the deposition testimony given regarding the Confidential
22 Information in this litigation as Confidential Information orally during the
23 deposition. Any questions intended to elicit testimony regarding the contents of
24
the Confidential Information shall be conducted only in the presence of persons
25
authorized to review the Confidential Information as provided in this Order. Any
26
deposition transcript containing such questions and testimony shall be subject to
27
the same protections and precautions applicable to the Confidential Information.
28
1 5.3 Inadvertent Failures to Designate. If timely corrected, an
2 inadvertent failure to designate qualified information or items does not, standing
3 alone, waive the Designating Party’s right to secure protection under this Order
4 for such material. Upon timely correction of a designation, the Receiving Party
5
must make reasonable efforts to assure that the material is treated in accordance
6
with the provisions of this Stipulated Protective Order.
7
8
6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
9
6.1 Timing of Challenges. Any Party or Non-Party may challenge a
10
designation of confidentiality at any time that is consistent with the court’s
11
Scheduling Order.
12
6.2 Meet and Confer. The Challenging Party shall initiate the dispute
13
resolution process under Local Rule 37.1 et seq. and with Section 2 of Judge
14
Christensen’s Civil Procedures titled “Brief Pre-Discovery Motion Conference.”2
15
16 6.3 The burden of persuasion in any such challenge proceeding shall be
17 on the Designating Party. Frivolous challenges, and those made for an improper
18 purpose (e.g., to harass or impose unnecessary expenses and burdens on other
19 parties) may expose the Challenging Party to sanctions. Unless the Designating
20 Party has waived or withdrawn the confidentiality designation, all parties shall
21 continue to afford the material in question the level of protection to which it is
22 entitled under the Producing Party’s designation until the court rules on the
23 challenge.
24
25
//
26
27
28
2 Judge Christensen’s Procedures are available at
1 7. ACCESS TO AND USE OF PROTECTED MATERIAL
2 7.1 Basic Principles. A Receiving Party may use Protected Material that
3 is disclosed or produced by another Party or by a Non-Party in connection with
4 this Action only for prosecuting, defending, or attempting to settle this Action.
5
Such Protected Material may be disclosed only to the categories of persons and
6
under the conditions described in this Order. When the Action reaches a Final
7
Disposition, a Receiving Party must comply with the provisions of section 13
8
below.
9
Protected Material must be stored and maintained by a Receiving Party at a
10
location and in a secure manner that ensures that access is limited to the persons
11
authorized under this Stipulated Protective Order.
12
7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
13
otherwise ordered by the court or permitted in writing by the Designating Party, a
14
Receiving Party may disclose any information or item designated
15
16 “CONFIDENTIAL” only:
17 (a) to the Receiving Party’s Outside Counsel of Record in this Action,
18 as 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) to the officers, directors, and employees (including House Counsel)
21 of the Receiving Party to whom disclosure is reasonably necessary for this
22 Action;
23 (c) to Experts (as defined in this Order) of the Receiving Party to whom
24
disclosure is reasonably necessary for this Action and who have signed the
25
“Acknowledgment and Agreement to Be Bound” (Exhibit A);
26
(d) to the court and its personnel;
27
(e) to court reporters and their staff;
28
1 (f) to professional jury or trial consultants, mock jurors, and
2 Professional Vendors to whom disclosure is reasonably necessary for this Action
3 and who have signed the “Acknowledgment and Agreement to Be Bound”
4 (Exhibit A);
5
(g) to the author or recipient of a document containing the information
6
or a custodian or other person who otherwise possessed or knew the information;
7
(h) during their depositions, to witnesses, and attorneys for witnesses, in
8
the Action to whom disclosure is reasonably necessary, provided: (1) the
9
deposing party requests that the witness sign the “Acknowledgment and
10
Agreement to Be Bound” (Exhibit A); and (2) the witness will not be permitted to
11
keep any confidential information unless they sign the “Acknowledgment and
12
Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating
13
Party or ordered by the court. Pages of transcribed deposition testimony or
14
exhibits to depositions that reveal Protected Material may be separately bound by
15
16 the court reporter and may not be disclosed to anyone except as permitted under
17 this Stipulated Protective Order; and
18 (i) to any mediator or settlement officer, and their supporting personnel,
19 mutually agreed upon by any of the parties engaged in settlement discussions.
20
21 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
22 PRODUCED IN OTHER LITIGATION
23 If a Party is served with a subpoena or a court order issued in other
24
litigation that compels disclosure of any information or items designated in this
25
Action as “CONFIDENTIAL,” that Party must:
26
(a) promptly notify in writing the Designating Party. Such notification
27
shall include a copy of the subpoena or court order;
28
1 (b) promptly notify in writing the party who caused the subpoena or
2 order to issue in the other litigation that some or all of the material covered by the
3 subpoena or order is subject to this Protective Order. Such notification shall
4 include a copy of this Stipulated Protective Order; and
5
(c) cooperate with respect to all reasonable procedures sought to be
6
pursued by the Designating Party whose Protected Material may be affected.
7
If the Designating Party timely seeks a protective order, the Party served
8
with the subpoena or court order shall not produce any information designated in
9
this action as “CONFIDENTIAL” before a determination by the court from which
10
the subpoena or order issued, unless the Party has obtained the Designating
11
Party’s permission. The Designating Party shall bear the burden and expense of
12
seeking protection in that court of its confidential material and nothing in these
13
provisions should be construed as authorizing or encouraging a Receiving Party
14
in this Action to disobey a lawful directive from another court.
15
16
17 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
18 PRODUCED IN THIS LITIGATION
19 9.1 Application. The terms of this Stipulated Protective Order are
20 applicable to information produced by a Non-Party in this Action and designated
21 as “CONFIDENTIAL.” Such information produced by Non-Parties in
22 connection with this litigation is protected by the remedies and relief provided by
23 this Order. Nothing in these provisions should be construed as prohibiting a Non-
24
Party from seeking additional protections.
25
9.2 Notification. In the event that a Party is required, by a valid
26
discovery request, to produce a Non-Party’s confidential information in its
27
possession, and the Party is subject to an agreement with the Non-Party not to
28
produce the Non-Party’s confidential information, then the Party shall:
1 (a) 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 (b) make the information requested available for inspection by the Non-
5
Party, if requested.
6
9.3 Conditions of Production. If the Non-Party fails to seek a protective
7
order from this court within 14 days of receiving the notice and accompanying
8
information, the Receiving Party may produce the Non-Party’s confidential
9
information responsive to the discovery request. If the Non-Party timely seeks a
10
protective order, the Receiving Party shall not produce any information in its
11
possession or control that is subject to the confidentiality agreement with the
12
Non-Party before a determination by the court. Absent a court order to the
13
contrary, the Non-Party shall bear the burden and expense of seeking protection
14
in this court of its Protected Material.
15
16
17 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
18 If a Receiving Party learns that, by inadvertence or otherwise, it has
19 disclosed Protected Material to any person or in any circumstance not authorized
20 under this Stipulated Protective Order, the Receiving Party must immediately (a)
21 notify in writing the Designating Party of the unauthorized disclosures, (b) use its
22 best efforts to retrieve all unauthorized copies of the Protected Material, (c)
23 inform the person or persons to whom unauthorized disclosures were made of all
24
the terms of this Order, and (d) request such person or persons to execute the
25
“Acknowledgment and Agreement to Be Bound” (Exhibit A).
26
27
28
1 11. INADVERTENT PRODUCTION OF PRIVILEGED OR
2 OTHERWISE PROTECTED MATERIAL
3 When a Producing Party gives notice to Receiving Parties that certain
4 inadvertently produced material is subject to a claim of privilege or other
5
protection, the obligations of the Receiving Parties are those set forth in Rule
6
26(b)(5)(B) of the Federal Rules of Civil Procedure. This provision is not
7
intended to modify whatever procedure may be established in an e-discovery
8
order that provides for production without prior privilege review. Pursuant to
9
Rules 502(d) and (e) of the Federal Rules of Evidence, insofar as the parties reach
10
an agreement on the effect of disclosure of a communication or information
11
covered by the attorney-client privilege or work product protection, the parties
12
may incorporate their agreement in the stipulated protective order submitted to
13
the court.
14
15
16 12. MISCELLANEOUS
17 12.1 Right to Further Relief. Nothing in this Stipulated Protective Order
18 abridges the right of any person to seek its modification by the court in the future.
19 12.2 Right to Assert Other Objections. By stipulating to the entry of this
20 Stipulated Protective Order no Party waives any right it otherwise would have to
21 object to disclosing or producing any information or item on any ground not
22 addressed in this Stipulated Protective Order. Similarly, no Party waives any
23 right to object on any ground to use in evidence of any of the material covered by
24
this Stipulated Protective Order.
25
12.3 Filing Protected Material. A Party that seeks to file under seal any
26
Protected Material must comply with Local Rule 79-5. Protected Material may
27
only be filed under seal pursuant to a court order authorizing the sealing of the
28
specific Protected Material at issue. If a Party's request to file Protected Material
1 under seal is denied by the court, then the Receiving Party may file the
2 information in the public record unless otherwise instructed by the court.
3
4 13. FINAL DISPOSITION
5
After the Final Disposition of this Action, as defined in paragraph 4, within
6
60 days of a written request by the Designating Party, each Receiving Party must
7
return all Protected Material to the Producing Party or destroy such material. As
8
used in this subdivision, “all Protected Material” includes all copies, abstracts,
9
compilations, summaries, and any other format reproducing or capturing any of
10
the Protected Material. Whether the Protected Material is returned or destroyed,
11
the Receiving Party must submit a written certification to the Producing Party
12
(and, if not the same person or entity, to the Designating Party) by the 60 day
13
deadline that (1) identifies (by category, where appropriate) all the Protected
14
Material that was returned or destroyed and (2) affirms that the Receiving Party
15
16 has not retained any copies, abstracts, compilations, summaries or any other
17 format reproducing or capturing any of the Protected Material. Notwithstanding
18 this provision, Counsel is entitled to retain an archival copy of all pleadings,
19 motion papers, trial, deposition, and hearing transcripts, legal memoranda,
20 correspondence, deposition and trial exhibits, expert reports, attorney work
21 product, and consultant and expert work product, even if such materials contain
22 Protected Material. Any such archival copies that contain or constitute Protected
23 Material remain subject to this Protective Order as set forth in Section 4.
24
25
14. VIOLATION
26
Any violation of this Stipulated Protective Order may be punished by any
27
and all appropriate measures including, without limitation, contempt proceedings
28
and/or monetary sanctions.
1 | IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
2
3 || Dated: January 29, 2026 LAW OFFICES OF CHRISTIAN CONTRERAS
4 A PROFESSIONAL LAW CORPORATION
> By ___/s/ Christian Contreras
6 CHRISTIAN CONTRERAS, ESQ.
Attorneys for Plaintiff
7 JAMES MEDINA
8
g || Dated: January 29, 2026 LAWRENCE BEACH ALLEN & CHOI, PC
10 By /s/ Rocco Zambito, Jr.
11 Rocco Zambito, Jr.
Attorneys for Defendants
2 County of Ventura and
Ventura County Sheriffs Office
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' | FOR GOOD CAUSE SHOWN, IT IS SO OR
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DATED: January 30, 2026
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Stephanie S. Christensen
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50 United States Magistrate Judge
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1Q
1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
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4 I, ________________________ [print or type full name], of
5 _________________ [print or type full address], declare under penalty of
6 perjury that I have read in its entirety and understand the Stipulated Protective
7 Order that was issued by the United States District Court for the Central District
8 of California on [date] in the case of James Medina v. Ventura County Sheriff’s
9 Department, et al., 2:25-cv-06274-SVW-SSC. I agree to comply with and to be
10 bound by all the terms of this Stipulated Protective Order and I understand and
11 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
13 in 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
15 this Order.
16 I further agree to submit to the jurisdiction of the United States District
17 Court for the Central District of California for the purpose of enforcing the terms
18 of this Stipulated Protective Order, even if such enforcement proceedings occur
19 after termination of this action. I hereby appoint ______________ [print or type
20 full name] of _________ [print or type full address and telephone number] as
21 my California agent for service of process in connection with this action or any
22 proceedings related to enforcement of this Stipulated Protective Order.
23 Date: ___________________________
24 City and State where sworn and
25 signed: ___________________________
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Printed name: ___________________________
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Signature: ___________________________
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