The opinion
FUJII LAW GROUP LLP
JOHN M. FUJI, SBN 172718
2| MAHADHI CORZANO, SBN 254905
MONICA PHAN, SBN 337735
3||2 Park Plaza, Suite 450
Irvine, California 92614
4|| Phone: (2 392-5501
Fax: (949) 392-5501
Email: JFuju(@FujiiLawGroup.com
Email: MCorzano@FujuLawGroup.com
6|| Email: MPhan@FuyulLawGroup.com
7|| Attorney for Defendant
COUNTY OF SAN BERNARDINO
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9 UNITED STATES DISTRICT COURT
10 CENTRAL DISTRICT OF CALIFORNIA
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12| JOSEPH ANDRE VENEGAS-ORNELAS, | CASE NO.: 5:25-cv-02037-SSS-E
13 Plaintiff, Judge: Sunshine S. Sykes.
Mag. Judge: Charles F. Eick
14 Vv.
STIPULATED PROTECTIVE
15] COUNTY OF SAN BERNARDINO ORDER
and DOES 1-10, Inclusive,
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17 Defendants. Trial Date: April 27, 2027
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PURPOSES AND LIMITATIONS
2 Defendant COUNTY OF SAN BERNARDINO (“Defendant”) contend that
3|| discovery in this action (the “Action’) is likely to involve production of confidential,
proprietary, or private information for which special protection from public disclosure
from use for any purpose other than prosecuting this litigation may be warranted.
6| Accordingly, Defendant and Plaintiff JOSEPH ANDRE VENEGAS-ORNELAS
7| (‘Plaintiff’), with Plaintiff and Defendant collectively referred to herein as the “Parties”
individually as the “Party,” hereby stipulate to and petition the Court to enter the
following Stipulated Protective Order (the “Protective Order”). The Parties acknowledge
this Protective Order does not confer blanket protections on all disclosures or
responses to discovery and that the protection it affords from public disclosure and use
12|extends only to the limited information or items that are entitled to confidential treatment
under the applicable legal principles.
GOOD CAUSE STATEMENT
15 This Action involves records of detention and investigations performed by the San
16| Bernardino County Sheriff's Department and its personnel, agents, and employees, and/or
other third parties contracted with the County. Defendant asserts that the underlying
18/incident, and evidence thereof, may involve the identity of personnel, third-party
witnesses, and others, that is private or confidential in nature. Further, Defendant
20|anticipates that Plaintiff will seek confidential documents in this matter which may
21/include, but are not limited to, personnel records of law enforcement officers,
22|}employment records, and confidential information from the San Bernardino County
23||Sheriff's Department (including potential information implicating privacy of third
parties) not generally available to the public, or which may be privileged or otherwise
protected from disclosure under state or federal statutes, court rules, case decisions, or
26}common law. Should this information (photos, videos, personnel records, private
27||information of witnesses, etc.) be disclosed without the protection of this Protective
28]|Order, and open access to the information be allowed, the privacy and safety of those
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1||involved in this Action, and other law enforcement matters, could be placed at risk.
2 Accordingly, to expedite the flow of information, facilitate the prompt resolution
of disputes over confidentiality of discovery materials, adequately protect information the
4| Parties are entitled to keep confidential, ensure the Parties are permitted reasonable and
5|| necessary uses of such material in preparation for trial and address their handling at the
6| end of the litigation, and serve the ends of justice, a protective order for such information
7\\is justified in this matter. It is the intent of the Parties that information will not be
8 | designated as “confidential” for tactical reasons and that nothing be so designated without
good faith belief that it has been maintained in a confidential, non-public manner, and
10|| there is good cause why it should not be part of the public record in this Action.
ACKNOWLEDGEMENT OF UNDER SEAL FILING PROCEDURE
12 The Parties further acknowledge, as set forth in Section 14.3, below, that this
13|| Stipulated Protective Order does not entitle them to file confidential information under
14|)seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the
standards that will be applied when a party seeks permission from the court to file material
16|under seal. There is a strong presumption that the public has a right of access to judicial
17] proceedings and records in civil cases. In connection with non-dispositive motions, good
cause must be shown to support a filing under seal. See Kamakana vy. City and County o
19|| Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors Corp., 307 F.3d
20] 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc., 187 F.R.D. 576,
(E.D. Wis. 1999) (even stipulated protective orders require good cause showing), and
specific showing of good cause or compelling reasons with proper evidentiary support
legal justification, must be made with respect to Protected Material that a party seeks
file under seal. The Parties’ mere designation of Disclosure or Discovery Material as
25 CONFIDENTIAL does not—without the submission of competent evidence by
26|declaration, establishing that the material sought to be filed under seal qualifies as
27| confidential, privileged, or otherwise protectable—constitute good cause. Further, if a
28|| party requests sealing related to a dispositive motion or trial, then compelling reasons, not
2
1|}only good cause, for the sealing must be shown, and the relief sought shall be narrowly
2|\tailored to serve the specific interest to be protected. See Pintos v. Pacific Creditors
3] Ass’n., 605 F.3d 665, 677-79 (9th Cir. 2010). For each item or type of information,
4|document, or thing sought to be filed or introduced under seal, the party seeking
protection must articulate compelling reasons, supported by specific facts and legal
justification, for the requested sealing order. Again, competent evidence supporting the
7| application to file documents under seal must be provided by declaration. Any document
8 | that is not confidential, privileged, or otherwise protectable in its entirety will not be filed
under seal if the confidential portions can be redacted. If documents can be redacted, then
redacted version for public viewing, omitting only the confidential, privileged, or
11] otherwise protectable portions of the document, shall be filed. Any application that seeks
file documents under seal in their entirety should include an explanation of why
redaction is not feasible.
DEFINITIONS
15 4.1 Action. This pending federal lawsuit entitled JOSEPH ANDRE VENEGAS-
16] ORNELAS v. COUNTY OF SAN BERNARDINO, et al. case number 5:25-cv-02037-
17] SSS-E.
18 4.2 Challenging Party. A Party or Non-Party that challenges the designation of
19] information or items under this Protective Order.
20 4.3. “CONFIDENTIAL” Information or Items. Information (regardless of how
was or is generated, stored, or maintained) or tangible things that qualify for protection
22|under Fed. R. Civ. P. 26(c), and as specified above in the Good Cause Statement above.
23 4.4 Counsel. Outside Counsel of Record and House Counsel, as these terms are
24| defined below (as well as their support staff).
25 4.5 Designating Party. A Party or Non-Party that designates information or
26|items that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.”
27 4.6 Disclosure or Discovery Material. All items or information, regardless of
medium or manner in which they are generated, stored, or maintained (including,
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1}among other things, testimony, transcripts, and tangible things) that are produced or
2|| generated in disclosures or responses to discovery in this matter.
3 4.7 Expert. A person with specialized knowledge or experience in a matter
pertinent to the litigation who has been retained by a Party or its counsel to serve as an
expert witness or as a consultant in this Action.
6 4.8 House Counsel. Attorneys who are employees of a Party to this Action.
House Counsel does not include Outside Counsel of Record or any other outside counsel.
8 4.9 Non-Party. Any natural person, partnership, corporation, association, or
9} other legal entity not named as a Party to this Action.
10 4.10 Qutside Counsel of Record. Attorneys who are not employees of a Party to
11} this Action but are retained to represent or advise a Party to this Action and have appeared
this Action on behalf of that Party or are affiliated with a law firm which has appeared
behalf of that Party, and include support staff.
14 4.11 Party. Any Party to this Action, including all of its officers, directors,
15|/employees, consultants, retained experts, and Outside Counsel of Record (and their
16|| support staff).
17 4.12 Producing Party. A Party or Non-Party that produces Disclosure or
Discovery Material in this Action.
19 4.13 Professional Vendors. Persons or entities that produce litigation support
20||services (e.g., photocopying, videotaping, translating, preparing exhibits or
demonstrations, and organizing, storing, or retrieving data in any form or medium) and
22| their employees and subcontractors.
23 4.14 Protected Material. Any Disclosure or Discovery Material that is designated
“CONFIDENTIAL.”
25 4.15 Receiving Party. A Party that receives Disclosure or Discovery Material
from a Producing Party.
2715. SCOPE
28 The protections conferred by this Stipulation and Order cover not only Protected
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1||Material (as defined above), but also (1) any information copied or extracted from
2||Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected
Material; and (3) any testimony, conversations, or presentations by Parties or their
Counsel that might reveal Protected Material. Any use of Protected Material at trial shall
governed by the orders of the trial judge and other applicable authorities. This Order
does not govern the use of Protected Material at trial.
DURATION
8 Once a case proceeds to trial, information that was designated as
CONFIDENTIAL or maintained pursuant to this protective order used or introduced as
exhibit at trial becomes public and will be presumptively available to all members of
11||the public, including the press, unless compelling reasons supported by specific factual
findings to proceed otherwise are made to the trial judge in advance of the trial. See
Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” showing for sealing
14|documents produced in discovery from “compelling reasons” standard when merits-
15||related documents are part of court record). Accordingly, the terms of this protective
order do not extend beyond the commencement of the trial.
DESIGNATING PROTECTED MATERIAL
18 7.1 Exercise of Restraint and Care in Designating Material for Protection. Each
19|'Party or Non-Party that designates information or items for protection under this
Protective Order must take care to limit any such designation to specific material that
21| qualifies under the appropriate standards. The Designating Party must designate for
22||protection only those parts of material, documents, items, or oral or written
23||communications that qualify so that other portions of the material, documents, items, or
24||communications for which protection is not warranted are not swept unjustifiably within
ambit of this Protective Order.
26 Mass, indiscriminate, or routinized designations are prohibited. Designations that
27| are shown to be clearly unjustified or that have been made for an improper purpose (e.g.,
unnecessarily encumber the case development process or to impose unnecessary
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1||expenses and burdens on other parties) may expose the Designating Party to sanctions.
2 If it comes to a Designating Party’s attention that information or items that it
3||designated for protection do not qualify for protection, that Designating Party must
4| promptly notify all other Parties that it is withdrawing the inapplicable designation.
5 7.2 Manner and Timing of Designations. Except as otherwise provided in this
6] Order, or as otherwise stipulated or ordered, Disclosure of Discovery Material that
7| qualifies for protection under this Order must be clearly so designated before the material
disclosed or produced.
9 Designation in conformity with this Order requires:
10 (a) for information in documentary form (e.g., paper or electronic
documents, but excluding transcripts of depositions or other pretrial or trial proceedings),
12| that the Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter
13|“CONFIDENTIAL legend’), to each page that contains protected material. If only a
portion of the material on a page qualifies for protection, the Producing Party also must
15||clearly identify the protected portion(s) (e.g., by making appropriate markings in the
16] margins).
17 A Party or Non-Party that makes original documents available for inspection need
designate them for protection until after the inspecting Party has indicated which
19|'documents it would like copied and produced. During the inspection and before the
20|designation, all of the material made available for inspection shall be deemed
21|“CONFIDENTIAL.” After the inspecting Party has identified the documents it wants
22||copied and produced, the Producing Party must determine which documents, or portions
thereof, qualify for protection under this Order. Then, before producing the specified
24| documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page
contains Protected Material. If only a portion of the material on a page qualifies for
26|protection, the Producing Party also must clearly identify the protected portion(s) (e.g.,
by making appropriate markings in the margins).
28 (b) for testimony given in depositions that the Designating Party identifies
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the Disclosure or Discovery Material on the record, before the close of the deposition all
2|| protected testimony.
3 (c) for information produced in some form other than documentary and for
other tangible items, that the Producing Party affix in a prominent place on the
5|exterior of the container or containers in which the information is stored the legend
6] “CONFIDENTIAL.” If only a portion or portions of the information warrants protection,
7| the Producing Party, to the extent practicable, shall identify the protected portion(s).
8 7.3. Inadvertent Failures to Designate. If timely corrected, an inadvertent failure
designate qualified information or items does not, standing alone, waive the
10] Designating Party’s right to secure protection under this Protective Order for such
11|/material. Upon timely correction of a designation, the Receiving Party must make
12||reasonable efforts to assure that the material is treated in accordance with the provisions
13] of this Protective Order.
14/8. CHALLENGING CONFIDENTIALITY DESIGNATIONS
15 8.1 Timing of Challenges. Any Party or Non-Party may challenge a designation
16| of confidentiality at any time that is consistent with the Court’s orders.
17 8.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution
18|| process under Local Rule 37.1 et seq.
19 8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a joint
stipulation pursuant to Local Rule 37-2.
21 8.4 Burden. The burden of persuasion in any such challenge proceeding shall
on the Designating Party. Frivolous challenges, and those made for an improper
23|| purpose (e.g., to harass or impose unnecessary expenses and burdens on other parties)
24|| may expose the Challenging Party to sanctions. Unless the Designating Party has waived
withdrawn the confidentiality designation, all parties shall continue to afford the
26|/material in question the level of protection to which it is entitled under the Producing
27| Party’s designation until the Court rules on the challenge.
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ACCESS TO AND USE OF PROTECTED MATERIAL
2 9.1 Basic Principles. A Receiving Party may use Protected Material that is
3} disclosed or produced by another Party or by a Non-Party in connection with this Action
only for prosecuting, defending, or attempting to settle this Action. Such Protected
5| Material may be disclosed only to the categories of persons and under the conditions
6| described in this Protective Order. When the Action has been terminated, a Receiving
7|| Party must comply with the provisions of Section 15 below (FINAL DISPOSITION).
8 Protected Material must be stored and maintained by a Receiving Party at a location
in a secure manner that ensures that access is limited only to the persons authorized
10] under this Protective Order.
11 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise
ordered by the Court or permitted in writing by the Designating Party, a Receiving Party
13|may disclose any information or item designated “CONFIDENTIAL” only to:
14 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as
15]employees of the Outside Counsel of Record to whom it is reasonably necessary to
16| disclose the information for this Action.
17 (b) the officers, directors, and employees (including House Counsel) of the
18] Receiving Party to whom disclosure is reasonably necessary for this Action;
19 (c) Experts (as defined in this Protective Order) of the Receiving Party to whom
20||disclosure is reasonably necessary for this Action and who have signed the
“Acknowledgment and Agreement to Be Bound” (Exhibit A);
22 (d) the Court and its personnel;
23 (e) court reporters and their staff;
24 (f) professional jury or trial consultants, mock jurors, and Professional Vendors
whom disclosure is reasonably necessary for this Action and who have signed the
26|)“Acknowledgment and Agreement to Be Bound” (Exhibit A);
27 (g) the author or recipient of a document containing the information or a
custodian or other person who otherwise possessed or knew the information;
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1 (h) during their depositions, witnesses, and attorneys for witnesses, in the Action
2||to whom disclosure is reasonably necessary provided: (1) the deposing party requests that
the witness sign the form attached as Exhibit A hereto; and (2) they will not be permitted
4|to keep any confidential information unless they sign the “Acknowledgment and
5| Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party
ordered by the court. Pages of transcribed deposition testimony or exhibits to
7| depositions that reveal Protected Material may be separately bound by the court reporter
may not be disclosed to anyone except as permitted under this Stipulated Protective
Order; and
10 (i) any mediator or settlement officer, and their supporting personnel, mutually
11|}agreed upon by any of the Parties engaged in settlement discussions.
PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN
13 OTHER LITIGATION
14 If a Party is served with a subpoena or a court order issued in other litigation that
15compels disclosure of any information or items designated in this Action as
“CONFIDENTIAL,” that Party must:
17 (a) promptly notify in writing the Designating Party. Such notification shall
include a copy of the subpoena or court order;
19 (b) promptly notify in writing the party who caused the subpoena or order to
20|/issue in the other litigation that some or all of the material covered by the subpoena or
order is subject to this Protective Order. Such notification shall include a copy of this
22|| Protective Order; and
23 (c) cooperate with respect to all reasonable procedures sought to be pursued by
24| the Designating Party whose Protected Material may be affected.
25 If the Designating Party timely seeks a protective order, the Party served with the
26|/subpoena or court order shall not produce any information designated in this Action as
27| “CONFIDENTIAL” before a determination by the court from which the subpoena or
order issued, unless the Party has obtained the Designating Party’s written permission.
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The Designating Party shall bear the burden and expense of seeking protection in that
2|court of its CONFIDENTIAL Information or Items, and nothing in these provisions
3||should be construed as authorizing or encouraging a Receiving Party in this Action to
4| disobey a lawful directive from another court.
S5}11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED
6 IN THIS LITIGATION
7 (a) The terms of this Order are applicable to information produced by a Non-
8 Party in this Action and designated as “CONFIDENTIAL.” Such information produced
9| by Non-Parties in connection with this litigation is protected by the remedies and relief
10|| provided by this Order. Nothing in these provisions should be construed as prohibiting a
11] Non-Party from seeking additional protections.
12 (b) Inthe event that a Party is required, by a valid discovery request, to produce
Non-Party’s confidential information in its possession, and the Party is subject to an
14||agreement with the Non-Party not to produce the Non-Party’s confidential information,
15||then the Party shall:
16 (1) promptly notify in writing the Requesting Party and the Non-Party that
17|}some or all of the information requested is subject to a confidentiality agreement with a
Non-Party;
19 (2) promptly provide the Non-Party with a copy of the Stipulated Protective
20|Order in this Action, the relevant discovery request(s), and a reasonably specific
description of the information requested; and
22 (3) make the information requested available for inspection by the Non-
Party, if requested.
24 (c) Ifthe Non-Party fails to seek a protective order from this court within 14
25||days of receiving the notice and accompanying information, the Receiving Party may
26|/produce the Non-Party’s confidential information responsive to the discovery request. If
Non-Party timely seeks a protective order, the Receiving Party shall not produce any
28||information in its possession or control that is subject to the confidentiality agreement
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1||with the Non-Party before a determination by the court. Absent a court order to the
2||contrary, the Non-Party shall bear the burden and expense of seeking protection in this
court of its Protected Material.
4412. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
5 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
Protected Material to any person or in any circumstances not authorized under this
Protective Order, the Receiving Party must immediately (a) notify in writing the
Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve all
unauthorized copies of the Protected Material, (c) inform the person or persons to whom
10]/unauthorized disclosures were made of all the terms of this Protective Order, and (d)
11|/request such person or persons to execute the “Acknowledgment and Agreement to Be
12 Bound” that is attached hereto as Exhibit A.
INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
14 PROTECTED MATERIAL
15 When a Producing Party gives notice to the Receiving Parties that certain
inadvertently produced material is subject to a claim of privilege or other protections, the
17| obligations of the Receiving Parties are those set forth in Fed. R. Civ. P. 26(b)(5)(B). This
provision is not intended to modify whatever procedure may be established in an e-
19| discovery order that provides for production without prior privilege review. Pursuant to
20|| Federal Rule of Evidence 502(d) and (e), insofar as the Parties reach an agreement on the
21\effect of disclosure of a communication or information covered by the attorney-client
22| privilege or work product protection, the Parties may may incorporate their agreement in
stipulated protective order submitted to the court.
24114. MISCELLANEOUS
25 14.1 Right to Further Relief. Nothing in this Protective Order abridges the right
26| of any person to seek its modification by the Court in the future.
27 14.2 Right to Assert Other Objections. By stipulating to the entry of this
28 || Protective Order, no Party waives any right it otherwise would have to object to disclosing
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producing any information or item on any ground not addressed in this Protective
2||Order. Similarly, no Party waives any right to object on any ground to the use in evidence
any of the material covered by this Protective Order.
4 14.3 Filing Protected Material. A Party that seeks to file under seal any Protected
5|| Material must comply with Civil Local Rule 79-5. Protected Material may only be filed
6|under seal pursuant to a court order authorizing the sealing of the specific Protected
Material at issue. If a Party’s request to file Protected Material under seal is denied by
Court, then the Receiving Party may file the information in the public record unless
otherwise instructed by the Court.
10/15. FINAL DISPOSITION
11 After the final disposition of this Action, as defined in paragraph 6, within 60 days
a written request by the Designating Party, each Receiving Party must return all
13||Protected Material to the Producing Party or destroy such material. As used in this
14|subdivision, “all Protected Material” includes all copies, abstracts, compilations,
15|/summaries, and any other format reproducing or capturing any of the Protected Material.
16|| Whether the Protected Material is returned or destroyed, the Receiving Party must submit
written certification to the Producing Party (and, if not the same person or entity, to the
Designating Party) by the 60-day deadline that (1) identifies (by category, where
19] appropriate) all the Protected Material that was returned or destroyed and (2) affirms that
20||the Receiving Party has not retained any copies, abstracts, compilations, summaries or
any other format reproducing or capturing any of the Protected Material. Notwithstanding
22||this provision, Counsel are entitled to retain an archival copy of all pleadings, motion
23||papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence,
24| deposition and trial exhibits, expert reports, attorney work product, and consultant and
expert work product, even if such materials contain Protected Material. Any such archival
26| copies that contain or constitute Protected Material remain subject to this Protective Order
set forth in Section 6 (DURATION).
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VIOLATIONS
2 Any violation of this Protective Order may be punished by any and all appropriate
measures including, without limitation, contempt proceedings and/or monetary sanctions.
4 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
5 Pursuant to Local Rule 5-4.3.4, by my signature below I, Mahadhi Corzano, attest
that all other signatories concur in this filing’s content and have authorized this filing.
7| Dated: February 18, 2026 FUJII LAW GROUP LLP
8
9 By: /s/ Mahadhi Corzano
John M. Fujii
10 Mahadhi Corzano
Monica Phan
1] Attorneys for Defendant
County of San Bernardino
Dated: February 10, 2026 LAW OFFICE OF JAMES S. TERRELL
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14
By: __/s/James S. Terrell
15 James S. Terrell
Attorneys for Plaintiff
16 Plaintiff Joseph Andre Venegas-
Ornelas
17
18
Dated: February 10, 2026 LAW OFFICE OF SHARON J. BRUNNER
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20
By: /s/ Sharon J. Brunner
2] Sharon J. Brunner
Attorneys for Plaintiff
22 Plaintiff Joseph Andre Venegas-
Ornelas
23
24 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
4 25|[Dated: 2/19/2026
=
27! HON. CHARLES F. EICK
59 United States Magistrate Judge
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1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3
, [print or type full
5|name], declare under penalty of perjury that I have read in its entirety and understand
6||the Protective Order that was issued by the United States District Court for the Central
7|| District of California on date [date] in the Action of JOSEPH ANDRE
8] VENEGAS-ORNELAS vy. COUNTY OF SAN BERNARDINO, et al. case number
□□□□□□□□□□□□□□□□□□□□□□ I agree to comply with and to be bound by all the terms of this
Protective Order, and I understand and acknowledge that failure to so comply could
11/}expose me to sanctions and punishment in the nature of contempt. I solemnly promise
I will not disclose in any manner any information or item that is subject to this
13|| Protective Order to any person or entity except in strict compliance with the provisions
14] of this Protective Order. I further agree to submit to the jurisdiction of the United States
District Court for the Central District of California for the purpose of enforcing the terms
16] of this Protective Order, even if such enforcement proceedings occur after termination of
17| this Action.
18 I hereby appoint as my California
19| agent for service of process in connection with this Action or any proceedings related to
20| enforcement of this Protective Order.
21
22|| Date:
City and State where sworn and signed:
Printed name:
25 Signature:
26
27
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_EXTIBIT A -