# Opinion

> District Court, C.D. California · February 19, 2026

URL: https://www.frixlaw.com/law-library/cases/11366275

## Case

- **Full name:** Antonelli Haggerty v. Law Offices of Los Angeles County Public Defender, County of Los Angeles, Los Angeles County Board of Supervisors, Ronald L. Brown, Ruben Marquez, Justine Esack, and Ricardo Garcia
- **Court:** District Court, C.D. California
- **Decided:** February 19, 2026
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

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## Opinion text

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8 UNITED STATES DISTRICT COURT
9 CENTRAL DISTRICT OF CALIFORNIA
10 WESTERN DIVISION
11
12 | ANTONELLI HAGGERTY, CASE NO.:CV 24-2287-DMG-PVCx

oh Plaintiff, DISCOVERY MATTER
14 Vy. STIPULATED PROTECTIVE
ORDER
15 | LAW OFFICES OF LOS ANGELES
COUNTY PUBLIC DEFENDER, a
16 | public entity, COUNTY OF LOS
ANGELES, a public entity, LOS
17 | ANGELES COUNTY BOARD OF
SUPERVISORS, a public entity,
18 | RONALD L. BROWN, an individual,
RUBEN MARQUEZ, an individual,
19 | JUSTINE ESACK, an individual, and
39 | RICARDO GARCIA, an individual.
21
Defendants.
23
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25
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27
28

1 INTRODUCTION
2 1.1 PURPOSES AND LIMITATIONS
3 Discovery in this action is likely to involve production of confidentiz
4 proprietary, or private information for which special protection from public □□□□□□□□
5 and from use for any purpose other than prosecuting this litigation may be warrante
6 | Accordingly, the parties hereby stipulate to and petition the Court to enter the followir
7 |Joint Motion for Stipulated Protective Order (“Stipulated Protective Order’). Tt
8 ||parties acknowledge that this Order does not confer blanket protections on a
9 disclosures or responses to discovery and that the protection it affords from publ
10 |\disclosure and use extends only to the limited information or items that are entitled 1
11 |confidential treatment under the applicable legal principles. The parties furth
12 acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective Ord
13 ||does not entitle them to file confidential information under seal; Civil Local Rule 79-
v= 14 ||sets forth the procedures that must be followed and the standards that will be applic
15 | when a party seeks permission from the court to file material under seal.
16 1.2 GOOD CAUSE STATEMENT
17 This is a civil lawsuit that Plaintiff Antonelli Haggerty (‘‘Plaintiff’)—«
18 individual who was previously civilly detained pursuant to California’s Sexual
19 | Violent Predator Act, Welf. & Inst. Code §§ 6600, et seq.—filed against Defendant
20 jon March 20, 2024 in the U.S. District Court for the Central District of Californi
21 jjalleging deprivations of civil rights in violation of 42 U.S.C. §§ 1983 and 198
22 |\including Plaintiff's alleged 14th Amendment due process right to a speedy civ
23 |commitment trial. Anticipated discovery in this case includes Plaintiff's publ
24 □□ defender files, which will contain years’ worth of Plaintiff's medical records regardir
25 |__"""["[___"_"__”
26 JL os Anucies County Public Defender (°P1") the Los Angeles County Board of
Supervisors, Los An eles County Public Defender Ricardo Garcia (“Garcia”), forme
27 □□□ Angeles County Public Defender Ronald L. Brown (“Brown’’), Los Angeles
28 | County Assistant Public Defender Ruben Marques, Angeles

1 □□□ detainment at the California Department of State Hospitals - Coalinga, among oth«
2 |personal sensitive information. Further, although Defendants have objected to many «
3 |these kinds of discovery requests, Plaintiff has requested documents related to: (
4 |certain communications (if any) between certain government officials and governme!
5 |entities related to certain government duties and functions; (2) changes to certa
6 | government policies, procedures, and customs (if any) made for any reason at all; an
7 (3) certain investigations, audits, reviews conducted (if any) on the handling of □□□□□□
8 || public defender cases.
9 Accordingly, this action will involve confidential information pertaining 1
10 | Plaintiff's legally protected medical records and may involve Law Offices of Li
11 | Angeles County Public Defender’s, Los Angeles County Board of Supervisors’ or oth
12 |County of Los Angeles’s (“LA County”) personnel records and perhaps oth
13 | government materials subject to privacy protections for which special protection fro1
v= 14 public disclosure and from use for any purpose other than prosecution of this action
15 | warranted. Limiting disclosure of these documents to the context of this litigation <
16 || provided herein will, accordingly, further the safety of LA County personnel ar
17 |protect the individual medical privacy rights of Plaintiff. Such confidential materia
18 |and information consist of, among other things, materials entitled to privileges and/<
19 |protections under the following: The United States and California Constitution
20 | Sanchez v. City of Santa Ana, 936 F.2d 1027, 1033 (9th Cir. 1990); Health Insuranc
21 | Portability and Accountability Act of 1996 (HIPPA); and other decisional law relatin
22 |to such provisions; and information otherwise generally unavailable to the public, «
23 | which may be privileged or otherwise protected from disclosure under state and feder
24 |statutes, principles of comity, court rules, case decisions, or common law.
25 Defendants also contend that discovery may involve confidential materials ar
26 |information entitled to the Deliberative Process Privilege and/or the right to privac
27 Confidential information with respect to the Defendants may include but is not limite
28 |to: personnel files; internal investigative files and documents; email and writte

1 | correspondence records; evaluations, reports, and policies and procedures that are key
2 from the public in the ordinary course of business, as well as other information that
3 not generally available to the public and is subject to the Deliberative Process Privileg
4 |and other privileges. Thus, limiting disclosure of these documents to the context of th
5 litigation as provided herein will also protect the ability for LA County personnel |
6 | have candid internal discussions to ensure the quality of government decision-makin,
7 Testimony taken at a deposition may be designated as Confidential by making
8 ||statement to that effect on the record at the deposition. Arrangements shall be mac
9 | with the court reporter transcribing the deposition to separately bind such portions «
10 |the transcript containing information designated as Confidential, and to label suc
11 |portions appropriately. Material designated Confidential, including but not limited 1
12 |photographs, video or audio footage obtained through the course of discovery «
13 otherwise may not be used for any purpose other than litigating this lawsuit.
DS 14 The parties agree to refrain from directly or indirectly disclosing or public!
15 | disseminating confidential records, deposition testimony, and/or photographs, video «
16 audio footage obtained through the course of discovery or otherwise, specificall
17 |including, but not limited to, dissemination via billboard advertisements, print ar
18 | online media organizations, or any other internet posting or social media. If any par
19 |\intends to use such confidential materials for any purpose other than litigating th
20 | lawsuit, the party seeking public disclosure must invoke the procedure set forth in Part
21 |infra.
22 In light of the nature of the claims and allegations in this case and the partie
23 |/representations that discovery in this case may involve the production of confidenti
24 |records, and to expedite the flow of information, to facilitate the prompt resolution «
25 |disputes over confidentiality of discovery materials, to adequately protect informatic
26 |the parties are entitled to keep confidential, to ensure that the parties are permitte
27 ||\reasonable necessary uses of such material in connection with this action, to addre:
28 their handling of such material at the end of the litigation, and to serve the ends «

1 ||justice, a protective order for such information is justified in this matter. The parti:
2 |shall not designate any information/documents as confidential without a good fait
3 |belief that such information/documents have been maintained in a confidentia
4 |nonpublic manner, and that there is good cause or a compelling reason why it shoul
5 |not be part of the public record of this case.
6 DEFINITIONS
7 2.1 Action: pending federal lawsuit, Haggerty v. Law Offices Of Los Angel:
8 || County Public Defender, et al., Case No. 2:24-CV-02287-DMG-PVC.
9 2.2. Challenging Party: a Party or Non-Party that challenges the designation «
10 |information or items under this Order.
11 2.33. “CONFIDENTIAL” Information or Items: information (regardless of ho
12 jit is generated, stored or maintained) or tangible things that qualify for protection und
13 |Federal Rule of Civil Procedure 26(c), and as specified above in the Good Caus
DS 14 Statement.
15 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as the
16 ||support staff).
17 2.5 Designating Party: a Party or Non-Party that designates information «
18 jitems that it produces in disclosures or in responses to discovery
19 |“CONFIDENTIAL.”
20 2.6 Disclosure or Discovery Material: all items or information, regardless «
21 |the medium or manner in which it is generated, stored, or maintained (including, amor
22 | other things, testimony, transcripts, and tangible things), that are produced or generate
23 |in disclosures or responses to discovery in this matter.
24 2.7 Expert: a person with specialized knowledge or experience in a matt
25 pertinent to the litigation who has been retained by a Party or its counsel to serve as 2
26 |/expert witness or as a consultant in this Action.
27 2.8 House Counsel: attorneys who are employees of a party to this Actio:
28 || House Counsel does not include Outside Counsel of Record or any other outsic

1 ||counsel.
2 2.9 Non-Party: any natural person, partnership, corporation, association, «
3 other legal entity not named as a Party to this action.
4 2.10 Qutside Counsel of Record: attorneys who are not employees of a party |
5 |this Action but are retained to represent or advise a party to this Action and hav
6 | appeared in this Action on behalf of that party or are affiliated with a law firm whic
7 |has appeared on behalf of that party, and includes support staff.
8 2.11 Party: any party to this Action, including all of its officers, director
9 |employees, consultants, retained experts, and Outside Counsel of Record (and the
10 |support staffs).
11 2.12 Producing Party: a Party or Non-Party that produces Disclosure «
12 | Discovery Material in this Action.
13 2.13 Professional Vendors: persons or entities that provide litigation suppo
DS 14 |lservices (e.g., photocopying, videotaping, translating, preparing exhibits <
15 | demonstrations, and organizing, storing, or retrieving data in any form or medium) ar
16 | their employees and subcontractors.
17 2.14 Protected Material: any Disclosure or Discovery Material that
18 | designated as “CONFIDENTIAL.”
19 2.15 Receiving Party: a Party that receives Disclosure or Discovery Materi
20 || from a Producing Party.
21 |3. SCOPE
22 The protections conferred by this Stipulation and Order cover not only Protecte
23 Material (as defined above), but also (1) any information copied or extracted fro:
24 || Protected Material; (2) all copies, excerpts, summaries, or compilations of Protecte
25 Material; and (3) any testimony, conversations, or presentations by Parties or the
26 | Counsel that might reveal Protected Material.
27 Any use of Protected Material at trial shall be governed by the orders of the tri
28 judge. This Order does not govern the use of Protected Material at trial.

1 DURATION
2 Once a case proceeds to trial, all of the information that was designated <
3 | confidential or maintained pursuant to this protective order becomes public and will t
4 |presumptively available to all members of the public, including the press, □□□□□
5 |compelling reasons supported by specific factual findings to proceed otherwise a1
6 |made to the trial judge in advance of the trial. See Kamakana v. City and County □
7 | Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing “good □□□□□
8 ||showing for sealing documents produced in discovery from “compelling reasons
9 |standard when merits-related documents are part of court record).
10 Even after final disposition of this litigation, the confidentiality obligatio1
11 imposed by this Order shall remain in effect until a Designating Party agrees otherwis
12 ||in writing or a court order otherwise directs. Final disposition shall be deemed to be tl
13 later of (1) dismissal of all claims and defenses in this Action, with or without prejudic:
v= 14 and (2) final judgment herein after the completion and exhaustion of all appeal
15 |rehearings, remands, trials, or reviews of this Action, including the time limits for filin
16 ||any motions or applications for extension of time pursuant to applicable law.
17 5. DESIGNATING PROTECTED MATERIAL
18 5.1 Exercise of Restraint and Care in Designating Material for Protectior
19 | Each Party or Non-Party that designates information or items for protection under th
20 Order must take care to limit any such designation to specific material that □□□□□□□□
21 |/under the appropriate standards. The Designating Party must designate for protectic
22 |only those parts of material, documents, items, or oral or written communications th
23 | qualify so that other portions of the material, documents, items, or communications fe
24 || which protection is not warranted are not swept unjustifiably within the ambit of th
25 | Order.
26 Mass, indiscriminate, or routinized designations are prohibited. Designatio1
27 |that are shown to be clearly unjustified or that have been made for an improper purpo:
28 |\(e.g., to unnecessarily encumber the case development process or to impo:

1 | unnecessary expenses and burdens on other parties) may expose the Designating Part
2 sanctions.
3 If it comes to a Designating Party’s attention that information or items that
4 |designated for protection do not qualify for protection, that Designating Party mu
5 | promptly notify all other Parties that it is withdrawing the inapplicable designation.
6 5.2 Manner and Timing of Designations. Except as otherwise provided in th
7 | Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulate
8 jor ordered, Disclosure or Discovery Material that qualifies for protection under th
9 | Order must be clearly so designated before the material is disclosed or produced.
10 Designation in conformity with this Order requires:
11 (a) for information in documentary form (e.g., paper or electron
12 |documents, but excluding transcripts of depositions or other pretrial or tri
13 proceedings), that the Producing Party affix at a minimum, □□□ □□□□□
DS 14 |“CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend’), to each page th
15 |}contains protected material. If only a portion or portions of the material on a pag
16 |qualifies for protection, the Producing Party also must clearly identify the protecte
17 |portion(s) (e.g., by making appropriate markings in the margins).
18 (b) for testimony given in depositions that the Designating Part
19 jjidentify all protected testimony including Disclosure or Discovery Material on tt
20 |record, before the close of the deposition.
21 (c) for information produced in some form other than documentary an
22 for any other tangible items, that the Producing Party affix in a prominent place on tt
23 |/exterior of the container or containers in which the information is stored the leger
24 “CONFIDENTIAL.”
25 (d) the legend “CONFIDENTIAL” shall be affixed to documents ar
26 |other tangible items in a manner that does not obscure the information containe
27 thereon.
28 5.3 Inadvertent Failures to Designate. If timely corrected, an □□□□□□□□□□

1 failure to designate qualified information or items does not, standing alone, waive tk
2 | Designating Party’s right to secure protection under this Order for such material. Upc
3 | timely correction of a designation, the Receiving Party must make reasonable efforts 1
4 |assure that the material is treated in accordance with the provisions of this Order.
5 CHALLENGING CONFIDENTIALITY DESIGNATIONS
6 6.1 Timing of Challenges. Any Party or Non-Party may challenge
7 | designation of confidentiality at any time that is consistent with the Court’s Schedulir
8 | Order.
9 6.2 Meet and Confer. The Challenging Party shall initiate the dispu
10 resolution process (and, if necessary, file a discovery motion) under Local Rule 37.1.
11 |seq.
12 6.3. The burden of persuasion in any such challenge proceeding shall be on tt
13 | Designating Party. Frivolous challenges, and those made for an improper purpose (e.¢
v= 14 ||to harass or impose unnecessary expenses and burdens on other parties) may expo:
15 |the Challenging Party to sanctions. Unless the Designating Party has waived «
16 | withdrawn the confidentiality designation, all parties shall continue to afford th
17 |material in question the level of protection to which it is entitled under the Producin
18 | Party’s designation until the Court rules on the challenge.
19 7. ACCESS TO AND USE OF PROTECTED MATERIAL
20 7.1 Basic Principles. A Receiving Party may use Protected Material that
21 |\disclosed or produced by another Party or by a Non-Party in connection with th
22 |Action only for prosecuting, defending, or attempting to settle this Action. Suc
23 || Protected Material may be disclosed only to the categories of persons and under tl
24 ||\conditions described in this Order. When the Action has been terminated, a Receivin
25 || Party must comply with the provisions of section 13 below (FINAL DISPOSITION)
26 Protected Material must be stored and maintained by a Receiving Party at a
27 location and in a secure manner that ensures that access is limited to the persons
28 | authorized under this Order.
°

1 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwi:
2 |ordered by the court or permitted in writing by the Designating Party, a Receiving Par
3 | may disclose any information or item designated “CONFIDENTIAL” only to:
4 (a) the Receiving Party’s Outside Counsel of Record in this Action, <
5 well as employees of said Outside Counsel of Record to whom it 1s reasonabl
6 |necessary to disclose the information for this Action;
7 (b) the officers, directors, and employees (including House Counsel) «
8 □□ □□□ Receiving Party to whom disclosure is reasonably necessary for this Action;
9 (c) Experts (as defined in this Order) of the Receiving Party to who:
10 |\disclosure is reasonably necessary for this Action and who have signed th
11 |“Acknowledgment and Agreement to Be Bound” (Exhibit A);
12 (d) the court and its personnel;
13 (e) court reporters and their staff;
v= 14 (f) professional jury or trial consultants, mock jurors, and Profession
15 | Vendors to whom disclosure is reasonably necessary for this Action and who hav
16 |signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
17 (g) the author or recipient of a document containing the information «
18 custodian or other person who otherwise possessed or knew the information;
19 (h) during their depositions, witnesses, and attorneys for witnesses, |
20 Action to whom disclosure is reasonably necessary provided: (1) the deposing part
21 |/requests that the witness sign the form attached as Exhibit A hereto; and (2) they wi
22 |not be permitted to keep any confidential information unless they sign tt
23 | ““Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agree
24 □ □□ the Designating Party or ordered by the court. Pages of transcribed depositic
25 ||testimony or exhibits to depositions that reveal Protected Material may be separate’
26 | bound by the court reporter and may not be disclosed to anyone except as permitte
27 |under this Stipulated Protective Order; and
28 (1) any mediator or settlement officer, and their supporting personne

1 | mutually agreed upon by any of the parties engaged in settlement discussions.
2 18. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED I
3 OTHER LITIGATION
4 If a Party is served with a subpoena or a court order issued in other litigation th
5 |compels disclosure of any information or items designated in this Action ¢
6 |CONFIDENTIAL,” that Party must:
7 (a) promptly notify in writing the Designating Party. Such notificatic
8 ||shall include a copy of the subpoena or court order;
9 (b) promptly notify in writing the party who caused the subpoena «
10 order to issue in the other litigation that some or all of the material covered by tt
11 subpoena or order is subject to this Protective Order. Such notification shall include
12 |\copy of this Stipulated Protective Order; and
13 (c) cooperate with respect to all reasonable procedures sought to t
v= 14 pursued by the Designating Party whose Protected Material may be affected.
15 If the Designating Party timely seeks a protective order, the Party served wi
16 |the subpoena or court order shall not produce any information designated in this actic
17 jas “CONFIDENTIAL” before a determination by the court from which the subpoer
18 | or order issued, unless the Party has obtained the Designating Party’s permission. TI
19 | Designating Party shall bear the burden and expense of seeking protection in that cou
20 |of its confidential material and nothing in these provisions should be construed □
21 |authorizing or encouraging a Receiving Party in this Action to disobey a lawf
22 ||directive from another court.
23 1/9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCE
24 IN THIS LITIGATION
25 (a) The terms of this Order are applicable to information produced t
26 ||a Non-Party in this Action and designated as “CONFIDENTIAL.” Such informatic
27 || produced by Non-Parties in connection with this litigation is protected by the □□□□□□
28 |and relief provided by this Order. Nothing in these provisions should be construed □
11

1 | prohibiting a Non-Party from seeking additional protections.
2 (b) Inthe event that a Party is required, by a valid discovery request, |
3 ||produce a Non-Party’s confidential information in its possession, and the Party
4 |subject to an agreement with the Non-Party not to produce the Non-Party’s confidenti:
5 |information, then the Party shall:
6 (1) promptly notify in writing the Requesting Party and the Not
7 |Party that some or all of the information requested is subject to a confidentialit
8 agreement with a Non-Party;
9 (2) promptly provide the Non-Party with a copy of the Stipulate
10 |Protective Order in this Action, the relevant discovery request(s), and a reasonab!
11 |/specific description of the information requested; and
12 (3) make the information requested available for inspection t
13 |the Non-Party, if requested.
v= 14 (c) If the Non-Party fails to seek a protective order from this cou
15 | within 14 days of receiving the notice and accompanying information, the Receivir
16 |Party may produce the Non-Party’s confidential information responsive to tt
17 ||discovery request. If the Non-Party timely seeks a protective order, the Receiving Part
18 |shall not produce any information in its possession or control that is subject to th
19 |confidentiality agreement with the Non-Party before a determination by the cour
20 | Absent a court order to the contrary, the Non-Party shall bear the burden and expen:
21 |of seeking protection in this court of its Protected Material.
22 |10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
23 If a Receiving Party learns that, by inadvertence or otherwise, it has disclose
24 ||Protected Material to any person or in any circumstance not authorized under th
25 || Stipulated Protective Order, the Receiving Party must immediately (a) notify in writir
26 ||the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrie\
27 |all unauthorized copies of the Protected Material, (c) inform the person or persons 1
28 | whom unauthorized disclosures were made of all the terms of this Order, and (d) reque
14

1 |such person or persons to execute the “Acknowledgment and Agreement to Be Bounc
2 |that is attached hereto as Exhibit A.
3 INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWIS
4 PROTECTED MATERIAL
5 When a Producing Party gives notice to Receiving Parties that □□□□□
6 |inadvertently produced material is subject to a claim of privilege or other protectio:
7 |the obligations of the Receiving Parties are those set forth in Federal Rule of Civ
8 | Procedure 26(b)(5)(B). This provision is not intended to modify whatever □□□□□□□
9 | may be established in an e-discovery order that provides for production without pric
10 |privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as th
11 |parties reach an agreement on the effect of disclosure of a communication □
12 |information covered by the attorney-client privilege or work product protection, th
13 |/parties may incorporate their agreement in the stipulated protective order submitted 1
14 | the court.
}12. MISCELLANEOUS
16 12.1 Right to Further Relief. Nothing in this Order abridges the right of ar
17 person to seek its modification by the Court in the future.
18 12.2 Right to Assert Other Objections. By stipulating to the entry of th
19 | Protective Order no Party waives any right it otherwise would have to object |
20 |disclosing or producing any information or item on any ground not addressed in th
21 ||Stipulated Protective Order. Similarly, no Party waives any right to object on ar
22 || ground to use in evidence of any of the material covered by this Protective Order.
23 12.3 Filing Protected Material. A Party that seeks to file under seal ar
24 || Protected Material must comply with Civil Local Rule 79-5. Protected Material □□□
25 |only be filed under seal pursuant to a court order authorizing the sealing of the specif
26 || Protected Material at issue. If a Party's request to file Protected Material under seal
27 ||denied by the court, then the Receiving Party may file the information in the publ
28 |record unless otherwise instructed by the court.
19

1 12.4 Right to Stipulate. Nothing in this Order abridges the right of the Parti
2 ||to stipulate to the use of Protected Material in this Action in any other related actic
3 pursuant to the terms of this subsection. The Party wishing to use Protected Materi:
4 |in this Action in another action must make a written request to the Designating Party |
5 which the requesting Party specifically identifies each piece of information and/
6 |document they wish to use in the other action, and they must receive express writte
7 |consent from the Designating Party allowing them to do so. Where reasonable, tt
8 ||requesting Party may also identify documents by categories (e.g., training materials
9 |The written request must also identify by name, case number, and location the oth
10 action(s) the Party wishes to use the Protected Material in. The Designating Party mez
11 |grant the request in whole, deny the request in whole, or agree as to some pieces ¢
12 |information/documents specifically listed but not others that are also listed.
13 The consent provided by the Designating Party (if any) will be valid only as 1
DS 14 ||the specifically identified information/document(s) in the written request, and only fe
15 |/use in the properly identified action(s) listed in the same written request. In all oth
16 instances, the terms of this Order remain in full force and effect and the Parties may n«
17 |\use Protected Material in a manner that is inconsistent with the Order’s terms.
18 FINAL DISPOSITION
19 After the final disposition of this Action, as defined in paragraph 4, within €
20 ||days of a written request by the Designating Party, each Receiving Party must □□□□□
21 |/all Protected Material to the Producing Party or destroy such material. As used in th
22 |subdivision, “all Protected Material” includes all copies, abstracts, compilation
23 summaries, and any other format reproducing or capturing any of the □□□□□□□
24 || Material. Whether the Protected Material is returned or destroyed, the Receiving Par
25 ||must submit a written certification to the Producing Party (and, if not the same persc
26 jor entity, to the Designating Party) by the 60 day deadline that (1) identifies (t
27 ||category, where appropriate) all the Protected Material that was returned or destroyc
28 (2) affirms that the Receiving Party has not retained any copies, abstract
19

1 | compilations, summaries or any other format reproducing or capturing any of tl
2 | Protected Material. Notwithstanding this provision, Counsel are entitled to retain a
3 archival copy of all pleadings, motion papers, trial, deposition, and hearing transcript
4 |legal memoranda, correspondence, deposition and trial exhibits, expert report
5 |attorney work product, and consultant and expert work product, even if such materia
6 |contain Protected Material. Any such archival copies that contain or constitu
7 Protected Material remain subject to this Protective Order as set forth in Section
8 |(DURATION).
9 114. Any willful violation of this Order may be punished by civil or criminal contem]
10 |proceedings, financial or evidentiary sanctions, reference to disciplinary authorities, «
11 other appropriate action at the discretion of the Court.
12
13 FOR GOOD CAUSE SHOWN BY THE PARTIES’ STIPULATION, IT IS S¢
DS 14 | ORDERED.

16 fu
DATED: February 19, 2026
7 HON. PEDRO V. CASTILLO
18 United States Magistrate Judge
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1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3 I, [print or type full name
4 jof [print or type full address
5 |declare under penalty of perjury that I have read in its entirety and understand tl
6 | Stipulated Protective Order that was issued by the United States District Court for tk
7 |Central District of California on , 202_, in the case of Haggerty
8 | Law Offices Of Los Angeles County Public Defender, et al., Case No. 2:24-CV-0228'
9 |DMG-PVC. I agree to comply with and to be bound by all the terms of this Stipulate
10 |Protective Order and I understand and acknowledge that failure to so comply coul
11 expose me to sanctions and punishment in the nature of contempt. I solemnly promis
12 |that I will not disclose in any manner any information or item that is subject to th
13 Stipulated Protective Order to any person or entity except in strict compliance with th
v= 14 |provisions of this Order.
15 I further agree to submit to the jurisdiction of the United States District Court fe
16 |the Central District of California for the purpose of enforcing the terms of th
17 Stipulated Protective Order, even if such enforcement proceedings occur aft
18 |termination of this action. I hereby appoint [print «
19 ||type full name] of [print or type fu
20 address and telephone number] as my California agent for service of process |
21 |}connection with this action or any proceedings related to enforcement of this Stipulate
22 || Protective Order.
23 | Date:
24 ||City and State where sworn and signed:
25
26 | Printed name:
27
28 | Signature:

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/11366275. Public record. Not legal advice.