Opinion

Court: District Court, C.D. California
Filed: Mar 6, 2026
Cited by: 0 cases
Authority: More cited than 41.4%

The opinion

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

4 HARSON CHONG,

ANGIE CHONG, Case No. 2:25-CV-507-FLA-AJR

5 GARY CHAN,

6 Plaintiff(s), STIPULATED PROTECTIVE

7 v. ORDER

8 TOAN DUONG, et al.

9 Defendant(s).

1. INTRODUCTION

1.1 Purposes and Limitations. Discovery in this action is likely to involve

production of confidential, proprietary, or private information for which special

protection from public disclosure and from use for any purpose other than

prosecuting this litigation may be warranted. Accordingly, the parties hereby

stipulate to and petition the court to enter the following Stipulated Protective Order.

The parties acknowledge that this Order does not confer blanket protections on all

disclosures or responses to discovery and that the protection it affords from public

disclosure and use extends only to the limited information or items that are entitled

to confidential treatment under the applicable legal principles.

1.2 Good Cause Statement. The Court finds good cause for the entry of

this Protective Order pursuant to Federal Rule of Civil Procedure 26(c). Discovery

in this action is likely to involve confidential law-enforcement information,

including but not limited to investigative materials, surveillance and operational

methods, internal communications, personnel and internal affairs records,

non-public identifying information of law-enforcement personnel and private

1 Privacy Act of 1974. Disclosure of such material without appropriate safeguards

2 could compromise legitimate privacy, safety, and law-enforcement interests. This

3 Protective Order is intended to facilitate discovery while protecting such interests

4 and does not constitute a determination that any particular material is relevant or

5 discoverable.

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

7 resolution of disputes over confidentiality of discovery materials, to adequately

8 protect information the parties are entitled to keep confidential, to ensure that the

9 parties are permitted reasonable necessary uses of such material in preparation for

10 and in the conduct of trial, to address their handling at the end of the litigation, and

11 serve the ends of justice, a protective order for such information is justified in this

12 matter. It is the intent of the parties that information will not be designated as

13 confidential for tactical reasons and that nothing be so designated without a good

14 faith belief that it has been maintained in a confidential, non-public manner, and

15 there is good cause why it should not be part of the public record of this case.

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 judicial

23 proceedings and records in civil cases. In connection with non-dispositive motions,

24 good cause must be shown to support a filing under seal. See Kamakana v. City

25 and Cnty. of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of

26 Byrd v. Gen. Motors Corp., 307 F.3d 1206, 1210–11 (9th Cir. 2002), Makar-

27 Welbon v. Sony Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated

1 cause or compelling reasons with proper evidentiary support and legal justification,

2 must be made with respect to Protected Material that a party seeks to file under

3 seal. The parties’ mere designation of Disclosure or Discovery Material as

4 CONFIDENTIAL does not—without the submission of competent evidence by

5 declaration, establishing that the material sought to be filed under seal qualifies as

6 confidential, privileged, or otherwise protectable—constitute good cause.

7 Further, if a party requests sealing related to a dispositive motion or trial,

8 then compelling reasons, not only good cause, for the sealing must be shown, and

9 the relief sought shall be narrowly tailored to serve the specific interest to be

10 protected. See Pintos v. Pac. Creditors Ass’n, 605 F.3d 665, 677–79 (9th Cir.

11 2010). For each item or type of information, document, or thing sought to be filed

12 or introduced under seal in connection with a dispositive motion or trial, the party

13 seeking protection must articulate compelling reasons, supported by specific facts

14 and legal justification, for the requested sealing order. Again, competent evidence

15 supporting the application to file documents under seal must be provided by

16 declaration.

17 Any document that is not confidential, privileged, or otherwise protectable in

18 its entirety will not be filed under seal if the confidential portions can be redacted.

19 If documents can be redacted, then a redacted version for public viewing, omitting

20 only the confidential, privileged, or otherwise protectable portions of the document,

21 shall be filed. Any application that seeks to file documents under seal in their

22 entirety should include an explanation of why redaction is not feasible.

23 1.4 Privacy Act Authorization. Pursuant to 5 U.S.C. § 552a(b)(12), this

24 Protective Order constitutes an order of a court of competent jurisdiction authorizing

25 the disclosure of records protected by the Privacy Act of 1974 in this action. Any

26 such records produced shall be subject to the terms of this Protective Order.

/ / /

1 DEFINITIONS

2 2.1 Action: this pending federal lawsuit as captioned above.

2.2 “Confidential Information” means: any information, document, or thing

that a Producing Party reasonably and in good faith believes contains: (a)

law-enforcement sensitive information, including investigative files, reports,

recordings, surveillance materials, or internal communications not publicly

disseminated; (b) policies, training materials, manuals, or guidance not intended for

public distribution; (c) personal identifying information of non-parties or

law-enforcement personnel, including addresses, telephone numbers, dates of birth,

financial information, or similar data; (d) information protected from disclosure by

federal or state privacy statutes, including the Privacy Act of 1974, 5 U.S.C. § 552a;

or (e) other information entitled to protection under Rule 26(c).

2.3 “Confidential – Attorneys’ Eyes Only” (“AEO”) Information means: a

subset of Confidential Information that the Producing Party reasonably and in good

faith believes is so sensitive that disclosure beyond counsel, experts, and the Court

would create a substantial risk of harm to privacy, safety, or law-enforcement

interests. This category may include, by way of example: (a) personnel files, internal

affairs investigations, disciplinary records, or complaint histories; (b) sensitive

law-enforcement tactical or surveillance information; (c) information whose

disclosure could reasonably be expected to compromise officer safety or ongoing or

future law-enforcement operations.

2.4 Challenging Party: a Party or Non-Party that challenges the designation

of information or items under this Order.

2.5 “CONFIDENTIAL” and/or “AEO” Information or Items: information

(regardless of how it is generated, stored or maintained) or tangible things that

qualify for protection under Rule 26(c) of the Federal Rules of Civil Procedure, and

as specified above in the Good Cause Statement.

1 2.6 Counsel: Outside Counsel of Record and House Counsel (as well as

2 their support staff).

3 2.7 Designating Party: a Party or Non-Party that designates information or

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

5 “CONFIDENTIAL.”

6 2.8 Disclosure or Discovery Material: all items or information, regardless

7 of the medium or manner in which it is generated, stored, or maintained (including,

8 among other things, testimony, transcripts, and tangible things), that are produced or

9 generated in disclosures or responses to discovery in this matter.

10 2.9 Expert: a person with specialized knowledge or experience in a matter

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

12 an expert witness or as a consultant in this Action.

13 2.10 Final Disposition: the later of (1) dismissal of all claims and defenses

14 in this Action, with or without prejudice; and (2) final judgment herein after the

15 completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of

16 this Action, including the time limits for filing any motions or applications for

17 extension of time pursuant to applicable law.

18 2.11 In-House Counsel: attorneys who are employees of a party to this

19 Action. In-House Counsel does not include Outside Counsel of Record or any other

20 outside counsel.

21 2.12 Non-Party: any natural person, partnership, corporation, association, or

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

23 2.13 Outside Counsel of Record: attorneys who are not employees of a party

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

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

26 has appeared on behalf of that party, and includes support staff.

27 2.14 Party: any party to this Action, including all of its officers, directors,

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

2 support staffs).

3 2.15 Producing Party: a Party or Non-Party that produces Disclosure or

4 Discovery Material in this Action.

5 2.16 Professional Vendors: persons or entities that provide litigation-

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

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

8 and their employees and subcontractors.

9 2.17 Protected Material: any Disclosure or Discovery Material that is

10 designated as “CONFIDENTIAL” or “AEO.”

11 2.18 Receiving Party: a Party that receives Disclosure or Discovery Material

12 from a Producing Party.

14 3. SCOPE

This Protective Order applies to all documents, information, and materials

produced by any Party or non-party, including non-party law-enforcement agencies

and current or former employing agencies of Defendants. The protections

conferred by this Stipulation and Order cover not only Protected Material (as

defined above), but also (1) any information copied or extracted from 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 be governed by the orders of the

trial judge. This Stipulated Protective Order does not govern the use of Protected

Material at trial.

/ / /

1 4. TRIAL AND DURATION

2 The terms of this Stipulated Protective Order apply through Final Disposition

3 of the Action.

Once a case proceeds to trial, information that was designated as

CONFIDENTIAL, AEO, or maintained pursuant to this Stipulated Protective Order

and used or introduced as an exhibit at trial becomes public and will be

presumptively available to all members of 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 documents produced in discovery

from “compelling reasons” standard when merits-related documents are part of

court record). Accordingly, for such materials, the terms of this Stipulated

Protective Order do not extend beyond the commencement of the trial.

[Optional addition:]

Even after Final Disposition of this litigation, the confidentiality obligations

imposed by this Stipulated Protective Order shall remain in effect until a

Designating Party agrees otherwise in writing or a court order otherwise directs.

5. DESIGNATING PROTECTED MATERIAL

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

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

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

qualifies under the appropriate standards. The Designating Party must designate for

protection only those parts of material, documents, items, or oral or written

communications that qualify so that other portions of the material, documents,

items, or communications for which protection is not warranted are not swept

unjustifiably within the ambit of this Order.

1 Mass, indiscriminate, or routinized designations are prohibited. Designations

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

3 purpose (e.g., to unnecessarily encumber the case development process or to

4 impose unnecessary expenses and burdens on other parties) may expose the

5 Designating Party to sanctions.

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

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

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

9 5.2 Unless otherwise ordered by the Court or agreed in writing, AEO

10 Information may be disclosed only to: (a) outside counsel of record and their staff;

11 (b) retained experts or consultants reasonably necessary for this litigation, after

12 execution of the acknowledgment attached to this Order and disclosure of the

13 expert’s identity and qualifications to the Producing Party; (c) the Court and its

14 personnel; (d) court reporters, videographers, and professional vendors reasonably

15 necessary for this litigation.

16 5.3 Plaintiffs themselves shall not have access to AEO Information absent

17 further agreement or court order. The Producing Party may object in good faith to

18 disclosure of AEO Information to a proposed expert within ten (10) business days

19 after disclosure of the expert’s identity and qualifications. If the parties are unable

20 to resolve the objection through good-faith meet and confer, the Producing Party

21 may seek appropriate relief from the Court.

22 5.4 Manner and Timing of Designations. Except as otherwise provided in

23 this Stipulated Protective Order (see, e.g., second paragraph of section 5.4(a)

24 below), or as otherwise stipulated or ordered, Disclosure or Discovery Material that

25 qualifies for protection under this Stipulated Protective Order must be clearly so

26 designated before the material is disclosed or produced.

27 Designation in conformity with this Stipulated Protective Order requires:

1 documents, but excluding transcripts of depositions or other pretrial or trial

2 proceedings), that the Producing Party affix at a minimum, the legend

3 “CONFIDENTIAL” to each page that contains protected material. If only a

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

5 Party also must clearly identify the protected portion(s) (e.g., by making

6 appropriate markings in the margins).

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

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

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

10 before the designation, all of the material made available for inspection shall be

11 deemed CONFIDENTIAL. After the inspecting Party has identified the documents

12 it wants copied and produced, the Producing Party must determine which

13 documents, or portions thereof, qualify for protection under this Stipulated

14 Protective Order. Then, before producing the specified documents, the Producing

15 Party must affix the “CONFIDENTIAL” or “AEO” legend to each page that

16 contains Protected Material. If only a portion or portions of the material on a page

17 qualifies for protection, the Producing Party also must clearly identify the protected

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

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

20 the Disclosure or Discovery Material on the record, before the close of the

21 deposition all protected testimony or during the period of time for witnesses to

22 review, correct, and verify the testimony.

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

24 for any other tangible items, that the Producing Party affix in a prominent place on

25 the exterior of the container or containers in which the information is stored the

26 “CONFIDENTIAL” or “AEO” legend. If only a portion or portions of the

27 information warrants protection, the Producing Party, to the extent practicable, shall

1 5.5 Inadvertent Failures to Designate. If timely corrected, an inadvertent

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

3 the Designating Party’s right to secure protection under this Order for such material.

4 Upon timely correction of a designation, the Receiving Party must make reasonable

5 efforts to assure that the material is treated in accordance with the provisions of this

6 Stipulated Protective Order.

8 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

9 6.1 A Receiving Party may challenge a confidentiality or AEO designation

10 at any time that is consistent with the Court’s Scheduling Order. The parties shall

11 first meet and confer in good faith to attempt to resolve the dispute. If the dispute is

12 not resolved, the challenging party may seek appropriate relief from the Court.

13 Until the Court rules, the material shall be treated in accordance with the

14 designation.

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

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

Scheduling Order.

6.3 Meet and Confer. The Challenging Party shall initiate the dispute

resolution process under Local Rule 37.1 et seq. and with Section 2 of Magistrate

Judge A. Joel Richlin’s Civil Procedures titled “Brief Pre-Discovery Motion

Conference.”1

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

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

purpose (e.g., to harass or impose unnecessary expenses and burdens on other

1 Judge Richlin’s Procedures are available at

1 parties) may expose the Challenging Party to sanctions. Unless the Designating

2 Party has waived or withdrawn the confidentiality designation, all parties shall

3 continue to afford the material in question the level of protection to which it is

4 entitled under the Producing Party’s designation until the court rules on the

5 challenge.

7 7. ACCESS TO AND USE OF PROTECTED MATERIAL

8 7.1 Basic Principles. A Receiving Party may use Protected Material that

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

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

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

12 conditions described in this Order. When the Action reaches a Final Disposition, a

13 Receiving Party must comply with the provisions of section 13 below.

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

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

16 authorized under this Stipulated Protective Order.

17 7.2 Use Of Protected Material In Depositions, Hearings, And Trial:

18 Confidential and AEO Information may be used in depositions, subject to

19 appropriate designation of the deposition transcript or exhibits. The designation of

20 material as Confidential or AEO does not, by itself, determine whether such

21 material may be used at hearings or trial. The parties shall confer in good faith

22 regarding the use of such material in advance of any hearing or trial, and any

23 dispute shall be resolved by the Court.

7.3 Disclosure of “CONFIDENTIAL” Information or Items. Unless

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

Receiving Party may disclose any information or item designated

“CONFIDENTIAL” only:

1 (a) to the Receiving Party’s Outside Counsel of Record in this Action, as

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

3 necessary to disclose the information for this Action;

4 (b) to the officers, directors, and employees (including House Counsel) of

5 the Receiving Party to whom disclosure is reasonably necessary for this Action;

6 (c) to Experts (as defined in this Order) of the Receiving Party to whom

7 disclosure is reasonably necessary for this Action and who have signed the

8 “Acknowledgment and Agreement to Be Bound” (Exhibit A);

9 (d) to the court and its personnel;

10 (e) to court reporters and their staff;

11 (f) to professional jury or trial consultants, mock jurors, and Professional

12 Vendors to whom disclosure is reasonably necessary for this Action and who have

13 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);

14 (g) to the author or recipient of a document containing the information or

15 a custodian or other person who otherwise possessed or knew the information;

16 (h) during their depositions, to witnesses, and attorneys for witnesses, in

17 the Action to whom disclosure is reasonably necessary, provided: (1) the deposing

18 party requests that the witness sign the “Acknowledgment and Agreement to Be

19 Bound” (Exhibit A); and (2) the witness will not be permitted to keep any

20 confidential information unless they sign the “Acknowledgment and Agreement to

21 Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party or

22 ordered by the court. Pages of transcribed deposition testimony or exhibits to

23 depositions that reveal Protected Material may be separately bound by the court

24 reporter and may not be disclosed to anyone except as permitted under this

25 Stipulated Protective Order; and

26 (i) to any mediator or settlement officer, and their supporting personnel,

27 mutually agreed upon by any of the parties engaged in settlement discussions.

1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED

2 PRODUCED IN OTHER LITIGATION

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

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

5 “CONFIDENTIAL” or “AEO,” that Party must:

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

shall include a copy of the subpoena or court order;

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

to 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 Stipulated Protective Order; and

pursued by the Designating Party whose Protected Material may be affected.

If the Designating Party timely seeks a protective order, the Party served

with the subpoena or court order shall not produce any information designated in

this action as “CONFIDENTIAL” before a determination by the court from which

the subpoena or order issued, unless the Party has obtained the Designating Party’s

permission. The Designating Party shall bear the burden and expense of seeking

protection in that court of its confidential material and nothing in these provisions

should be construed as authorizing or encouraging a Receiving Party in this Action

to disobey a lawful directive from another court.

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

PRODUCED IN THIS LITIGATION

9.1 Application. The terms of this Stipulated Protective Order are

applicable to information produced by a Non-Party in this Action and designated as

“CONFIDENTIAL” And/or “AEO.” Such information produced by Non-Parties in

1 connection with this litigation is protected by the remedies and relief provided by

2 this Order. Nothing in these provisions should be construed as prohibiting a Non-

3 Party from seeking additional protections.

4 9.2 Notification. In the event that a Party is required, by a valid discovery

5 request, to produce a Non-Party’s confidential information in its possession, and the

6 Party is subject to an agreement with the Non-Party not to produce the Non-

7 Party’s confidential information, then the Party shall:

8 (a) promptly notify in writing the Requesting Party and the Non-Party

9 that some or all of the information requested is subject to a confidentiality

10 agreement with a Non-Party;

11 (b) make the information requested available for inspection by the Non-

12 Party, if requested.

13 9.3 Conditions of Production. If the Non-Party fails to seek a protective

14 order from this court within 14 days of receiving the notice and accompanying

15 information, the Receiving Party may produce the Non-Party’s confidential

16 information responsive to the discovery request. If the Non-Party timely seeks a

17 protective order, the Receiving Party shall not produce any information in its

18 possession or control that is subject to the confidentiality agreement with the Non-

19 Party before a determination by the court. Absent a court order to the contrary, the

20 Non-Party shall bear the burden and expense of seeking protection in this court of its

21 Protected Material.

23 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

25 disclosed Protected Material to any person or in any circumstance not authorized

26 under this Stipulated Protective Order, the Receiving Party must immediately (a)

27 notify in writing the Designating Party of the unauthorized disclosures, (b) use its

1 best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform

2 the person or persons to whom unauthorized disclosures were made of all the terms

3 of this Order, and (d) request such person or persons to execute the

4 “Acknowledgment and Agreement to Be Bound” (Exhibit A).

6 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

7 PROTECTED MATERIAL

When a Producing Party gives notice to Receiving Parties that certain

inadvertently produced material is subject to a claim of privilege or other

protection, the obligations of the Receiving Parties are those set forth in Rule

26(b)(5)(B) of the Federal Rules of Civil Procedure. This provision is not intended

to modify whatever procedure may be established in an e-discovery order that

provides for production without prior privilege review. Pursuant to Rules 502(d)

and (e) of the Federal Rules of Evidence, insofar as the parties reach an agreement

on the effect of disclosure of a communication or information covered by the

attorney-client privilege or work product protection, the parties may incorporate

their agreement in the stipulated protective order submitted to the court.

12. MISCELLANEOUS

12.1 Right to Further Relief. Nothing in this Stipulated Protective Order

abridges the right of any person to seek its modification by the court in the future.

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

Stipulated Protective Order no Party waives any right it otherwise would have to

object to disclosing or producing any information or item on any ground not

addressed in this Stipulated Protective Order. Similarly, no Party waives any right

to object on any ground to use in evidence of any of the material covered by this

Stipulated Protective Order.

1 12.3 Filing Protected Material. A Party that seeks to file under seal any

2 Protected Material must comply with Local Rule 79-5. Protected Material may

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

4 specific Protected Material at issue. If a Party's request to file Protected Material

5 under seal is denied by the court, then the Receiving Party may file the information

6 in the public record unless otherwise instructed by the court.

8 13. FINAL DISPOSITION

9 After the Final Disposition of this Action, as defined in paragraph 4, within

10 60 days of a written request by the Designating Party, each Receiving Party must

11 return all Protected Material to the Producing Party or destroy such material. As

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

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

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

15 Receiving Party must submit a written certification to the Producing Party (and, if

16 not the same person or entity, to the Designating Party) by the 60 day deadline that

17 (1) identifies (by category, where appropriate) all the Protected Material that was

18 returned or destroyed and (2) affirms that the Receiving Party has not retained any

19 copies, abstracts, compilations, summaries or any other format reproducing or

20 capturing any of the Protected Material. Notwithstanding this provision, Counsel is

21 entitled to retain an archival copy of all pleadings, motion papers, trial, deposition,

22 and hearing transcripts, legal memoranda, correspondence, deposition and trial

23 exhibits, expert reports, attorney work product, and consultant and expert work

24 product, even if such materials contain Protected Material. Any such archival

25 copies that contain or constitute Protected Material remain subject to this Protective

26 Order as set forth in Section 4.

/ / /

1 || 14. VIOLATION

2 Any violation of this Stipulated Protective Order may be punished by any

3 || and all appropriate measures including, without limitation, contempt proceedings

4 || and/or monetary sanctions.

6 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD.

8 DATED: March 4, 2026 /s/ Todd W. Burns

9 TODD W. BURNS

10 Attorney for Plaintiffs Harson Chong,

Angie Chong, and Gary Chan

DATED:March 4, 2026 /s/ Jill Williams

JILL WILLIAMS

14 Attorney for Defendants

15 Lt. Toan Duong, Sgt. Steve Kim, Sgt.

Choong Lee

DATED: March 4, 2026 /s/ Soo-Young Shin

18 SOO-YOUNG SHIN

19 Assistant United States Attorney

Attorneys for Defendant Andrew Flood

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

25 || DATED: March 6, 2026

26 A. JOEL RICHLIN

United States Magistrate Judge

1 EXHIBIT A

2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3 I, ________________________ [print or type full name], of

4 _________________ [print or type full address], declare under penalty of

5 perjury that I have read in its entirety and understand the Stipulated Protective

6 Order that was issued by the United States District Court for the Central District

7 of California on _____________ [date] in the case of Harson Chong, et al. v.

8 Toan Duong, et al., Case No. 2:25-CV-507-FLA-AJR. I agree to comply with

9 and to be bound by all the terms of this Stipulated Protective Order and I

10 understand and acknowledge that failure to so comply could expose me to

11 sanctions and punishment in the nature of contempt. I solemnly promise that I

12 will not disclose in any manner any information or item that is subject to this

13 Stipulated Protective Order to any person or entity except in strict compliance

14 with the provisions of this Order.

15 I further agree to submit to the jurisdiction of the United States District

16 Court for the Central District of California for the purpose of enforcing the terms

17 of this Stipulated Protective Order, even if such enforcement proceedings occur

18 after termination of this action. I hereby appoint ________________________

19 [print or type full name] of ________________________________________

20 _______________________ [print or type full address and telephone number]

21 as 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 signed:

___________________________

Printed name: ___________________________

Signature: ___________________________

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