Opinion

Court: District Court, C.D. California
Filed: Mar 19, 2026
Cited by: 0 cases

The opinion

8 UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

WILLIAM FUENTES, Case No.: 2:25-cv-12068-FLA (AJRx)

13 [PROPOSED] STIPULATED

Plaintiff, PROTECTIVE ORDER

15 Action Filed: December 22, 2025

v. Pretrial Conference: TBD

Trial Date: TBD

DEPUTY ANGEL BLANCO; and Assigned to:

DOE DEPUTIES 1 – 10, Hon. Fernando L. Aenlle-Rocha

19 U.S. District Court Judge

20 Courtroom 6B

Defendants.

23 1. GENERAL

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

1 the Court to enter the following Stipulated Protective Order. The parties acknowledge

2 that this Order does not confer blanket protections on all disclosures or responses to

3 discovery and that the protection it affords from public disclosure and use extends only

4 to the limited information or items that are entitled to confidential treatment under the

5 applicable legal principles. The parties further acknowledge, as set forth in Section 12.3,

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

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

8 followed and the standards that will be applied when a party seeks permission from the

court to file material under seal.

1.2 Good Cause Statement.

In light of the nature of the claims and allegations in this case and the parties’

representations that discovery in this case will involve the production of confidential

records. The disclosure of the foregoing information to non-parties or others would be

harmful to the parties' interests, including the involved and/or third parties. Therefore,

this information must be protected from public dissemination and/or publication outside

of this litigation.

In order to expedite the flow of information, to facilitate the prompt resolution of

disputes over confidentiality of discovery materials, to adequately protect information

the parties are entitled to keep confidential, to ensure that the parties are permitted

reasonable necessary uses of such material in connection with this action, to address

their handling of such material at the end of the litigation, and to serve the ends of

justice, a protective order for such information is justified in this matter. The parties

shall not designate any information/documents as confidential without a good faith belief

that such information/documents have been maintained in a confidential, non-public

26 manner, and that there is good cause or a compelling reason why it should not be part of

27 the public record of this case.

1 2. DEFINITIONS

2 2.1 Action: Fuentes v. Deputy Angel Blanco; Case Number 2:25-cv-12068-

3 FLA-AJR.

4 2.2 Challenging Party: a Party or Non-Party that challenges the designation of

5 information or items under this Order.

6 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how

7 it is generated, stored or maintained) or tangible things that qualify for protection under

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

Statement.

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

support staff).

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

items that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.”

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

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

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

in disclosures or responses to discovery in this matter.

2.7 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.

2.8 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.

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

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

27 2.10 Outside Counsel of Record: attorneys who are not employees of a party to

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

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

2 appeared on behalf of that party, including support staff.

3 2.11 Party: any party to this Action, including all of its officers, directors,

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

5 support staffs).

6 2.12 Producing Party: a Party or Non-Party that produces Disclosure or

7 Discovery Material in this Action.

8 2.13 Professional Vendors: persons or entities that provide litigation support

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

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

their employees and subcontractors.

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

as “CONFIDENTIAL.”

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

from a Producing Party.

3. SCOPE

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

27 4. DURATION

28 Once a case proceeds to trial, all of the court-filed information to be introduced

1 that was previously designated as confidential or maintained pursuant to this protective

2 order becomes public and will be presumptively available to all members of the public,

3 including the press, unless compelling reasons supported by specific factual findings to

4 proceed otherwise are made to the trial judge in advance of the trial. See Kamakana v.

5 City and Cty. of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing

6 “good cause” showing for sealing documents produced in discovery from “compelling

7 reasons” standard when merits-related documents are part of court record). Accordingly,

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

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.

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

are shown to be clearly unjustified or that have been made for an improper purpose (e.g.,

to unnecessarily encumber the case development process or to impose unnecessary

expenses and burdens on other parties) may expose the Designating Party to sanctions.

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

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

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

26 5.2 Manner and Timing of Designations. Except as otherwise provided in this

27 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or

1 ordered, Disclosure or Discovery Material that qualifies for protection under this Order

2 must be clearly so designated before the material is disclosed or produced.

3 Designation in conformity with this Order requires:

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

5 documents, but excluding transcripts of depositions or other pretrial or trial proceedings),

6 that the Producing Party affix, at a minimum, the legend “CONFIDENTIAL”

7 (hereinafter “CONFIDENTIAL legend”), to each page that contains protected material.

8 If only a portion or portions of the material on a page qualifies for protection, the

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

appropriate markings in the margins).

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

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

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

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

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

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

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

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

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

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

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

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

the Disclosure or Discovery Material on the record, before the close of the deposition.

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

27 exterior of the container or containers in which the information is stored the legend

28 “CONFIDENTIAL.” If only a portion or portions of the information warrants

1 protection, the Producing Party, to the extent practicable, shall identify the protected

2 portion(s).

3 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure

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

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

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

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

6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

6.1 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.

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

resolution process under Local Rule 37-1, et seq. Any discovery motion must strictly

comply with the procedures set forth in Local Rules 37-1, 37-2, and 37-3.

6.3 Burden. 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 parties)

may expose the Challenging Party to sanctions. Unless the Designating Party has

waived or withdrawn the confidentiality designation, all parties shall continue to afford

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

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

7. ACCESS TO AND USE OF PROTECTED MATERIAL

26 7.1 Basic Principles. A Receiving Party may use Protected Material that is

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

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

1 Material may be disclosed only to the categories of persons and under the conditions

2 described in this Order. When the Action has been terminated, a Receiving Party must

3 comply with the provisions of section 13 below (FINAL DISPOSITION).

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

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

6 authorized under this Order.

7 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise

8 ordered by the Court or permitted in writing by the Designating Party, a Receiving Party

may disclose any information or item designated “CONFIDENTIAL” only to:

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

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

disclose the information for this Action;

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

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

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

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

(d) the Court and its personnel;

(e) court reporters and their staff;

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

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

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

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

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

26 (h) during their depositions, witnesses, and attorneys for witnesses, in the

27 Action to whom disclosure is reasonably necessary provided: (1) the deposing party

28 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will not

1 be permitted to keep any confidential information unless they sign the

2 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed

3 by the Designating Party or ordered by the Court. Pages of transcribed deposition

4 testimony or exhibits to depositions that reveal Protected Material may be separately

5 bound by the court reporter and may not be disclosed to anyone except as permitted

6 under this Stipulated Protective Order; and

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

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

8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED

IN OTHER LITIGATION

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

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

“CONFIDENTIAL,” 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

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

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

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

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

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

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

3 from another court.

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

6 PRODUCED IN THIS LITIGATION

7 (a) The terms of this Order are applicable to information produced by a Non-Party

8 in this Action and designated as “CONFIDENTIAL.” Such information produced by

Non-Parties in connection with this litigation is protected by the remedies and relief

provided by this Order. Nothing in these provisions should be construed as prohibiting a

Non-Party from seeking additional protections.

(b) In the event that a Party is required, by a valid discovery request, to produce a

Non-Party’s confidential information in its possession, and the Party is subject to an

agreement with the Non-Party not to produce the Non-Party’s confidential information,

then the Party shall:

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

some or all of the information requested is subject to a confidentiality agreement with a

Non-Party;

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

Protective Order in this Action, the relevant discovery request(s), and a reasonably

specific description of the information requested; and

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

Party, if requested.

26 of receiving the notice and accompanying information, the Receiving Party may produce

27 the Non-Party’s confidential information responsive to the discovery request. If the

28 Non-Party timely seeks a protective order, the Receiving Party shall not produce any

1 information in its possession or control that is subject to the confidentiality agreement

2 with the Non-Party before a determination by the Court. Absent a court order to the

3 contrary, the Non-Party shall bear the burden and expense of seeking protection in this

4 Court of its Protected Material.

6 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

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

Stipulated 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 unauthorized disclosures were made of all the terms of this Order, and (d) request

such person or persons to execute the “Acknowledgment and Agreement to Be Bound”

that is attached hereto as Exhibit A.

11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

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 Federal Rule of Civil Procedure

26(b)(5)(B). 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 Federal Rule of Evidence 502(d) and (e), insofar as the parties reach

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

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

27 agreement in the stipulated protective order submitted to the Court.

1 12. MISCELLANEOUS

2 12.1 Right to Further Relief. Nothing in this Order abridges the right of any

3 person to seek its modification by the Court in the future.

4 12.2 Right to Assert Other Objections. By stipulating to the entry of this

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

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

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

8 ground to use in evidence of any of the material covered by this Protective Order.

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

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

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

Protected Material at issue; good cause must be shown in the request to file under seal.

If a Party’s request to file Protected Material under seal is denied by the Court, then the

Receiving Party may file the information in the public record unless otherwise instructed

by the Court.

13. FINAL DISPOSITION

After the final disposition of this Action, within 60 days of a written request by the

Designating Party, each Receiving Party must return all Protected Material to the

Producing Party or destroy such material. As used in this subdivision, “all Protected

Material” includes all copies, abstracts, compilations, summaries, and any other format

reproducing or capturing any of the Protected Material. Whether the Protected Material

is returned or destroyed, the Receiving Party must submit a written certification to the

Producing Party (and, if not the same person or entity, to the Designating Party) by the

26 60 day deadline that (1) identifies (by category, where appropriate) all the Protected

27 Material that was returned or destroyed, and (2) affirms that the Receiving Party has not

28 retained any copies, abstracts, compilations, summaries or any other format reproducing

1 capturing any of the Protected Material. Notwithstanding this provision, counsel <

2 || entitled to retain an archival copy of all pleadings, motion papers, trial, deposition, a

3 ||hearing transcripts, legal memoranda, correspondence, deposition and trial exhibi

4 || expert reports, attorney work product, and consultant and expert work product, even

> |/such materials contain Protected Material. Any such archival copies that contain

7 || Section 4 (DURATION).

|/14. VIOLATION OF ORDER

*0 Any violation of this Order may be punished by any and all appropriate □□□□□□

including, without limitation, contempt proceedings and/or monetary sanctions.

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

16 DATED: March 18, 2026.

/s/ Gregory Kirakosian

18 Attorneys for Plaintiff(s)

51 ||/DATED: March 18, 2026,

22 /s/ Molshree Gupta

23 || Attorneys for Defendant(s)

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

26 \ Q R: p

37 DATED: March 19, 2026

HON*A. JOEL RICHLIN

28 United States Magistrate Judge

1 EXHIBIT A

2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

4 I, _____________________________ [full name], of _________________ [full

5 address], declare under penalty of perjury that I have read in its entirety and understand

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

7 Central District of California on ____________ [date] in the case of

8 Fuentes v. Deputy Angel Blanco; Case Number 2:25-cv-12068-FLA-AJR.

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

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

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

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

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

of this 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 of this Stipulated

Protective Order, even if such enforcement proceedings occur after termination of this

action. I hereby appoint __________________________ [full name] of

_______________________________________ [full address and telephone number]

as my California agent for service of process in connection with this action or any

proceedings related to enforcement of this Stipulated Protective Order.

Date: ______________________________________

City and State where signed: _________________________________

26 Printed name: _______________________________

28 Signature: _________________________________

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.