# Opinion

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

URL: https://www.frixlaw.com/law-library/cases/11371188

## Case

- **Full name:** William Fuentes v. Deputy Angel Blanco; Doe Deputies 1 – 10
- **Court:** District Court, C.D. California
- **Decided:** March 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
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CENTRAL DISTRICT OF CALIFORNIA
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WILLIAM FUENTES, Case No.: 2:25-cv-12068-FLA (AJRx)
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13 [PROPOSED] STIPULATED
Plaintiff, PROTECTIVE ORDER
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15 Action Filed: December 22, 2025
v. Pretrial Conference: TBD
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Trial Date: TBD
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DEPUTY ANGEL BLANCO; and Assigned to:
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DOE DEPUTIES 1 – 10, Hon. Fernando L. Aenlle-Rocha
19 U.S. District Court Judge
20 Courtroom 6B
Defendants.
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23 1. GENERAL
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1.1 Purposes and Limitations. Discovery in this action is likely to involve
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production of confidential, proprietary, or private information for which special
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protection from public disclosure and from use for any purpose other than prosecuting
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this litigation may be warranted. Accordingly, the parties hereby stipulate to and petition
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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
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court to file material under seal.
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1.2 Good Cause Statement.
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In light of the nature of the claims and allegations in this case and the parties’
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representations that discovery in this case will involve the production of confidential
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records. The disclosure of the foregoing information to non-parties or others would be
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harmful to the parties' interests, including the involved and/or third parties. Therefore,
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this information must be protected from public dissemination and/or publication outside
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of this litigation.
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In order to expedite the flow of information, to facilitate the prompt resolution of
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disputes over confidentiality of discovery materials, to adequately protect information
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the parties are entitled to keep confidential, to ensure that the parties are permitted
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reasonable necessary uses of such material in connection with this action, to address
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their handling of such material at the end of the litigation, and to serve the ends of
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justice, a protective order for such information is justified in this matter. The parties
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shall not designate any information/documents as confidential without a good faith belief
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that such information/documents have been maintained in a confidential, non-public
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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.
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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
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Statement.
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2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their
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support staff).
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2.5 Designating Party: a Party or Non-Party that designates information or
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items that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.”
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2.6 Disclosure or Discovery Material: all items or information, regardless of
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the medium or manner in which it is generated, stored, or maintained (including, among
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other things, testimony, transcripts, and tangible things), that are produced or generated
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in disclosures or responses to discovery in this matter.
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2.7 Expert: a person with specialized knowledge or experience in a matter
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pertinent to the litigation who has been retained by a Party or its counsel to serve as an
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expert witness or as a consultant in this Action.
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2.8 House Counsel: attorneys who are employees of a party to this Action.
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House Counsel does not include Outside Counsel of Record or any other outside
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counsel.
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2.9 Non-Party: any natural person, partnership, corporation, association, or
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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
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services (e.g., photocopying, videotaping, translating, preparing exhibits or
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demonstrations, and organizing, storing, or retrieving data in any form or medium) and
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their employees and subcontractors.
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2.14 Protected Material: any Disclosure or Discovery Material that is designated
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as “CONFIDENTIAL.”
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2.15 Receiving Party: a Party that receives Disclosure or Discovery Material
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from a Producing Party.
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3. SCOPE
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The protections conferred by this Stipulation and Order cover not only Protected
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Material (as defined above), but also (1) any information copied or extracted from
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Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected
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Material; and (3) any testimony, conversations, or presentations by Parties or their
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Counsel that might reveal Protected Material.
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Any use of Protected Material at trial shall be governed by the orders of the trial
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judge. This Order does not govern the use of Protected Material at trial.
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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.
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5. DESIGNATING PROTECTED MATERIAL
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5.1 Exercise of Restraint and Care in Designating Material for Protection. Each
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Party or Non-Party that designates information or items for protection under this Order
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must take care to limit any such designation to specific material that qualifies under the
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appropriate standards. The Designating Party must designate for protection only those
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parts of material, documents, items, or oral or written communications that qualify so
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that other portions of the material, documents, items, or communications for which
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protection is not warranted are not swept unjustifiably within the ambit of this Order.
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Mass, indiscriminate, or routinized designations are prohibited. Designations that
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are shown to be clearly unjustified or that have been made for an improper purpose (e.g.,
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to unnecessarily encumber the case development process or to impose unnecessary
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expenses and burdens on other parties) may expose the Designating Party to sanctions.
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If it comes to a Designating Party’s attention that information or items that it
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designated for protection do not qualify for protection, that Designating Party must
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promptly notify all other Parties that it is withdrawing the inapplicable designation.
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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
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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
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Producing Party also must clearly identify the protected portion(s) (e.g., by making
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appropriate markings in the margins).
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A Party or Non-Party that makes original documents available for inspection need
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not designate them for protection until after the inspecting Party has indicated which
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documents it would like copied and produced. During the inspection and before the
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designation, all of the material made available for inspection shall be deemed
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“CONFIDENTIAL.” After the inspecting Party has identified the documents it wants
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copied and produced, the Producing Party must determine which documents, or portions
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thereof, qualify for protection under this Order. Then, before producing the specified
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documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page
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that contains Protected Material. If only a portion or portions of the material on a page
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qualifies for protection, the Producing Party also must clearly identify the protected
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portion(s) (e.g., by making appropriate markings in the margins).
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(b) for testimony given in depositions that the Designating Party identify
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the Disclosure or Discovery Material on the record, before the close of the deposition.
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(c) for information produced in some form other than documentary and for
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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.
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6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
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6.1 Timing of Challenges. Any Party or Non-Party may challenge a
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designation of confidentiality at any time that is consistent with the Court’s Scheduling
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Order.
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6.2 Meet and Confer. The Challenging Party shall initiate the dispute
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resolution process under Local Rule 37-1, et seq. Any discovery motion must strictly
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comply with the procedures set forth in Local Rules 37-1, 37-2, and 37-3.
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6.3 Burden. The burden of persuasion in any such challenge proceeding shall
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be on the Designating Party. Frivolous challenges, and those made for an improper
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purpose (e.g., to harass or impose unnecessary expenses and burdens on other parties)
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may expose the Challenging Party to sanctions. Unless the Designating Party has
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waived or withdrawn the confidentiality designation, all parties shall continue to afford
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the material in question the level of protection to which it is entitled under the Producing
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Party’s designation until the Court rules on the challenge.
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7. ACCESS TO AND USE OF PROTECTED MATERIAL
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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
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may disclose any information or item designated “CONFIDENTIAL” only to:
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(a) the Receiving Party’s Outside Counsel of Record in this Action, as well
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as employees of said Outside Counsel of Record to whom it is reasonably necessary to
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disclose the information for this Action;
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(b) the officers, directors, and employees (including House Counsel) of the
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Receiving Party to whom disclosure is reasonably necessary for this Action;
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(c) Experts (as defined in this Order) of the Receiving Party to whom
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disclosure is reasonably necessary for this Action and who have signed the
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“Acknowledgment and Agreement to Be Bound” (Exhibit A);
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(d) the Court and its personnel;
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(e) court reporters and their staff;
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(f) professional jury or trial consultants, mock jurors, and Professional
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Vendors to whom disclosure is reasonably necessary for this Action and who have
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signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
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(g) the author or recipient of a document containing the information or a
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custodian or other person who otherwise possessed or knew the information;
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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.
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8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
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IN OTHER LITIGATION
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If a Party is served with a subpoena or a court order issued in other litigation that
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compels disclosure of any information or items designated in this Action as
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“CONFIDENTIAL,” that Party must:
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(a) promptly notify in writing the Designating Party. Such notification shall
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include a copy of the subpoena or court order;
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(b) promptly notify in writing the party who caused the subpoena or order to issue
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in the other litigation that some or all of the material covered by the subpoena or order is
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subject to this Protective Order. Such notification shall include a copy of this Stipulated
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Protective Order; and
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(c) cooperate with respect to all reasonable procedures sought to be pursued by
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the Designating Party whose Protected Material may be affected.
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If the Designating Party timely seeks a protective order, the Party served with the
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subpoena or court order shall not produce any information designated in this action as
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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.
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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
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Non-Parties in connection with this litigation is protected by the remedies and relief
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provided by this Order. Nothing in these provisions should be construed as prohibiting a
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Non-Party from seeking additional protections.
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(b) In the event that a Party is required, by a valid discovery request, to produce a
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Non-Party’s confidential information in its possession, and the Party is subject to an
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agreement with the Non-Party not to produce the Non-Party’s confidential information,
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then the Party shall:
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(1) promptly notify in writing the Requesting Party and the Non-Party that
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some or all of the information requested is subject to a confidentiality agreement with a
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Non-Party;
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(2) promptly provide the Non-Party with a copy of the Stipulated
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Protective Order in this Action, the relevant discovery request(s), and a reasonably
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specific description of the information requested; and
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(3) make the information requested available for inspection by the Non-
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Party, if requested.
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(c) If the Non-Party fails to seek a protective order from this Court within 14 days
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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.
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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
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Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing
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the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve
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all unauthorized copies of the Protected Material, (c) inform the person or persons to
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whom unauthorized disclosures were made of all the terms of this Order, and (d) request
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such person or persons to execute the “Acknowledgment and Agreement to Be Bound”
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that is attached hereto as Exhibit A.
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11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
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PROTECTED MATERIAL
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When a Producing Party gives notice to Receiving Parties that certain
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inadvertently produced material is subject to a claim of privilege or other protection, the
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obligations of the Receiving Parties are those set forth in Federal Rule of Civil Procedure
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26(b)(5)(B). This provision is not intended to modify whatever procedure may be
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established in an e-discovery order that provides for production without prior privilege
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review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the parties reach
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an agreement on the effect of disclosure of a communication or information covered by
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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.
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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.
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12.3 Filing Protected Material. A Party that seeks to file under seal any
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Protected Material must comply with Civil Local Rule 79-5. Protected Material may
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only be filed under seal pursuant to a court order authorizing the sealing of the specific
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Protected Material at issue; good cause must be shown in the request to file under seal.
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If a Party’s request to file Protected Material under seal is denied by the Court, then the
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Receiving Party may file the information in the public record unless otherwise instructed
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by the Court.
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13. FINAL DISPOSITION
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After the final disposition of this Action, within 60 days of a written request by the
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Designating Party, each Receiving Party must return all Protected Material to the
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Producing Party or destroy such material. As used in this subdivision, “all Protected
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Material” includes all copies, abstracts, compilations, summaries, and any other format
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reproducing or capturing any of the Protected Material. Whether the Protected Material
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is returned or destroyed, the Receiving Party must submit a written certification to the
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Producing Party (and, if not the same person or entity, to the Designating Party) by the
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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
© constitute Protected Material remain subject to this Protective Order as set forth
7 || Section 4 (DURATION).
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|/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.

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16 DATED: March 18, 2026.
/s/ Gregory Kirakosian

18 Attorneys for Plaintiff(s)
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51 ||/DATED: March 18, 2026,
22 /s/ Molshree Gupta
23 || Attorneys for Defendant(s)
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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
3
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.
9
I agree to comply with and to be bound by all the terms of this Stipulated Protective
10
Order and I 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 will not
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disclose in any manner any information or item that is subject to this Stipulated
13
Protective Order to any person or entity except in strict compliance with the provisions
14
of this Order.
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I further agree to submit to the jurisdiction of the United States District Court for
16
the Central District of California for the purpose of enforcing the terms of this Stipulated
17
Protective Order, even if such enforcement proceedings occur after termination of this
18
action. I hereby appoint __________________________ [full name] of
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_______________________________________ [full address and telephone number]
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as my California agent for service of process in connection with this action or any
21
proceedings related to enforcement of this Stipulated Protective Order.
22
Date: ______________________________________
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City and State where signed: _________________________________
24

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26 Printed name: _______________________________
27
28 Signature: _________________________________

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/11371188. Public record. Not legal advice.