The opinion
1 Thomas J. Ryu, Esq. [SB# 155749]
tom@ryuyunlaw.com
2 S. Nathan Yun [SB# 316821]
nathan@ryuyunlaw.com
3 Ryu & Yun, LLP
3435 Wilshire Boulevard, Suite 2050
4 Los Angeles, California 90010
Tel: (213) 380-9200
5 Fax: (213) 380-9302
6 Attorneys for Plaintiff,
ALEJANDRO HERNANDEZ
7
8 Angela M. Powel, SBN 191876
amp@jones-mayer.com
9 Helen O. Kim, Esq., SBN 254560
hok@jones-mayer.com
10 JONES MAYER
3777 North Harbor Boulevard
11 Fullerton, CA 92835
Telephone: (714) 446-1400
12 Facsimile: (714) 446-1448
13 Attorneys for Defendants,
County of Los Angeles, Deputy Corona,
14 Deputy Trejo, Deputy Lozano, and
Deputy Tamayo
15
16
UNITED STATES DISTRICT COURT
17
CENTRAL DISTRICT OF CALIFORNIA
18
19 ALEJANDRO HERNANDEZ, Case No. 2:25-cv-10166 AB (MARx)
20 Plaintiff, District Judge: Andre Birotte Jr.
Magistrate Judge: Margo A. Rocconi
21 v.
STIPULATED PROTECTIVE
22 COUNTY OF LOS ANGELES, a public ORDER
entity; DEPUTY CORONA #639073 an
23 individual; DEPUTY TREJO #552627, Action Filed: October 22, 2025
an individual; DEPUTY LOZANO
24 #639905, and individual; DEPUTY
TAMAYO #628715, an individual; and
25 DOES 1 through 10,
26 Defendants.
27
1 1. INTRODUCTION
2 1.1 PURPOSES AND LIMITATIONS
3 Discovery in this action is likely to involve production of confidential,
4 proprietary, or private information for which special protection from public
5 disclosure and from use for any purpose other than prosecuting this litigation
6 may be warranted. Accordingly, the parties hereby stipulate to and petition the
7 Court to enter the following Stipulated Protective Order. The parties
8 acknowledge that this Order does not confer blanket protections on all
9 disclosures or responses to discovery and that the protection it affords from
10 public disclosure and use extends only to the limited information or items that
11 are entitled to confidential treatment under the applicable legal principles. The
12 parties further acknowledge, as set forth in Section 12.3, below, that this
13 Stipulated Protective Order does not entitle them to file confidential
14 information under seal; Civil Local Rule 79-5 sets forth the procedures that
15 must be followed and the standards that will be applied when a party seeks
16 permission from the court to file material under seal
17 1.2 GOOD CAUSE STATEMENT
18
This action is likely to involve discovery that is confidential and
19
privileged for which special protection from public disclosure and from use for
20
any purpose other than prosecution of this action may be warranted. Such
21
confidential and proprietary materials and information consist of, among other
22
things, information pertaining to the investigation from Los Angeles County
23
Sheriff’s Department (LACSD) of the underlying criminal activities, as well as
24
peace officer personnel file information and/or documents which the parties
25
agree include (1) Personal data, including marital status, family members,
26
educational and employment history, home addresses, or similar information;
27
(2) Medical history; (3) Election of employee benefits; (4) Employee
1 advancement, appraisal or discipline; and (5) Complaints, or investigations of
2 complaints, if any, concerning an event or transaction in which a peace officer
3 participated, or which a peace officer perceived, and pertaining to the manner
4 in which the peace officer performed his or her duties.
5 Such confidential materials and information consist of, among other
6 things, materials which may be entitled to privileges and/or protections under
7 the following: United States Constitution, First Amendment; the California
8 Constitution, Article I, Section 1; California Penal Code §§ 832.5, 832.7 and
9 832.8; California Evidence Code §§ 1040 and 1043 et. seq; the Privacy Act of
10 1974, 5 U.S.C. § 552; Health Insurance Portability and Accountability Act of
11 1996 (HIPPA); the right to privacy; decisional law relating to such provisions;
12 and information otherwise generally unavailable to the public, or which may be
13 privileged or otherwise protected from disclosure under state or federal statutes,
14 court rules, case decisions, or common law.
15 Defendants also contend that such confidential materials and
16 information are entitled to the Official Information Privilege. Sanchez v. City
17 of Santa Ana, 936 F.2d 1027, 1033 (9th Cir. Cal.1990); see also Kerr v. United
18 States Dist. Ct. for N.D. Cal., 511 F.2d 192, 198 (9th Cir. Cal. 1975). Aff’d, 426
19 U.S. 394, 96 S. Ct. 3229, 48 L.Ed.2d 725 (1976). The information otherwise may
20 be generally unavailable to the public, or may be privileged or otherwise
21 protected from disclosure under state or federal statutes, court rules, case
22 decisions, or common law.
23 Further, discovery may require depositions, written discovery and/or
24 the production of certain information the public disclosure of which could
25 comprise officer safety, and/or raise security issues. Additionally, public
26 disclosure of such information poses a substantial risk of embarrassment,
27 oppression, and/or physical harm to peace officers whose confidential
1 other government employees due to the nature of their profession. The benefit
2 of public disclosure of confidential information is minimal while the potential
3 disadvantages are great.
4 Accordingly, to expedite the flow of information, to facilitate the prompt
5 resolution of disputes over confidentiality of discovery materials, to adequately
6 protect information the parties are entitled to keep confidential, to ensure that
7 the parties are permitted reasonable necessary uses of such material in
8 preparation for and in the conduct of trial, to address their handling at the end
9 of the litigation, and serve the ends of justice, a protective order for such
10 information is justified in this matter. It is the intent of the parties that
11 information will not be designated as confidential for tactical reasons and that
12 nothing be so designated without a good faith belief that it has been maintained
13 in a confidential, non-public manner, and there is good cause why it should not
14 be part of the public record of this case.
15
16 2. DEFINITIONS
17 2.1 Action: Alejandro Hernandez v County of Los Angeles, a public
18 entity; Deputy Corona #639073 an individual; Deputy Trejo #552627, an
19 individual; Deputy Lozano #639905, an individual; Deputy Tamayo #628715, an
20 individual; and Does 1 through 10.
21 2.2 Challenging Party: a Party or Non-Party that challenges the
22 designation of information or items under this Order.
23 2.3 “CONFIDENTIAL” Information or Items: information (regardless
24 of how it is generated, stored or maintained) or tangible things that qualify for
25 protection under Federal Rule of Civil Procedure 26(c), and as specified above
26 in the Good Cause Statement.
27 2.4 Counsel: Outside Counsel of Record and House Counsel (as well
1 2.5 Designating Party: a Party or Non-Party that designates
2 information or items that it produces in disclosures or in responses to discovery
3 as “CONFIDENTIAL.”
4 2.6 Disclosure or Discovery Material: all items or information,
5 regardless of the medium or manner in which it is generated, stored, or
6 maintained (including, among other things, testimony, transcripts, and tangible
7 things), that are produced or generated in disclosures or responses to discovery
8 in this matter.
9 2.7 Expert: a person with specialized knowledge or experience in a
10 matter pertinent to the litigation who has been retained by a Party or its counsel
11 to serve as an expert witness or as a consultant in this Action.
12 2.8 House Counsel: attorneys who are employees of a party to this
13 Action. House Counsel does not include Outside Counsel of Record or any other
14 outside counsel.
15 2.9 Non-Party: any natural person, partnership, corporation,
16 association, or other legal entity not named as a Party to this action.
17 2.10 Outside Counsel of Record: attorneys who are not employees of a
18 party to this Action but are retained to represent or advise a party to this Action
19 and have appeared in this Action on behalf of that party or are affiliated with a
20 law firm which has appeared on behalf of that party, and includes support staff.
21 2.11 Party: any party to this Action, including all of its officers,
22 directors, employees, consultants, retained experts, and Outside Counsel of
23 Record (and their support staffs).
24 2.12 Producing Party: a Party or Non-Party that produces Disclosure
25 or Discovery Material in this Action.
26 2.13 Professional Vendors: persons or entities that provide litigation
27 support services (e.g., photocopying, videotaping, translating, preparing
1 form or medium) and their employees and subcontractors.
2 2.14 Protected Material: any Disclosure or Discovery Material that is
3 designated as “CONFIDENTIAL.”
4 2.15 Receiving Party: a Party that receives Disclosure or Discovery
5 Material from a Producing Party.
6
7 3. SCOPE
8 The protections conferred by this Stipulation and Order cover not only
9 Protected Material (as defined above), but also (1) any information copied or
10 extracted from Protected Material; (2) all copies, excerpts, summaries, or
11 compilations of Protected Material; and (3) any testimony, conversations, or
12 presentations by Parties or their Counsel that might reveal Protected Material.
13 Any use of Protected Material at trial will be governed by the orders of the trial
14 judge. This Order does not govern the use of Protected Material at trial.
15
16 4. DURATION
17 Once a case proceeds to trial, all of the information that was designated
18 as confidential or maintained pursuant to this protective order becomes public
19 and will be presumptively available to all members of the public, including the
20 press, unless compelling reasons supported by specific factual findings to
21 proceed otherwise are made to the trial judge in advance of the trial. See
22 Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1180–81 (9th Cir.
23 2006) (distinguishing “good cause” showing for sealing documents produced in
24 discovery from “compelling reasons” standard when merits-related documents
25 are part of court record). Accordingly, the terms of this protective order do not
26 extend beyond the commencement of the trial.
27 Even after final disposition of this litigation, the confidentiality
1 agrees otherwise in writing or a court order otherwise directs. Final disposition
2 will be deemed to be the later of (1) dismissal of all claims and defenses in this
3 Action, with or without prejudice; and (2) final judgment herein after the
4 completion and exhaustion of all appeals, rehearings, remands, trials, or
5 reviews of this Action, including the time limits for filing any motions or
6 applications for extension of time pursuant to applicable law.
7
8 5. DESIGNATING PROTECTED MATERIAL
9 5.1 Exercise of Restraint and Care in Designating Material for
10 Protection. Each Party or Non-Party that designates information or items for
11 protection under this Order must take care to limit any such designation to
12 specific material that qualifies under the appropriate standards. The
13 Designating Party must designate for protection only those parts of material,
14 documents, items, or oral or written communications that qualify so that other
15 portions of the material, documents, items, or communications for which
16 protection is not warranted are not swept unjustifiably within the ambit of this
17 Order. Mass, indiscriminate, or routinized designations are prohibited.
18 Designations that are shown to be clearly unjustified or that have been made
19 for an improper purpose (e.g., to unnecessarily encumber the case development
20 process or to impose unnecessary expenses and burdens on other parties) may
21 expose the Designating Party to sanctions. If it comes to a Designating Party’s
22 attention that information or items that it designated for protection do not
23 qualify for protection, that Designating Party must promptly notify all other
24 Parties that it is withdrawing the inapplicable designation.
25 5.2 Manner and Timing of Designations. Except as otherwise
26 provided in this Order (see, e.g., second paragraph of section 5.2(a) below), or as
27 otherwise stipulated or ordered, Disclosure or Discovery Material that qualifies
1 is disclosed or produced. Designation in conformity with this Order requires:
2 (a) for information in documentary form (e.g., paper or electronic
3 documents, but excluding transcripts of depositions or other pretrial or trial
4 proceedings), that the Producing Party affix at a minimum, the legend
5 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
6 contains protected material. If only a portion or portions of the material on a
7 page qualifies for protection, the Producing Party also must clearly identify the
8 protected portion(s) (e.g., by making appropriate markings in the margins). A
9 Party or Non-Party that makes original documents available for inspection need
10 not designate them for protection until after the inspecting Party has indicated
11 which documents it would like copied and produced. During the inspection and
12 before the designation, all of the material made available for inspection will be
13 deemed “CONFIDENTIAL.” After the inspecting Party has identified the
14 documents it wants copied and produced, the Producing Party must determine
15 which documents, or portions thereof, qualify for protection under this Order.
16 Then, before producing the specified documents, the Producing Party must affix
17 the “CONFIDENTIAL legend” to each page that contains Protected Material. If
18 only a portion or portions of the material on a page qualifies for protection, the
19 Producing Party also must clearly identify the protected portion(s) (e.g., by
20 making appropriate markings in the margins).
21 (b) for testimony given in depositions that the Designating Party
22 identify the Disclosure or Discovery Material on the record, before the close of
23 the deposition all protected testimony.
24 (c) for information produced in some form other than documentary and
25 for any other tangible items, that the Producing Party affix in a prominent place
26 on the exterior of the container or containers in which the information is stored
27 the legend “CONFIDENTIAL.” If only a portion or portions of the information
1 the protected portion(s).
2 5.3 Inadvertent Failures to Designate. If timely corrected, an
3 inadvertent failure to designate qualified information or items does not,
4 standing alone, waive the Designating Party’s right to secure protection under
5 this Order for such material. Upon timely correction of a designation, the
6 Receiving Party must make reasonable efforts to assure that the material is
7 treated in accordance with the provisions of this Order.
8
9 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
10 6.1 Timing of Challenges. Any Party or Non-Party may challenge
11 a designation of confidentiality at any time that is consistent with the Court’s
12 Scheduling Order.
13 6.2 Meet and Confer. The Challenging Party will initiate the
14 dispute resolution process under Local Rule 37.1 et seq. 6.3 The burden of
15 persuasion in any such challenge proceeding will be on the Designating Party.
16 Frivolous challenges, and those made for an improper purpose (e.g., to harass
17 or impose unnecessary expenses and burdens on other parties) may expose the
18 Challenging Party to sanctions. Unless the Designating Party has waived or
19 withdrawn the confidentiality designation, all parties will continue to afford the
20 material in question the level of protection to which it is entitled under the
21 Producing Party’s designation until the Court rules on the challenge.
22
23 7. ACCESS TO AND USE OF PROTECTED MATERIAL
24 7.1 Basic Principles. A Receiving Party may use Protected Material
25 that is disclosed or produced by another Party or by a Non-Party in connection
26 with this Action only for prosecuting, defending, or attempting to settle this
27 Action. Such Protected Material may be disclosed only to the categories of
1 been terminated, a Receiving Party must comply with the provisions of section
2 13 below (FINAL DISPOSITION). Protected Material must be stored and
3 maintained by a Receiving Party at a location and in a secure manner that
4 ensures that access is limited to the persons authorized under this Order.
5 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
6 otherwise ordered by the court or permitted in writing by the Designating Party,
7 a Receiving Party may disclose any information or item designated
8 “CONFIDENTIAL” only to:
9 (a) the Receiving Party’s Outside Counsel of Record in this Action, as
10 well as employees of said Outside Counsel of Record to whom it is reasonably
11 necessary to disclose the information for this Action;
12 (b) the officers, directors, and employees (including House Counsel) of
13 the Receiving Party to whom disclosure is reasonably necessary for this Action;
14 (c) Experts (as defined in this Order) of the Receiving Party to whom
15 disclosure is reasonably necessary for this Action and who have signed the
16 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
17 (d) the Court and its personnel;
18 (e) court reporters and their staff;
19 (f) professional jury or trial consultants, mock jurors, and Professional
20 Vendors to whom disclosure is reasonably necessary for this Action and who
21 have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
22 (g) the author or recipient of a document containing the information or
23 a custodian or other person who otherwise possessed or knew the information;
24 (h) during their depositions, witnesses, and attorneys for witnesses, in
25 the Action to whom disclosure is reasonably necessary provided: (1) the deposing
26 party requests that the witness sign the form attached as Exhibit A hereto; and
27 (2) they will not be permitted to keep any confidential information unless they
1 otherwise agreed by the Designating Party or ordered by the court. Pages of
2 transcribed deposition testimony or exhibits to depositions that reveal Protected
3 Material may be separately bound by the court reporter and may not be
4 disclosed to anyone except as permitted under this Stipulated Protective Order;
5 and
6 (i) any mediator or settlement officer, and their supporting personnel,
7 mutually agreed upon by any of the parties engaged in settlement discussions.
8
9 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
10 PRODUCED IN OTHER LITIGATION
11 If a Party is served with a subpoena or a court order issued in other
12 litigation that compels disclosure of any information or items designated in this
13 Action as “CONFIDENTIAL,” that Party must:
14 (a) promptly notify in writing the Designating Party. Such notification
15 will include a copy of the subpoena or court order;
16 (b) promptly notify in writing the party who caused the subpoena or
17 order to issue in the other litigation that some or all of the material covered by
18 the subpoena or order is subject to this Protective Order. Such notification will
19 include a copy of this Stipulated Protective Order; and
20 (c) cooperate with respect to all reasonable procedures sought to be
21 pursued by the Designating Party whose Protected Material may be affected. If
22 the Designating Party timely seeks a protective order, the Party served with the
23 subpoena or court order will not produce any information designated in this
24 action as “CONFIDENTIAL” before a determination by the court from which
25 the subpoena or order issued, unless the Party has obtained the Designating
26 Party’s permission. The Designating Party will bear the burden and expense of
27 seeking protection in that court of its confidential material and nothing in these
1 in this Action to disobey a lawful directive from another court.
2
3 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
4 PRODUCED IN THIS LITIGATION
5 (a) The terms of this Order are applicable to information produced by
6 a Non-Party in this Action and designated as “CONFIDENTIAL.” Such
7 information produced by Non-Parties in connection with this litigation is
8 protected by the remedies and relief provided by this Order. Nothing in these
9 provisions should be construed as prohibiting a Non-Party from seeking
10 additional protections.
11 (b) In the event that a Party is required, by a valid discovery request,
12 to produce a Non-Party’s confidential information in its possession, and the
13 Party is subject to an agreement with the Non-Party not to produce the Non-
14 Party’s confidential information, then the Party will:
15 (1) promptly notify in writing the Requesting Party and the Non-
16 Party that some or all of the information requested is subject to a confidentiality
17 agreement with a Non-Party;
18 (2) promptly provide the Non-Party with a copy of the Stipulated
19 Protective Order in this Action, the relevant discovery request(s), and a
20 reasonably specific description of the information requested; and
21 (3) make the information requested available for inspection by the
22 Non-Party, if requested.
23 (c) If the Non-Party fails to seek a protective order from this court
24 within 14 days of receiving the notice and accompanying information, the
25 Receiving Party may produce the Non-Party’s confidential information
26 responsive to the discovery request. If the Non-Party timely seeks a protective
27 order, the Receiving Party shall not produce any information in its possession
1 before a determination by the court. Absent a court order to the contrary, the
2 Non-Party shall bear the burden and expense of seeking protection in this court
3 of its Protected Material.
4
5 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
6 If a Receiving Party learns that, by inadvertence or otherwise, it has
7 disclosed Protected Material to any person or in any circumstance not
8 authorized under this Stipulated Protective Order, the Receiving Party must
9 immediately (a) notify in writing the Designating Party of the unauthorized
10 disclosures, (b) use its best efforts to retrieve all unauthorized copies of the
11 Protected Material, (c) inform the person or persons to whom unauthorized
12 disclosures were made of all the terms of this Order, and (d) request such person
13 or persons to execute the “Acknowledgment and Agreement to Be Bound” that
14 is attached hereto as Exhibit A.
15
16 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
17 PROTECTED MATERIAL
18 When a Producing Party gives notice to Receiving Parties that certain
19 inadvertently produced material is subject to a claim of privilege or other
20 protection, the obligations of the Receiving Parties are those set forth in Federal
21 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify
22 whatever procedure may be established in an e-discovery order that provides for
23 production without prior privilege review. Pursuant to Federal Rule of Evidence
24 502(d) and (e), insofar as the parties reach an agreement on the effect of
25 disclosure of a communication or information covered by the attorney-client
26 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
3 right of any 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
5 this Protective Order no Party waives any right it otherwise would have to object
6 to disclosing or producing any information or item on any ground not addressed
7 in this Stipulated Protective Order. Similarly, no Party waives any right to
8 object on any ground to use in evidence of any of the material covered by this
9 Protective Order.
10 12.3 Filing Protected Material. A Party that seeks to file under seal
11 any Protected Material must comply with Civil Local Rule 79-5. Protected
12 Material may only be filed under seal pursuant to a court order authorizing the
13 sealing of the specific Protected Material at issue. If a Party’s request to file
14 Protected Material under seal is denied by the court, then the Receiving Party
15 may file the information in the public record unless otherwise instructed by the
16 court.
17
18 13. FINAL DISPOSITION
19 After the final disposition of this Action, as defined in paragraph 4,
20 within 60 days of a written request by the Designating Party, each Receiving
21 Party must return all Protected Material to the Producing Party or destroy such
22 material. As used in this subdivision, “all Protected Material” includes all
23 copies, abstracts, compilations, summaries, and any other format reproducing
24 or capturing any of the Protected Material. Whether the Protected Material is
25 returned or destroyed, the Receiving Party must submit a written certification
26 to the Producing Party (and, if not the same person or entity, to the Designating
27 Party) by the 60 day deadline that (1) identifies (by category, where appropriate)
1 || the Receiving Party has not retained any copies, abstracts, compilations,
2 || summaries or any other format reproducing or capturing any of the Protected
3 || Material. Notwithstanding this provision, Counsel are entitled to retain an
4 || archival copy of all pleadings, motion papers, trial, deposition, and hearing
5 || transcripts, legal memoranda, correspondence, deposition and trial exhibits,
6 || expert reports, attorney work product, and consultant and expert work product,
7 || even if such materials contain Protected Material. Any such archival copies that
8 || contain or constitute Protected Material remain subject to this Protective Order
9 || as set forth in Section 4 (DURATION).
10 14. Any willful violation of this Order may be punished by civil or criminal
11 || contempt proceedings, financial or evidentiary sanctions, reference to
12 || disciplinary authorities, or other appropriate action at the discretion of the
13 || Court.
14
15 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD.
16
17
13 DATED: March 31, 2026
19
20
DATED: March 31, 2026 s/ Helen O. Kim
21 Attorneys for Defendant
22
23 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
24
2 4/13/26 JAX
26 pA HON. MARGO A.ROCCONI □
57 United States Magistrate Judge
28
1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3
4 I, _____________________________ [print or type full name], of _________________
5 [print or type full address], declare under penalty of perjury that I have read in
6 its entirety and understand the Protective Order that was issued by the United
7 States District Court for the Central District of California on
8 _________________________ in the case of
9 _____________________________________. I agree to comply with and to be
10 bound by all the terms of this Protective Order and I understand and
11 acknowledge that failure to so comply could expose me to sanctions and
12 punishment in the nature of contempt. I solemnly promise that I will not
13 disclose in any manner any information or item that is subject to this Protective
14 Order to any person or entity except in strict compliance with the provisions of
15 this Order.
16 I further agree to submit to the jurisdiction of the United States District
17 Court for the Central District of California for the purpose of enforcing the terms
18 of this Protective Order, even if such enforcement proceedings occur after
19 termination of this action. I hereby appoint __________________________ [print
20 or type full name] of _______________________________________ [print or type
21 full address and telephone number] as my California agent for service of process
22 in connection with this action or any proceedings related to enforcement of this
23 Protective Order.
24 Date: ______________________________________
25 City and State where sworn and signed: _________________________________
26
27 Printed name: _______________________________