# Opinion > District Court, C.D. California · June 1, 2026 URL: https://www.frixlaw.com/law-library/cases/11382841 ## Case - **Full name:** Felix Espinoza, an individual and successor-in-interest to Sierra Rose Vanatta v. County of Orange, Anthony Magdaleno, an individual; and Does 1 through 10, inclusive - **Court:** District Court, C.D. California - **Decided:** June 1, 2026 - **Opinion:** 100trialcourt - **Cited by:** 0 later opinions in the Frix Law Library ## Citator (automated) - No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases. - Full citator and citing cases: https://www.frixlaw.com/law-library/cases/11382841 ## Opinion text 1 JESSE K. COX – SBN 285218 jcox@lynberg.com 2 GARROS CHAN – SBN 320561 gchan@lynberg.com 3 LYNBERG & WATKINS A Professional Corporation 4 1100 W. Town & Country Road, Suite #1450 Orange, California 92868 5 (714) 937-1010 Telephone (714) 937-1003 Facsimile 6 Attorneys for Defendants COUNTY OF ORANGE 7 and ANTHONY MAGDALENO 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA – SANTA ANA 10 11 FELIX ESPINOZA, an individual and CASE NO. 8:24-cv-02120-AH-DFM successor-in-interest to SIERRA ROSE 12 VANATTA, Assigned to: Honorable Anne Hwang Dept. 7D 13 Plaintiff, STIPULATED PROTECTIVE 14 vs. ORDER 15 COUNTY OF ORANGE, ANTHONY DISCOVERY MATTER MAGDALENO, an individual; and 16 DOES 1 through 10, inclusive, Second Amended Complaint Filed: March 27, 2025 17 Defendants. Trial Date: December 8, 2026 18 19 Defendants COUNTY OF ORANGE and ANTHONY MAGDALENO 20 (collectively, “Defendants”), by through their attorneys of record, Lynberg & 21 Watkins, P. C., and Plaintiff FELIX ESPINOZA, individually and as a successor in 22 interest to SIERRA ROSE VANATTA, by and through their attorneys of record, 23 Skapik Law Group, hereby stipulate, as follows: 24 1. A. PURPOSES AND LIMITATIONS 25 Discovery in this action is likely to involve production of confidential, 26 proprietary, or private information for which special protection from public 27 disclosure and from use for any purpose other than prosecuting this litigation may 1 enter the following Stipulated Protective Order. The parties acknowledge that this 2 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 4 only to the limited information or items that are entitled to confidential treatment 5 under the applicable legal principles. The parties further acknowledge, as set forth in 6 Section 12.3, below, that this Stipulated Protective Order does not entitle them to 7 file confidential information under seal; Civil Local Rule 79-5 sets forth the 8 procedures that must be followed and the standards that will be applied when a party 9 seeks permission from the court to file material under seal. 10 B. GOOD CAUSE STATEMENT 11 This action is likely to involve information which one or more of the parties 12 contend special protection from use for any purpose other than litigation in this 13 action is warranted. Defendants contend that such confidential information 14 includes video footage and/or photographs from within County of Orange jail 15 facilities containing information pertaining to third parties that are not parties to this 16 lawsuit, and/or containing images of third parties that are not parties to this lawsuit. 17 Such confidential information may also include documents that contain personal and 18 confidential information regarding individuals which information is generally 19 unavailable to the public, including peace officer and/or County employee personnel 20 records. The disclosure of this information to the public may violate these 21 individuals’ privacy rights, and its disclosure may impact the County Sheriff’s 22 Department’s operations and safety. Good cause therefore exists for designating 23 these materials as confidential for Defendants, its employees, and officials to protect 24 government interests, as well as the privacy rights of third parties not subject to this 25 litigation. Accordingly, to expedite the flow of information, to facilitate the prompt 26 resolution of disputes over confidentiality of discovery materials, to adequately 27 protect information the parties are entitled to keep confidential, to ensure that the 1 and in the conduct of trial, to address their handling at the end of the litigation, and 2 serve the ends of justice, a protective order for such information is justified in this 3 matter. It is the intent of the parties that information will not be designated as 4 confidential for tactical reasons and that nothing be so designated without a good 5 faith belief that it has been maintained in a confidential, non-public manner, and 6 there is good cause why it should not be part of the public record of this case. 7 2. DEFINITIONS 8 2.1 Action: This pending federal law suit. 9 2.2 Challenging Party: a Party or Non-Party that challenges the designation 10 of information or items under this Order. 11 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 12 how it is generated, stored or maintained) or tangible things that qualify for 13 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 14 the Good Cause Statement. 15 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 16 support staff). 17 2.5 Designating Party: a Party or Non-Party that designates information or 18 items that it produces in disclosures or in responses to discovery as 19 “CONFIDENTIAL.” 20 2.6 Disclosure or Discovery Material: all items or information, regardless of 21 the medium or manner in which it is generated, stored, or maintained (including, 22 among other things, testimony, transcripts, and tangible things), that are produced or 23 generated in disclosures or responses to discovery in this matter. 24 2.7 Expert: a person with specialized knowledge or experience in a matter 25 pertinent to the litigation who has been retained by a Party or its counsel to serve as 26 an expert witness or as a consultant in this Action. 27 2.8 House Counsel: attorneys who are employees of a party to this Action. 1 counsel. 2 2.9 Non-Party: any natural person, partnership, corporation, association, or 3 other legal entity not named as a Party to this action. 4 2.10 Outside Counsel of Record: attorneys who are not employees of a party 5 to this Action but are retained to represent or advise a party to this Action and have 6 appeared in this Action on behalf of that party or are affiliated with a law firm which 7 has appeared on behalf of that party, and includes support staff. 8 2.11 Party: any party to this Action, including all of its officers, directors, 9 employees, consultants, retained experts, and Outside Counsel of Record (and their 10 support staffs). 11 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 12 Discovery Material in this Action. 13 2.13 Professional Vendors: persons or entities that provide litigation support 14 services (e.g., photocopying, videotaping, translating, preparing exhibits or 15 demonstrations, and organizing, storing, or retrieving data in any form or medium) 16 and their employees and subcontractors. 17 2.14 Protected Material: any Disclosure or Discovery Material that is 18 designated as “CONFIDENTIAL.” 19 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 20 from a Producing Party. 21 3. SCOPE 22 The protections conferred by this Stipulation and Order cover not only 23 Protected Material (as defined above), but also (1) any information copied or 24 extracted from Protected Material; (2) all copies, excerpts, summaries, or 25 compilations of Protected Material; (3) any testimony, conversations, or 26 presentations by Parties or their Counsel that might reveal Protected Material; and 27 (4) if any information, documents, video, photographs, and/or other materials which 1 deposition, said portion of the deposition transcript shall be treated as confidential 2 material subject to this Protective Order. Protected Material shall be used solely in 3 connection with the preparation and trial of the within case, Case No. 8:24-cv- 4 02120-AH-DFM, or any related appellate proceeding, and not for any other purpose, 5 including any other litigation. Any use of Protected Material at trial shall be 6 governed by the orders of the trial judge. This Order does not govern the use of 7 Protected Material at trial. 8 4. DURATION 9 Once a case proceeds to trial, unless timely objected to, all trial exhibits that 10 were designated as confidential or maintained pursuant to this Protective Order 11 become public and will be presumptively available to all members of the public, 12 including the press, unless compelling reasons supported by specific factual findings 13 to proceed otherwise are made to the trial judge in advance of the trial. See 14 Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) 15 (distinguishing “good cause” showing for sealing documents produced in discovery 16 from “compelling reasons” standard when merits-related documents are part of court 17 record). Any trial exhibit containing the Confidential Designation that is to be used 18 at trial shall be reproduced without the Confidential Designation during the parties’ 19 pretrial disclosures. Even after final disposition of this litigation, the confidentiality 20 obligations imposed by this Order shall remain in effect until a Designating Party 21 agrees otherwise in writing or a court order otherwise directs. Final disposition shall 22 be deemed to be the later of (1) dismissal of all claims and defenses in this Action, 23 with or without prejudice; and (2) final judgment herein after the completion and 24 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 25 including the time limits for filing any motions or applications for extension of time 26 pursuant to applicable law. 27 5. DESIGNATING PROTECTED MATERIAL 1 Each Party or Non-Party that designates information or items for protection under 2 this Order must take care to limit any such designation to specific material that 3 qualifies under the appropriate standards. The Designating Party must designate for 4 protection only those parts of material, documents, items, or oral or written 5 communications that qualify so that other portions of the material, documents, 6 items, or communications for which protection is not warranted are not swept 7 unjustifiably within the ambit of this Order. 8 Mass, indiscriminate, or routinized designations are prohibited. Designations 9 that are shown to be clearly unjustified or that have been made for an improper 10 purpose (e.g., to unnecessarily encumber the case development process or to impose 11 unnecessary expenses and burdens on other parties) may expose the Designating 12 Party to sanctions. 13 If it comes to a Designating Party’s attention that information or items that it 14 designated for protection do not qualify for protection, that Designating Party must 15 promptly notify all other Parties that it is withdrawing the inapplicable designation. 16 5.2 Manner and Timing of Designations. Except as otherwise provided in this 17 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 18 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 19 under this Order must be clearly so designated before the material is disclosed or 20 produced. 21 Designation in conformity with this Order requires: 22 (a) for information in documentary form (e.g., paper or electronic 23 documents, but excluding transcripts of depositions or other pretrial or trial 24 proceedings), that the Producing Party affix at a minimum, the legend 25 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 26 contains protected material. If only a portion or portions of the material on a page 27 qualifies for protection, the Producing Party also must clearly identify the protected 1 A Party or Non-Party that makes original documents available for inspection 2 need not designate them for protection until after the inspecting Party has indicated 3 which documents it would like copied and produced. During the inspection and 4 before the designation, all of the material made available for inspection shall be 5 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 6 documents it wants copied and produced, the Producing Party must determine which 7 documents, or portions thereof, qualify for protection under this Order. Then, before 8 producing the specified documents, the Producing Party must affix the 9 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 10 portion or portions of the material on a page qualifies for protection, the Producing 11 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 12 markings in the margins). 13 (b) for testimony given in depositions that the Designating Party 14 identify the Disclosure or Discovery Material on the record, before the close of the 15 deposition all protected testimony. 16 (c) for information produced in some form other than documentary and 17 for any other tangible items, that the Producing Party affix in a prominent place on 18 the exterior of the container or containers in which the information is stored the 19 legend “CONFIDENTIAL.” If only a portion or portions of the information 20 warrants protection, the Producing Party, to the extent practicable, shall identify the 21 protected portion(s). 22 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 23 failure to designate qualified information or items does not, standing alone, waive 24 the Designating Party’s right to secure protection under this Order for such material. 25 Upon timely correction of a designation, the Receiving Party must make reasonable 26 efforts to assure that the material is treated in accordance with the provisions of this 27 Order. 1 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 2 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 3 designation of confidentiality at any time that is consistent with the Court’s 4 Scheduling Order. 5 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 6 resolution process under Local Rule 37.1 et seq. or follow the procedures for 7 informal, telephonic discovery hearings on the Court's website. 8 6.3 The burden of persuasion in any such challenge proceeding shall be on the 9 Designating Party. Frivolous challenges, and those made for an improper purpose 10 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 11 expose the Challenging Party to sanctions. Unless the Designating Party has waived 12 or withdrawn the confidentiality designation, all parties shall continue to afford the 13 material in question the level of protection to which it is entitled under the 14 Producing Party’s designation until the Court rules on the challenge. 15 7. ACCESS TO AND USE OF PROTECTED MATERIAL 16 7.1 Basic Principles. A Receiving Party may use Protected Material that is 17 disclosed or produced by another Party or by a Non-Party in connection with this 18 Action only for prosecuting, defending, or attempting to settle this Action. Such 19 Protected Material may be disclosed only to the categories of persons and under the 20 conditions described in this Order. When the Action has been terminated, a 21 Receiving Party must comply with the provisions of section 13 below (FINAL 22 DISPOSITION). 23 Protected Material must be stored and maintained by a Receiving Party at a 24 location and in a secure manner that ensures that access is limited to the persons 25 authorized under this Order. 26 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 27 otherwise ordered by the court or permitted in writing by the Designating Party, a 1 “CONFIDENTIAL” only to: 2 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 3 well as employees of said Outside Counsel of Record to whom it is reasonably 4 necessary to disclose the information for this Action; 5 (b) the officers, directors, and employees (including House Counsel) of 6 the Receiving Party to whom disclosure is reasonably necessary for this Action; 7 (c) Experts (as defined in this Order) of the Receiving Party to whom 8 disclosure is reasonably necessary for this Action and who have signed the 9 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 10 (d) the court and its personnel; 11 (e) court reporters and their staff; 12 (f) professional jury or trial consultants, mock jurors, and Professional 13 Vendors to whom disclosure is reasonably necessary for this Action and who have 14 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 15 (g) the author or recipient of a document containing the information or 16 a custodian or other person who otherwise possessed or knew the information; 17 (h) during their depositions, witnesses, and attorneys for witnesses, in 18 the Action to whom disclosure is reasonably necessary provided: (1) the deposing 19 party requests that the witness sign the form attached as Exhibit A hereto; and (2) 20 they will not be permitted to keep any confidential information unless they sign the 21 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 22 agreed by the Designating Party or ordered by the court. Pages of transcribed 23 deposition testimony or exhibits to depositions that reveal Protected Material may 24 be separately bound by the court reporter and may not be disclosed to anyone except 25 as permitted under this Stipulated Protective Order; and 26 (i) any mediator or settlement officer, and their supporting personnel, 27 mutually agreed upon by any of the parties engaged in settlement discussions. 1 employees of Defendants or other authorized governmental officials from having 2 access to the documents or other items if they would have had access in the normal 3 course of their job duties. Further, nothing in this order prevents a witness from 4 disclosing events or activities personal to him or her, that is, a witness can disclose 5 to others information previously given to Defendants or its employees with respect 6 to what he or she saw, heard, or otherwise sensed. 7 (k) Each person to whom disclosure of “confidential” documents is 8 made, with the exception of counsel, who are presumed to know the contents of this 9 Protective Order, shall be provided by the person furnishing him/her such material a 10 copy of this order, and shall agree that he/she understands the provisions of the 11 Protective Order. Such person also must consent to be subject to the jurisdiction of 12 the presiding court with respect to any proceeding relating to enforcement of this 13 order, including without limitation, any proceeding for contempt. Unless made on 14 the record in this litigation, counsel making the disclosure to any person described 15 above shall retain the original executed copy of said agreement until final 16 termination of this litigation. 17 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 18 PRODUCED IN OTHER LITIGATION 19 If a Party is served with a subpoena or a court order issued in other litigation 20 that compels disclosure of any information or items designated in this Action as 21 “CONFIDENTIAL,” that Party must: 22 (a) promptly notify in writing the Designating Party. Such notification 23 shall include a copy of the subpoena or court order; 24 (b) promptly notify in writing the party who caused the subpoena or 25 order to issue in the other litigation that some or all of the material covered by the 26 subpoena or order is subject to this Protective Order. Such notification shall include 27 a copy of this Stipulated Protective Order; and 1 pursued by the Designating Party whose Protected Material may be affected. 2 If the Designating Party timely seeks a protective order, the Party served with 3 the subpoena or court order shall not produce any information designated in this 4 action as “CONFIDENTIAL” before a determination by the court from which the 5 subpoena or order issued, unless the Party has obtained the Designating Party’s 6 permission. The Designating Party shall bear the burden and expense of seeking 7 protection in that court of its confidential material and nothing in these provisions 8 should be construed as authorizing or encouraging a Receiving Party in this Action 9 to disobey a lawful directive from another court. 10 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 11 PRODUCED IN THIS LITIGATION 12 (a) The terms of this Order are applicable to information produced by a 13 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 14 produced by Non-Parties in connection with this litigation is protected by the 15 remedies and relief provided by this Order. Nothing in these provisions should be 16 construed as prohibiting a Non-Party from seeking additional protections. 17 (b) In the event that a Party is required, by a valid discovery request, to 18 produce a Non-Party’s confidential information in its possession, and the Party is 19 subject to an agreement with the Non-Party not to produce the Non-Party’s 20 confidential information, then the Party shall: 21 (1) promptly notify in writing the Requesting Party and the Non-Party 22 that some or all of the information requested is subject to a confidentiality 23 agreement with a Non-Party; 24 (2) promptly provide the Non-Party with a copy of the Stipulated 25 Protective Order in this Action, the relevant discovery request(s), and a reasonably 26 specific description of the information requested; and 27 (3) make the information requested available for inspection by the 1 (c) If the Non-Party fails to seek a protective order from this court within 14 2 days of receiving the notice and accompanying information, the Receiving Party 3 may produce the Non-Party’s confidential information responsive to the discovery 4 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 5 not produce any information in its possession or control that is subject to the 6 confidentiality agreement with the Non-Party before a determination by the court. 7 Absent a court order to the contrary, the Non-Party shall bear the burden and 8 expense of seeking protection in this court of its Protected Material. 9 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 10 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 11 Protected Material to any person or in any circumstance not authorized under this 12 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 13 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 14 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 15 persons to whom unauthorized disclosures were made of all the terms of this Order, 16 and (d) request such person or persons to execute the “Acknowledgment and 17 Agreement to Be Bound” that is attached hereto as Exhibit A. 18 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 19 PROTECTED MATERIAL 20 When a Producing Party gives notice to Receiving Parties that certain 21 inadvertently produced material is subject to a claim of privilege or other protection, 22 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 23 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 24 may be established in an e-discovery order that provides for production without 25 prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar 26 as the parties reach an agreement on the effect of disclosure of a communication or 27 information covered by the attorney-client privilege or work product protection, the 1 to the court. 2 12. MISCELLANEOUS 3 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 4 person to seek its modification by the Court in the future. 5 12.2 Right to Assert Other Objections. By stipulating to the entry of this 6 Protective Order no Party waives any right it otherwise would have to object to 7 disclosing or producing any information or item on any ground not addressed in this 8 Stipulated Protective Order. Similarly, no Party waives any right to object on any 9 ground to use in evidence of any of the material covered by this Protective Order. 10 12.3 Filing Protected Material. A Party that seeks to file under seal any 11 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 12 only be filed under seal pursuant to a court order authorizing the sealing of the 13 specific Protected Material at issue. If a Party’s request to file Protected Material 14 under seal is denied by the court, then the Receiving Party may file the information 15 in the public record unless otherwise instructed by the court. 16 13. FINAL DISPOSITION 17 After the final disposition of this Action, as defined in paragraph 4, within 60 18 days of a written request by the Designating Party, each Receiving Party must return 19 all Protected Material to the Producing Party or destroy such material. As used in 20 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 21 summaries, and any other format reproducing or capturing any of the Protected 22 Material. Whether the Protected Material is returned or destroyed, the Receiving 23 Party must submit a written certification to the Producing Party (and, if not the same 24 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 25 (by category, where appropriate) all the Protected Material that was returned or 26 destroyed and (2) affirms that the Receiving Party has not retained any copies, 27 abstracts, compilations, summaries or any other format reproducing or capturing any 1 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 2 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 3 reports, attorney work product, and consultant and expert work product, even if such 4 materials contain Protected Material. Any such archival copies that contain or 5 constitute Protected Material remain subject to this Protective Order as set forth in 6 Section 4 (DURATION). 7 14. Any violation of this Order may be punished by any and all appropriate 8 measures including, without limitation, contempt proceedings and/or monetary 9 sanctions. 10 IT IS SO STIPULATED. 11 DATED: May 28, 2026 Respectfully submitted, 12 LYNBERG & WATKINS A Professional Corporation 13 14 By: /s/ Jesse K. Cox1 15 JESSE K. COX GARROS CHAN 16 Attorneys for Defendants ORANGE COUNTY and ANTHONY 17 MAGDALENO 18 19 /// 20 /// 21 /// 22 /// 23 /// 24 /// 25 26 1 Pursuant to California Central District Local Rule 5-4.3.4, all other 27 signatories listed, and on whose behalf the filing is submitted, concur in the 1 || DATED: May 28, 2026 SKAPIK LAW GROUP 2 3