The opinion
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UNITED STATES DISTRICT COURT
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CENTRAL DISTRICT OF CALIFORNIA
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11 || K.W., AMINOR, BY AND THROUGH | CASE NO. 2:25-CV-08250-FLA-(Ex)
SHALAYLA THOMPSON AND Hon. Eemando Lazaro Aenlle-Rocha
12 || SHALAYLA THOMPSON, — Ctr. 6B, First Street Fed. Courthouse
INDIVIDUALLY, Hon. Charles F. Eick, US Magistrate Judge
13 i. —Ctrm. 750, Edward Roybal Bldg.
Plaintiffs,
v. STIPULATED [PROBO@SED]
R RDER
12 CITY OF LOS ANGELES POLICE PROTECTIVE ORDE
16 || DEPARTMENT; CITY OF LOS
ANGELES, CALIFORNIA; JIM
17 ||} MCDONNELL; LUKE MELLO,
18 Defendants,
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20
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22 GENERAL
23 1.1 Purposes and Limitations. Discovery in this action is likely to involve
24 || production of confidential, proprietary, or private information for which special
25 || protection from public disclosure and from use for any purpose other than prosecuting
26 || this litigation may be warranted. Accordingly, the parties hereby stipulate to and
27 || petition the Court to enter the following Stipulated Protective Order. The parties
28 || acknowledge that this Order does not confer blanket protections on all disclosures or
1 responses to discovery and that the protection it affords from public disclosure and use
2 extends only to the limited information or items that are entitled to confidential
3. treatment under the applicable legal principles. The parties further acknowledge, as set
4 forth in Section 12.3, below, that this Stipulated Protective Order does not entitle them
5 to file confidential information under seal; Civil Local Rule 79-5 sets forth the
6 procedures that must be followed and the standards that will be applied when a party
7 seeks permission from the court to file material under seal.
8 1.2 Good Cause Statement.
9 This action involves the City of Los Angeles and members of the Los Angeles
10 Police Department. Plaintiff is seeking materials and information that Defendants the
11 City of Los Angeles et al. (“City”) maintains as confidential, such as personnel files of
12 the police officers involved in this incident, Internal Affairs materials and information,
13. video recordings (including Body-Worn Video recordings and Digital In-Car Video
14 recordings), audio recordings, and information and other administrative materials and
15 information currently in the possession of the City and which the City believes need
16 special protection from public disclosure and from use for any purpose other than
prosecuting this litigation. Plaintiff is also seeking official information contained in the
18 personnel files of the police officers involved in the subject incident, which the City
19 maintains as strictly confidential and which the City believes need special protection
20 from public disclosure and from use for any purpose other than prosecuting this
21 litigation.
22 The City asserts that the confidentiality of the materials and information sought
23 by Plaintiff is recognized by California and federal law, as evidenced inter alia by
24 California Penal Code section 832.7 and Kerr v. United States Dist. Ct. for N.D. Cal.,
25. 511 F.2d 192, 198 (9th Cir. 1975), aff'd, 426 U.S. 394 (1976). The City has not publicly
26 released the materials and information referenced above except under protective order
27 or pursuant to a court order, if at all. These materials and information are of the type that
28 has been used to initiate disciplinary action against Los Angeles Police Department
1 ||(“LAPD”) officers, and has been used as evidence in disciplinary proceedings, where
2 || the officers’ conduct was considered to be contrary to LAPD policy. The City contends
3 ||that absent a protective order delineating the responsibilities of nondisclosure on the
4 || part of the parties hereto, there is a specific risk of unnecessary and undue disclosure by
5 |}one or more of the many attorneys, secretaries, law clerks, paralegals and expert
6 || witnesses involved in this case, as well as the corollary risk of embarrassment,
7 || harassment and professional and legal harm on the part of the LAPD officers referenced
8 || in the materials and information.
9 The City also contends that the unfettered disclosure of the materials and
10 || information, absent a protective order, would allow the media to share this information
11 || with potential jurors in the area, impacting the rights of the City herein to receive a fair
12 Accordingly, to expedite the flow of information, to facilitate the prompt
13 || resolution of disputes over confidentiality of discovery materials, to adequately protect
14 || information the parties are entitled to keep confidential, to ensure that the parties are
15 || permitted reasonable necessary uses of such material in preparation for and in the
16 || conduct of trial, to address their handling at the end of the litigation, and serve the ends
17 || of justice, a protective order for such information is justified in this matter. It is the
18 || intent of the parties that information will not be designated as confidential for tactical
19 ||reasons and that nothing be so designated without a good faith belief that it has been
20 || maintained in a confidential, non-public manner, and there is good cause why it should
21 || not be part of the public record of this case.
22 ||2. DEFINITIONS
23 2.1 Action: K.W., et al. v. City of Los Angeles, et. al, United States District
24 || Court, Central District of California, 2:25-CV-08250-FLA-(Ex).
25 2.2 Challenging Party: a Party or Non-Party that challenges the designation of
26 || information or items under this Order.
27 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how
28 || it is generated, stored or maintained) or tangible things that qualify for protection under
+
1 || Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause
2 || Statement.
3 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their
4 || support staff).
5 2.5 Designating Party: a Party or Non-Party that designates information or
6 that it produces in disclosures or in responses to discovery as
7 || “CONFIDENTIAL.”
8 2.6 Disclosure or Discovery Material: all items or information, regardless of
9 medium or manner in which it is generated, stored, or maintained (including, among
10 || other things, testimony, transcripts, and tangible things), that are produced or generated
1] || in disclosures or responses to discovery in this matter.
12 2.7 Expert: a person with specialized knowledge or experience in a matter
13 || pertinent to the litigation who has been retained by a Party or its counsel to serve as an
14 || expert witness or as a consultant in this Action.
15 2.8 House Counsel: attorneys who are employees of a party to this Action.
16 House Counsel does not include Outside Counsel of Record or any other outside
17 || counsel.
18 2.9 Non-Party: any natural person, partnership, corporation, association, or
19 || other legal entity not named as a Party to this action.
20 2.10 Outside Counsel of Record: attorneys who are not employees of a party to
21 || this Action but are retained to represent or advise a party to this Action and have
22 || appeared in this Action on behalf of that party or are affiliated with a law firm that has
23 || appeared on behalf of that party, including support staff.
24 2.11 Party: any party to this Action, including all of its officers, directors,
25 || employees, consultants, retained experts, and Outside Counsel of Record (and their
26 || support staffs).
27 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
28 || Discovery Material in this Action.
1 2.13 Professional Vendors: persons or entities that provide litigation support
2 ||services (e.g., photocopying, videotaping, translating, preparing exhibits or
3 || demonstrations, and organizing, storing, or retrieving data in any form or medium) and
4 employees and subcontractors.
5 2.14 Protected Material: any Disclosure or Discovery Material that is
6 || designated as “CONFIDENTIAL.”
7 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material
8 || from a Producing Party.
9
10 ||3. SCOPE
11 The protections conferred by this Stipulation and Order cover not only Protected
12 || Material (as defined above), but also (1) any information copied or extracted from
13 ||Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected
14 || Material; and (3) any testimony, conversations, or presentations by Parties or their
15 Counsel that might reveal Protected Material.
16 Any use of Protected Material at trial shall be governed by the orders of the trial
17 ||judge. This Order does not govern the use of Protected Material at trial.
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19 ||4. DURATION
20 Once a case proceeds to trial, all of the court-filed information to be introduced
21 ||that was previously designated as confidential or maintained pursuant to this protective
22 || order becomes public and will be presumptively available to all members of the public,
23 || including the press, unless compelling reasons supported by specific factual findings to
24 || proceed otherwise are made to the trial judge in advance of the trial. See Kamakana v.
25 || City and Cty. of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing
26 || “good cause” showing for sealing documents produced in discovery from “compelling
27 ||reasons” standard when merits-related documents are part of court record).
28 || Accordingly, the terms of this protective order do not extend beyond the
1 || commencement of the trial.
2
3 DESIGNATING PROTECTED MATERIAL
4 5.1 Exercise of Restraint Care in Designating Material for Protection.
5 ||Each Party or Non-Party that designates information or items for protection under this
6 || Order must take care to limit any such designation to specific material that qualifies
7 under the appropriate standards. The Designating Party must designate for protection
8 || only those parts of material, documents, items, or oral or written communications that
9 || qualify so that other portions of the material, documents, items, or communications for
10 || which protection is not warranted are not swept unjustifiably within the ambit of this
11 || Order.
12 Mass, indiscriminate, or routinized designations are prohibited. Designations that
13 || are shown to be clearly unjustified or that have been made for an improper purpose
14 || (e.g., to unnecessarily encumber the case development process or to impose unnecessary
15 || expenses and burdens on other parties) may expose the Designating Party to sanctions.
16 If it comes to a Designating Party’s attention that information or items that it
17 || designated for protection do not qualify for protection, that Designating Party must
18 || promptly notify all other Parties that it is withdrawing the inapplicable designation.
19 5.2 Manner and Timing of Designations. Except as otherwise provided in this
20 || Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or
21 || ordered, Disclosure or Discovery Material that qualifies for protection under this Order
22 || must be clearly so designated before the material is disclosed or produced.
23 Designation in conformity with this Order requires:
24 (a) for information in documentary form (e.g., paper or electronic
25 ||documents, but excluding transcripts of depositions or other pretrial or trial
26 ||proceedings), that the Producing Party affix, at a minimum, the legend
27 ||““CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
28 contains protected material. If only a portion or portions of the material on a page
1 || qualifies for protection, the Producing Party also must clearly identify the protected
2 || portion(s) (e.g., by making appropriate markings in the margins).
3 A Party or Non-Party that makes original documents available for inspection need
4 ||not designate them for protection until after the inspecting Party has indicated which
5 ||documents it would like copied and produced. During the inspection and before the
6 || designation, all of the material made available for inspection shall be deemed
7 ||“CONFIDENTIAL.” After the inspecting Party has identified the documents it wants
8 || copied and produced, the Producing Party must determine which documents, or portions
9 thereof, qualify for protection under this Order. Then, before producing the specified
10 || documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page
11 || that contains Protected Material. If only a portion or portions of the material on a page
12 || qualifies for protection, the Producing Party also must clearly identify the protected
13 || portion(s) (e.g., by making appropriate markings in the margins).
14 (b) for testimony given in depositions that the Designating Party identify
15 || the Disclosure or Discovery Material on the record, before the close of the deposition.
16 (c) for information produced in some form other than documentary and for
17 ||any other tangible items, that the Producing Party affix in a prominent place on the
18 ||exterior of the container or containers in which the information is stored the legend
19 ||“CONFIDENTIAL.” If only a portion or portions of the information warrants
20 || protection, the Producing Party, to the extent practicable, shall identify the protected
21 || 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 the
24 || Designating Party’s right to secure protection under this Order for such material. Upon
25 || timely correction of a designation, the Receiving Party must make reasonable efforts to
26 || assure that the material is treated in accordance with the provisions of this Order.
DF
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1 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 Scheduling
4 || Order.
5 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
6 resolution process under Local Rule 37-1, et seq. Any discovery motion must strictly
7 ||comply with the procedures set forth in Local Rules 37-1, 37-2, and 37-3.
8 6.3 Burden. The burden of persuasion in any such challenge proceeding shall
9 || be on the Designating Party. Frivolous challenges, and those made for an improper
10 || purpose (e.g., to harass or impose unnecessary expenses and burdens on other parties)
11 ||may expose the Challenging Party to sanctions. Unless the Designating Party has
12 || waived or withdrawn the confidentiality designation, all parties shall continue to afford
13 ||the 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.
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16 ||7. ACCESS TO AND USE OF PROTECTED MATERIAL
17 7.1 Basic Principles. A Receiving Party may use Protected Material that is
18 || disclosed or produced by another Party or by a Non-Party in connection with this Action
19 for prosecuting, defending, or attempting to settle this Action. Such Protected
20 || Material may be disclosed only to the categories of persons and under the conditions
21 || described in this Order. When the Action has been terminated, a Receiving Party must
22 ||comply with the provisions of section 13 below (FINAL 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 otherwise
27 || ordered by the Court or permitted in writing by the Designating Party, a Receiving Party
28 || may disclose any information or item designated “CONFIDENTIAL” only to:
l (a) the Receiving Party’s Outside Counsel of Record in this Action, as well
2 employees of said Outside Counsel of Record to whom it is reasonably necessary to
3 || disclose the information for this Action;
4 (b) the officers, directors, and employees (including House Counsel) of the
5 || Receiving Party to whom disclosure is reasonably necessary for this Action;
6 (c) Experts (as defined in this Order) of the Receiving Party to whom
7 ||disclosure is reasonably necessary for this Action and who have signed the
8 ||““Acknowledgment and Agreement to Be Bound” (Exhibit A);
9 (d) the Court and its personnel;
10 (e) court reporters and their staff;
11 (f) professional jury or trial consultants, mock jurors, and Professional
12 || Vendors to whom disclosure is reasonably necessary for this Action and who have
13 || signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
14 (g) the author or recipient of a document containing the information or a
15 || custodian or other person who otherwise possessed or knew the information;
16 (h) during their depositions, witnesses, and attorneys for witnesses, in the
17 || Action to whom disclosure is reasonably necessary provided: (1) the deposing party
18 || requests that the witness sign the form attached as Exhibit A hereto; and (2) they will
19 ||not be permitted to keep any confidential information unless they sign the
20 ||““Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed
21 the Designating Party or ordered by the Court. Pages of transcribed deposition
22 ||testimony or exhibits to depositions that reveal Protected Material may be separately
23 || bound by the court reporter and may not be disclosed to anyone except as permitted
24 || under this Stipulated Protective Order; and
25 (i) any mediator or settlement officer, and their supporting personnel,
26 || mutually agreed upon by any of the parties engaged in settlement discussions.
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1 PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
2 IN OTHER LITIGATION
3 If a Party is served with a subpoena or a court order issued in other litigation that
4 ||compels disclosure of any information or items designated in this Action as
5 ||“CONFIDENTIAL,” that Party must:
6 (a) promptly notify in writing the Designating Party. Such notification shall
7 || include a copy of the subpoena or court order;
8 (b) promptly notify in writing the party who caused the subpoena or order to
9 || issue in the other litigation that some or all of the material covered by the subpoena or
10 || order is subject to this Protective Order. Such notification shall include a copy of this
11 || Stipulated Protective Order; and
12 (c) cooperate with respect to all reasonable procedures sought to be pursued by
13 || the Designating Party whose Protected Material may be affected.
14 If the Designating Party timely seeks a protective order, the Party served with the
15 ||subpoena or court order shall not produce any information designated in this action as
16 || “CONFIDENTIAL” before a determination by the court from which the subpoena or
17 ||order issued, unless the Party has obtained the Designating Party’s permission. The
18 || Designating Party shall bear the burden and expense of seeking protection in that court
19 || of its confidential material and nothing in these provisions should be construed as
20 || authorizing or encouraging a Receiving Party in this Action to disobey a lawful
21 || directive from another court.
22
23 ||9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
24 PRODUCED IN THIS LITIGATION
25 (a) The terms of this Order are applicable to information produced by a Non-
26 || Party in this Action and designated as “CONFIDENTIAL.” Such information produced
27 || by Non-Parties in connection with this litigation is protected by the remedies and relief
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1 || provided by this Order. Nothing in these provisions should be construed as prohibiting
2 ||a Non-Party from seeking additional protections.
3 (b) In the event that a Party is required, by a valid discovery request, to produce a
4 ||Non-Party’s confidential information in its possession, and the Party is subject to an
5 ||agreement with the Non-Party not to produce the Non-Party’s confidential information,
6 || then the Party shall:
7 (1) promptly notify in writing the Requesting Party and the Non-Party that
8 || some or all of the information requested is subject to a confidentiality agreement with a
9 || Non-Party;
10 (2) promptly provide the Non-Party with a copy of the Stipulated
11 || Protective Order in this Action, the relevant discovery request(s), and a reasonably
12 || specific description of the information requested; and
13 (3) make the information requested available for inspection by the Non-
14 || Party, if requested.
15 (c) If the Non-Party fails to seek a protective order from this Court within 14
16 || days of receiving the notice and accompanying information, the Receiving Party may
17 || produce the Non-Party’s confidential information responsive to the discovery request.
18 || If the Non-Party timely seeks a protective order, the Receiving Party shall not produce
19 ||any information in its possession or control that is subject to the confidentiality
20 ||agreement with the Non-Party before a determination by the Court. Absent a court
21 |jorder to the contrary, the Non-Party shall bear the burden and expense of seeking
22 || protection in this Court of its Protected Material.
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24 ||10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
25 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
26 Protected Material to any person or in any circumstance not authorized under this
27 || Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing
28 || the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve
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1 unauthorized copies of the Protected Material, (c) inform the person or persons to
2 || whom unauthorized disclosures were made of all the terms of this Order, and (d) request
3 person or persons to execute the “Acknowledgment and Agreement to Be Bound”
4 || that is attached hereto as Exhibit A.
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6 INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
7 PROTECTED MATERIAL
8 When a Producing Party gives notice to Receiving Parties that certain
9 || inadvertently produced material is subject to a claim of privilege or other protection, the
10 obligations of the Receiving Parties are those set forth in Federal Rule of Civil
11 ||Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
12 ||may be established in an e-discovery order that provides for production without prior
13 || privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
14 ||parties reach an agreement on the effect of disclosure of a communication or
15 ||information covered by the attorney-client privilege or work product protection, the
16 || parties may incorporate their agreement in the stipulated protective order submitted to
17 || the Court.
18
19 ||12. MISCELLANEOUS
20 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
21 || person to seek its modification by the Court in the future.
22 12.2 Right to Assert Other Objections. By stipulating to the entry of this
23 Protective Order, no Party waives any right it otherwise would have to object to
24 || disclosing or producing any information or item on any ground not addressed in this
25 || Stipulated Protective Order. Similarly, no Party waives any right to object on any
26 || ground to use in evidence of any of the material covered by this Protective Order.
27 12.3 Filing Protected Material. A Party that seeks to file under seal any
28 || Protected Material must comply with Civil Local Rule 79-5. Protected Material may
1 || only be filed under seal pursuant to a court order authorizing the sealing of the specific
2 || Protected Material at issue; good cause must be shown in the request to file under seal.
3 ||If a Party’s request to file Protected Material under seal is denied by the Court, then the
4 ||Receiving Party may file the information in the public record unless otherwise
5 || instructed by the Court.
6
7 FINAL DISPOSITION
8 After the final disposition of this Action, within 60 days of a written request by
9 Designating Party, each Receiving Party must return all Protected Material to the
10 || Producing Party or destroy such material. As used in this subdivision, “all Protected
11 || Material” includes all copies, abstracts, compilations, summaries, and any other format
12 || reproducing or capturing any of the Protected Material. Whether the Protected Material
13 ||is returned or destroyed, the Receiving Party must submit a written certification to the
14 || Producing Party (and, if not the same person or entity, to the Designating Party) by the
15 ||60 day deadline that (1) identifies (by category, where appropriate) all the Protected
16 || Material that was returned or destroyed, and (2) affirms that the Receiving Party has not
17 ||retained any copies, abstracts, compilations, summaries or any other format reproducing
18 || or capturing any of the Protected Material. Notwithstanding this provision, counsel are
19 || entitled to retain an archival copy of all pleadings, motion papers, trial, deposition, and
20 || hearing transcripts, legal memoranda, correspondence, deposition and trial exhibits,
21 ||expert reports, attorney work product, and consultant and expert work product, even if
22 ||such materials contain Protected Material. Any such archival copies that contain or
23 ||constitute Protected Material remain subject to this Protective Order as set forth in
24 || Section 4 (DURATION).
25
26 VIOLATION OF ORDER
27 Any violation of this Order may be punished by any and all appropriate measures
28 || including, without limitation, contempt proceedings and/or monetary sanctions.
1 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
2
3
4 DATED: June 16, 2026 The Lanier Law Firm, P.C.
5
6 Lee A. Cirsch, Esq.
Attorneys for Plaintiff(s)
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8 DATED: June 16, 2026 Stone Busailah, LLP
9
10 tn
Muna Busailah, Esq.
11 Attorneys for Defendants
2 Luke Mello
Michael Enriquez
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14 Dated: June 16, 2026 HYDEE FELDSTEIN SOTO, City Attorney
15 DENISE C. MILLS, Chief Deputy City Attorney
16 KATHLEEN KENEALY, Chief Asst. City Atty.
17
18 BY je ere
SHANT G. TASLAKIAN, Deputy City Attorney
19 Attorneys for Defendants, CITY OF LOS
0 ANGELES, LOS ANGELES POLICE
DEPARTMENT AND JIM McDONNELL
21
22
23
FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
25 :
og |[DATED: _¢//¢/2é AEE
HON. CHARLES F. EICK
27 United States Magistrate Judge
28
1 EXHIBIT A
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
7 the Central District of California on [date] in the case of K.W., et al. v.
City of Los Angeles, et al., USDC Case No. 2:25-CV-08250-FLA-(E). I agree to
9 comply with and to be bound by all the terms of this Stipulated Protective Order and I
10 understand and acknowledge that failure to so comply could expose me to sanctions and
i punishment in the nature of contempt. I solemnly promise that I will not disclose in any
0 manner any information or item that is subject to this Stipulated Protective Order to any
13 || Person or entity except in strict compliance with the provisions of this Order.
14 I further agree to submit to the jurisdiction of the United States District Court for
1s the Central District of California for the purpose of enforcing the terms of this
16 Stipulated Protective Order, even if such enforcement proceedings occur after
7 termination of this action. I hereby appoint [full
13 name] of — [full address and telephone
19 number] as my California agent for service of process in connection with this action or
30 any proceedings related to enforcement of this Stipulated Protective Order.
21
99 Date: eee
23
34 City and State where signed:
25
36 Printed name: eee
27
28 Signature: ee
ac