Opinion

Court: District Court, C.D. California
Filed: Jun 30, 2026
Cited by: 0 cases

The opinion

1 ASenanne TAhnodmreaws sH, iEgsgqin.,s (, SEBsNq. ,1 (0S3B2N80 2)6 6888)

2 Kimberly DeGonia, Esq., (SBN 256989)

Ryan M. McIntosh, Esq., (SBN 328042)

3 David Kao, Esq., (SBN 261117)

ANDREWS & HIGGINS

4 4701 Von Karman Ave., Suite 300

Newport Beach, CA 92660

5 Phone (949) 748-1000

survivor@andrewsthornton.com

Attorneys for Plaintiff

Rick Richmond (SBN 194962)

8 rrichmond@larsonllp.com

Andrew E. Calderón (SBN 316673)

9 acalderon@larsonllp.com

Andrew S. Bledsoe (SBN 332171)

10 abledsoe@larsonllp.com

LARSON LLP

11 555 South Flower Street, 30th Floor

Los Angeles, California 90071

12 Telephone:(213) 436-4888

Facsimile: (213) 623-2000

Attorneys for Defendant The Church of

14 Jesus Christ of Latter-day Saints

17 UNITED STATES DISTRICT COURT

18 CENTRAL DISTRICT OF CALIFORNIA

20 JANE DOE, Case No. 2:25-cv-00713-FMO (AJRx)

21 Plaintiff, [PROPOSED] PROTECTIVE

STIPULATED ORDER

22 vs.

23 THE CHURCH OF JESUS CHRIST

OF LATTER-DAY SAINTS, A

24 Corporation), and DOE 2-500,

Inclusive,

25 Judge: Hon. Fernando M. Olguin

Defendants. Magistrate Judge: Hon. A. Joel Richlin

1 1. GENERAL

2 1.1 Purposes and Limitations. Discovery in this action is likely to involve

3 production of confidential, proprietary, or private information for which special

4 protection from public disclosure and from use for any purpose other than prosecuting

5 this litigation may be warranted. Accordingly, the parties hereby stipulate to and

6 petition the Court to enter the following Stipulated Protective Order. The parties

7 acknowledge that this Order does not confer blanket protections on all disclosures or

8 responses to discovery and that the protection it affords from public disclosure and

9 use extends only to the limited information or items that are entitled to confidential

10 treatment under the applicable legal principles. The parties further acknowledge, as

11 set forth in Section 12.3, below, that this Stipulated Protective Order does not entitle

12 them to file confidential information under seal; Civil Local Rule 79-5 sets forth the

13 procedures that must be followed and the standards that will be applied when a party

14 seeks permission from the court to file material under seal.

15 1.2 Good Cause Statement. This action arises from allegations of

16 childhood sexual abuse and is likely to involve medical records, psychiatric records,

17 confidential church membership records, and other private information implicating

18 the privacy rights of third parties for which special protection from public disclosure

19 and from use for any purpose other than prosecution of this action is warranted.

20 Accordingly, to expedite the flow of information, to facilitate the prompt resolution

21 of disputes over confidentiality of discovery materials, to adequately protect

22 information the parties are entitled to keep confidential, to ensure that the parties are

23 permitted reasonable necessary uses of such material in preparation for and in the

24 conduct of trial, to address their handling at the end of the litigation, and serve the

25 ends of justice, a protective order for such information is justified in this matter. It is

26 the intent of the parties that information will not be designated as confidential for

27 tactical reasons and that nothing be so designated without a good faith belief that it

1 has been maintained in a confidential, non-public manner, and there is good cause

2 why it should not be part of the public record of this case.

4 2. DEFINITIONS

5 2.1 Action: Jane Doe v. The Church of Jesus Christ of Latter-day Saints (a

6 corporation), 2:25-cv-00713-FMO (AJRx).

7 2.2 Challenging Party: a Party or Non-Party that challenges the designation

8 of information or items under this Order.

9 2.3 “CONFIDENTIAL” Information or Items: information (regardless of

10 how it is generated, stored or maintained) or tangible things that qualify for protection

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

12 Cause Statement.

13 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their

14 support staff).

15 2.5 Designating Party: a Party or Non-Party that designates information or

16 items that it produces in disclosures or in responses to discovery as

17 “CONFIDENTIAL.”

18 2.6 Disclosure or Discovery Material: all items or information, regardless

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

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

21 generated in disclosures or responses to discovery in this matter.

22 2.7 Expert: a person with specialized knowledge or experience in a matter

23 pertinent to the litigation who has been retained by a Party or its counsel to serve as

24 an expert witness or as a consultant in this Action.

25 2.8 House Counsel: attorneys who are employees of a party to this Action,

26 and, for purposes of Defendants, attorneys from Kirton McConkie and their staff.

27 House Counsel does not include Outside Counsel of Record or any other outside

28 counsel.

1 2.9 Non-Party: any natural person, partnership, corporation, association, or

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

3 2.10 Outside Counsel of Record: attorneys who are not employees of a party

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

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

6 has appeared on behalf of that party, including support staff.

7 2.11 Party: any party to this Action, including all of its officers, directors,

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

9 support staffs).

10 2.12 Producing Party: a Party or Non-Party that produces Disclosure or

11 Discovery Material in this Action.

12 2.13 Professional Vendors: persons or entities that provide litigation support

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

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

15 and their employees and subcontractors.

16 2.14 Protected Material: any Disclosure or Discovery Material that is

17 designated as “CONFIDENTIAL.”

18 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material

19 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 extracted

24 from Protected Material; (2) all copies, excerpts, summaries, or compilations of

25 Protected Material; and (3) any testimony, conversations, or presentations by Parties

26 or their Counsel that might reveal Protected Material.

27 Any use of Protected Material at trial shall be governed by the orders of the

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

1 4. DURATION

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

3 that was previously designated as confidential or maintained pursuant to this

4 protective order becomes public and will be presumptively available to all members

5 of the public, including the press, unless compelling reasons supported by specific

6 factual findings to proceed otherwise are made to the trial judge in advance of the

7 trial. See Kamakana v. City and Cty. of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir.

8 2006) (distinguishing “good cause” showing for sealing documents produced in

9 discovery from “compelling reasons” standard when merits-related documents are

10 part of court record).

11 Information that remains confidential and is not made available to the public

12 at trial shall remain subject to the confidentiality obligations imposed by this Order

13 until a Designated Party agrees otherwise in writing or a court order otherwise

14 directs, even after final disposition of this litigation. Final disposition will be

15 deemed to be the later of (1) dismissal of all claims and defenses in this Action, with

16 or without prejudice; and (2) final judgement herein after the completion and

17 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action,

18 including the time limits for filing any motions or applications for extension of time

19 pursuant to applicable law.

21 5. DESIGNATING PROTECTED MATERIAL

22 5.1 Exercise of Restraint and Care in Designating Material for Protection.

23 Each Party or Non-Party that designates information or items for protection under this

24 Order must take care to limit any such designation to specific material that qualifies

25 under the appropriate standards. The Designating Party must designate for protection

26 only those parts of material, documents, items, or oral or written communications that

27 qualify so that other portions of the material, documents, items, or communications

1 for which protection is not warranted are not swept unjustifiably within the ambit of

2 this Order.

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

4 that are shown to be clearly unjustified or that have been made for an improper

5 purpose (e.g., to unnecessarily encumber the case development process or to impose

6 unnecessary expenses and burdens on other parties) may expose the Designating Party

7 to sanctions.

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

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

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

11 5.2 Manner and Timing of Designations. Except as otherwise provided in

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

13 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection

14 under this Order must be clearly so designated before the material is disclosed or

15 produced.

16 Designation in conformity with this Order requires:

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

18 documents, but excluding transcripts of depositions or other pretrial or trial

19 proceedings), that the Producing Party affix, at a minimum, the legend

20 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that

21 contains protected material. If only a portion or portions of the material on a page

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

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

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

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

26 which documents it would like copied and produced. During the inspection and

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

28 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents

1 it wants copied and produced, the Producing Party must determine which documents,

2 or portions thereof, qualify for protection under this Order. Then, before producing

3 the specified documents, the Producing Party must affix the “CONFIDENTIAL

4 legend” to each page that contains Protected Material. If only a portion or portions

5 of the material on a page qualifies for protection, the Producing Party also must clearly

6 identify the protected portion(s) (e.g., by making appropriate markings in the

7 margins).

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

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

10 (c) for information produced in some form other than documentary and

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

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

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

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

15 portion(s).

16 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent

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

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

19 Upon timely correction of a designation, the Receiving Party must make reasonable

20 efforts to assure that the material is treated in accordance with the provisions of this

21 Order.

23 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

24 6.1 Timing of Challenges. Any Party or Non-Party may challenge a

25 designation of confidentiality at any time that is consistent with the Court’s

26 Scheduling Order.

1 6.2 Meet and Confer. The Challenging Party shall initiate the dispute

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

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

4 6.3 Burden. The burden of persuasion in any such challenge proceeding

5 shall be on the Designating Party. Frivolous challenges, and those made for an

6 improper purpose (e.g., to harass or impose unnecessary expenses and burdens on

7 other parties) may expose the Challenging Party to sanctions. Unless the Designating

8 Party has waived or withdrawn the confidentiality designation, all parties shall

9 continue to afford the material in question the level of protection to which it is entitled

10 under the Producing Party’s designation until the Court rules on the challenge.

12 7. ACCESS TO AND USE OF PROTECTED MATERIAL

13 7.1 Basic Principles. A Receiving Party may use Protected Material that is

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

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

16 Protected Material may be disclosed only to the categories of persons and under the

17 conditions described in this Order. When the Action has been terminated, a Receiving

18 Party must comply with the provisions of section 13 below (FINAL DISPOSITION).

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

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

21 authorized under this Order.

22 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless

23 otherwise ordered by the Court or permitted in writing by the Designating Party, a

24 Receiving Party may disclose any information or item designated

25 “CONFIDENTIAL” only to:

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

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

28 necessary to disclose the information for this Action;

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

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

3 (c) Experts (as defined in this Order) of the Receiving Party to whom

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

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

6 (d) the Court and its personnel;

7 (e) court reporters and their staff;

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

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

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

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

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

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

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

15 party requests that the witness sign the form attached as Exhibit A hereto; and (2) they

16 will not be permitted to keep any confidential information unless they sign the

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

18 agreed by the Designating Party or ordered by the Court. Pages of transcribed

19 deposition testimony or exhibits to depositions that reveal Protected Material may be

20 separately bound by the court reporter and may not be disclosed to anyone except as

21 permitted under this Stipulated Protective Order; and

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

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

25 / / /

26 / / /

27 / / /

28 / / /

1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED

2 PRODUCED IN OTHER LITIGATION

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

4 that 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

10 or order is subject to this Protective Order. Such notification shall include a copy of

11 this Stipulated Protective Order; and

12 (c) cooperate with respect to all reasonable procedures sought to be pursued

13 by the Designating Party whose Protected Material may be affected.

14 If the Designating Party timely seeks a protective order, the Party served with

15 the subpoena or court order shall not produce any information designated in this action

16 as “CONFIDENTIAL” before a determination by the court from which the subpoena

17 or 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.

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

27 produced by Non-Parties in connection with this litigation is protected by the

1 remedies and relief provided by this Order. Nothing in these provisions should be

2 construed as prohibiting a Non-Party from seeking additional protections.

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

4 a 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

6 information, then the Party shall:

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

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

9 with a 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 order to the contrary, the Non-Party shall bear the burden and expense of seeking

22 protection in this Court of its Protected Material.

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

28 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts

1 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or

2 persons to whom unauthorized disclosures were made of all the terms of this Order,

3 and (d) request such person or persons to execute the “Acknowledgment and

4 Agreement to Be Bound” that is attached hereto as Exhibit A.

6 11. 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,

10 the 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

17 to the Court.

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

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

4 then the Receiving Party may file the information in the public record unless

5 otherwise instructed by the Court.

7 13. FINAL DISPOSITION

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

9 the 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

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

13 Material is returned or destroyed, the Receiving Party must submit a written

14 certification to the Producing Party (and, if not the same person or entity, to the

15 Designating Party) by the 60 day deadline that (1) identifies (by category, where

16 appropriate) all the Protected Material that was returned or destroyed, and (2) affirms

17 that the Receiving Party has not retained any copies, abstracts, compilations,

18 summaries or any other format reproducing or capturing any of the Protected Material.

19 Notwithstanding this provision, counsel are entitled to retain an archival copy of all

20 pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda,

21 correspondence, deposition and trial exhibits, expert reports, attorney work product,

22 and consultant and expert work product, even if such materials contain Protected

23 Material. Any such archival copies that contain or constitute Protected Material

24 remain subject to this Protective Order as set forth in Section 4 (DURATION).

26 / / /

27 / / /

28 / / /

1 14. VIOLATION OF ORDER

2 Any violation of this Order may be punished by any and all appropriate

3 measures including, without limitation, contempt proceedings and/or monetary

4 sanctions.

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

Dated: June 29, 2026 LARSON LLP

12 By: /s/ Rick Richmond

13 Rick Richmond

Andrew E. Calderón

Kimberly E. Wilkinson

15 Attorneys for Defendant The Church of Jesus

Christ of Latter-day Saints

17 Dated: June 29, 2026 ANDREWS & HIGGINS

By: /s/ Kimberly Degonia

Anne Andrews

21 Sean Thomas Higgins

Kimberly DeGonia

Ryan M. McIntosh

Attorneys for Plaintiff

1 |} FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

3 || parEp:990/2026 \ok Pith

4 United States Magistrate Judge

1 EXHIBIT A

2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

4 I, _____________________________ [full name], of _________________

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

6 understand the Stipulated Protective Order that was issued by the United States

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

8 case of Jane Doe v. The Church of Jesus Christ of Latter-day Saints, a corporation),

9 2:25-cv-00713-FMO (AJRx). I agree to comply with and to be bound by all the

10 terms of this Stipulated Protective Order and I understand and acknowledge that

11 failure to so comply could expose me to sanctions and punishment in the nature of

12 contempt. I solemnly promise that I will not disclose in any manner any

13 information or item that is subject to this Stipulated Protective Order to any person

14 or entity except in strict compliance with the provisions of this Order.

15 I further agree to submit to the jurisdiction of the United States District Court

16 for the Central District of California for the purpose of enforcing the terms of this

17 Stipulated Protective Order, even if such enforcement proceedings occur after

18 termination of this action. I hereby appoint __________________________ [full

19 name] of _______________________________________ [full address and

20 telephone number] as my California agent for service of process in connection with

21 this action or any proceedings related to enforcement of this Stipulated Protective

22 Order.

23 Date: ______________________________________

24 City and State where signed: _________________________________

26 Printed name: _______________________________

28 Signature: __________________________________

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