# Opinion

> District Court, C.D. California · August 3, 2026

URL: https://www.frixlaw.com/law-library/cases/11427697

## Case

- **Full name:** Alec Marrujo v. Target Corporation, a Minnesota corporation; and Does 1 through 100 inclusive
- **Court:** District Court, C.D. California
- **Decided:** August 3, 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/11427697

## Opinion text

1 SEYFARTH SHAW LLP
Mandana Massoumi (SBN 191359)
2 mmassoumi@seyfarth.com
Kishaniah Dhamodaran (SBN 331001)
3 kdhamodaran@seyfarth.com
Mackenzie Mullin (SBN 357678)
4 mmullin@seyfarth.com
2029 Century Park East, Suite 3500
5 Los Angeles, California 90067-3021
Telephone: (310) 277-7200
6 Facsimile: (310) 201-5219
7 Attorneys for Defendant
TARGET CORPORATION
8
9
10 UNITED STATES DISTRICT COURT
11 CENTRAL DISTRICT OF CALIFORNIA
12
13 ALEC MARRUJO, an individual, Case No. 5:26-cv-02125-CV-DTB
14 Plaintiff, STIPULATED PROTECTIVE
ORDER
15 v.

16 TARGET CORPORATION, a Minnesota
corporation; and DOES 1 through 100
17 inclusive,
18 Defendants.
19

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1 1. INTRODUCTION
2 1.1. Purposes And Limitations
3 Discovery in this action is likely to involve production of confidential, proprietary,
4 or private information for which special protection from public disclosure and from use for
5 any purpose other than prosecuting this litigation may be warranted. Accordingly, the
6 parties hereby stipulate to petition the Court to enter the following Stipulated Protective
7 Order. The parties acknowledge that this Order does not confer blanket protections on all
8 disclosures or responses to discovery and that the protection it affords from public
9 disclosure and use extends only to the limited information or items that are entitled to
10 confidential treatment under the applicable legal principles. The parties further
11 acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective Order does
12 not entitle them to file confidential information under seal; Civil Local Rule 79-5 sets forth
13 the 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
16 This action is likely to involve the production of confidential information, including
17 Plaintiff’s personal and private information (such as medical records) and Defendant’s
18 proprietary business policies, procedures, and commercially sensitive information, for
19 which special protection from public disclosure and from use for any purpose other than
20 prosecution of this action is warranted. Such confidential and proprietary materials and
21 information consist of, among other things, medical, private, confidential and proprietary
22 business or financial information, information regarding confidential business practices
23 and policies, information implicating privacy rights of third parties, information otherwise
24 generally unavailable to the public, or which may be privileged or otherwise protected from
25 disclosure under state or federal statutes, court rules, case decisions, or common law.
26 Disclosure of this information to persons who are not entitled to it carries danger of
27 compromising the competitive business interests of Defendant and also risks invasion of
28 legitimate personal privacy interests of Plaintiff and non-parties. Accordingly, to expedite
1 the flow of information, to facilitate the prompt resolution of disputes over confidentiality
2 of discovery materials, to adequately protect information the parties are entitled to keep
3 confidential, to ensure that the parties are permitted reasonable necessary uses of such
4 material in preparation for and in the conduct of trial, to address their handling at the end
5 of the litigation, and serve the ends of justice, a protective order for such information is
6 justified in this matter. It is the intent of the parties that information will not be designated
7 as confidential for tactical reasons and that nothing be so designated without a good faith
8 belief that it has been maintained in a confidential, non-public manner, and there is good
9 cause why it should not be part of the public record of this case.
10 2. DEFINITIONS
11 2.1. Action: Alec Marrujo v. Target Corporation, Case No. 5:26-cv-02125-CV-
12 DTB.
13 2.2. Challenging Party: a Party or Non-Party that challenges the designation of
14 information or items under this Order.
15 2.3. “CONFIDENTIAL” Information or Items: information (regardless of how it
16 is generated, stored or maintained) or tangible things that qualify for protection under
17 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause Statement.
18 2.4. Counsel: Outside Counsel of Record and House Counsel (as well as their
19 support staff).
20 2.5. Designating Party: a Party or Non-Party that designates information or items
21 that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.”
22 2.6. Disclosure or Discovery Material: all items or information, regardless of the
23 medium or manner in which it is generated, stored, or maintained (including, among other
24 things, testimony, transcripts, and tangible things), that are produced or generated in
25 disclosures or responses to discovery in this matter.
26 2.7. Expert: a person with specialized knowledge or experience in a matter
27 pertinent to the litigation who has been retained by a Party or its counsel to serve as an
28 expert witness or as a consultant in this Action.
1 2.8. House Counsel: attorneys who are employees of a party to this Action. House
2 Counsel does not include Outside Counsel of Record or any other outside counsel.
3 2.9. Non-Party: any natural person, partnership, corporation, association, or other
4 legal entity not named as a Party to this action.
5 2.10. Outside Counsel of Record: attorneys who are not employees of a party to this
6 Action but are retained to represent or advise a party to this Action and have appeared in
7 this Action on behalf of that party or are affiliated with a law firm which has appeared on
8 behalf of that party and includes support staff.
9 2.11. Party: any party to this Action, including all of its officers, directors,
10 employees, consultants, retained experts, and Outside Counsel of Record (and their support
11 staffs).
12 2.12. Producing Party: a Party or Non-Party that produces Disclosure or Discovery
13 Material in this Action.
14 2.13. Professional Vendors: Persons or entities that provide litigation support
15 services (e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations,
16 and organizing, storing, or retrieving data in any form or medium) and their employees and
17 subcontractors.
18 3. SCOPE
19 The protections conferred by this Stipulation and Order cover not only Protected
20 Material (as defined above), but also (1) any information copied or extracted from
21 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected
22 Material; and (3) any testimony, conversations, or presentations by Parties or their Counsel
23 that might reveal Protected Material.
24 Any use of Protected Material at trial shall be governed by the orders of the trial
25 judge. This Order does not govern the use of Protected Material at trial.
26 4. DURATION
27 Once a case proceeds to trial, information that was designated as CONFIDENTIAL
28 or maintained pursuant to this protective order used or introduced as an exhibit at trial
1 becomes public and will be presumptively available to all members of the public, including
2 the press, unless compelling reasons supported by specific factual findings to proceed
3 otherwise are made to the trial judge in advance of the trial. See Kamakana v. City and
4 County of Honolulu, 447 F.3d 1172, 1180-81 (distinguishing “good cause” showing for
5 sealing documents produced in discovery from “compelling reasons” standard when
6 merits-related documents are part of court record). Accordingly, the terms of this protective
7 order do not extend beyond the commencement of the trial.
8 5. DESIGNATING PROTECTED MATERIAL
9 5.1. Exercise of Restraint and Care in Designating Material for Protection. Each
10 Party or Non-Party that designates information or items for protection under this Order
11 must take care to limit any such designation to specific material that qualifies under the
12 appropriate standards. The Designating Party must designate for protection only those parts
13 of material, documents, items, or oral or written communications that qualify so that other
14 portions of the material, documents, items, or communications for which protection is not
15 warranted are not swept unjustifiably within the ambit of this Order.
16 Mass, indiscriminate, or routinized designations are prohibited. Designations that
17 are shown to be clearly unjustified or that have been made for an improper purpose (e.g.,
18 to unnecessarily encumber the case development process or to impose unnecessary
19 expenses and burdens on other parties) may expose the Designating Party to sanctions.
20 If it comes to a Designating Party’s attention that information or items that it
21 designated for protection do not qualify for protection, that Designating Party must
22 promptly notify all other Parties that it is withdrawing the inapplicable designation.
23 5.2. Manner and Timing of Designations. Except as otherwise provided in this
24 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or
25 ordered, Disclosure or Discovery Material that qualifies for protection under this Order
26 must be clearly so designated before the material is disclosed or produced.
27 Designation in conformity with this Order requires:
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1 (a) for information in documentary form (e.g., paper or electronic
2 documents, but excluding transcripts of depositions or other pretrial or trial proceedings),
3 that the Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter
4 “CONFIDENTIAL legend”), to each page that contains protected material. If only a portion
5 or portions of the material on a page qualifies for protection, the Producing Party also must
6 clearly identify the protected portion(s) (e.g., by making appropriate markings in the
7 margins).
8 A Party or Non-Party that makes original documents available for inspection need
9 not designate them for protection until after the inspecting Party has indicated which
10 documents it would like copied and produced. During the inspection and before the
11 designation, all of the material made available for inspection shall be deemed
12 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants
13 copied and produced, the Producing Party must determine which documents, or portions
14 thereof, qualify for protection under this Order. Then, before producing the specified
15 documents, the Producing Party must affix the “CONFIDENTIAL legend” to each page
16 that contains Protected Material. If only a portion or portions of the material on a page
17 qualifies for protection, the Producing Party also must clearly identify the protected
18 portion(s) (e.g., by making appropriate markings in the margins).
19 (b) for testimony given in depositions that the Designating Party identify
20 the Disclosure or Discovery Material on the record, before the close of the deposition all
21 protected testimony.
22 (c) for information produced in some form other than documentary and for
23 any other tangible items, that the Producing Party affix in a prominent place on the exterior
24 of the container or containers in which the information is stored the legend
25 “CONFIDENTIAL.” If only a portion or portions of the information warrants protection,
26 the Producing Party, to the extent practicable, shall identify the protected portion(s).
27 5.3. Inadvertent Failures to Designate. If timely corrected, an inadvertent failure
28 to designate qualified information or items does not, standing alone, waive the Designating
1 Party’s right to secure protection under this Order for such material. Upon timely correction
2 of a designation, the Receiving Party must make reasonable efforts to assure that the
3 material is treated in accordance with the provisions of this Order.
4 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
5 6.1. Timing of Challenges. Any Party or Non-Party may challenge a designation
6 of confidentiality at any time that is consistent with the Court’s Scheduling Order.
7 6.2. Meet and Confer. The Challenging Party shall initiate the dispute resolution
8 process under Local Rule 37.1 et seq. or follow the procedures for informal, telephonic
9 discovery hearings on the Court's website.
10 6.3. The burden of persuasion in any such challenge proceeding shall be on the
11 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., to
12 harass or impose unnecessary expenses and burdens on other parties) may expose the
13 Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn the
14 confidentiality designation, all parties shall continue to afford the material in question the
15 level of protection to which it is entitled under the Producing Party’s designation until the
16 Court rules on the challenge.
17 7. ACCESS TO AND USE OF PROTECTED MATERIAL
18 7.1. Basic Principles. A Receiving Party may use Protected Material that is
19 disclosed or produced by another Party or by a Non-Party in connection with this Action
20 only for prosecuting, defending, or attempting to settle this Action. Such Protected Material
21 may be disclosed only to the categories of persons and under the conditions described in
22 this Order. When the Action has been terminated, a Receiving Party must comply with the
23 provisions of section 13 below (FINAL DISPOSITION). Protected Material must be stored
24 and maintained by a Receiving Party at a location and in a secure manner that ensures that
25 access is limited to the persons authorized under this Order. Protected Material may not be
26 uploaded to any open or unsecure AI platforms.
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1 7.2. Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise
2 ordered by the court or permitted in writing by the Designating Party, a Receiving Party
3 may disclose any information or item designated “CONFIDENTIAL” only to:
4 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well
5 as employees of said Outside Counsel of Record to whom it is reasonably necessary to
6 disclose the information for this Action;
7 (b) the officers, directors, and employees (including House Counsel) of the
8 Receiving Party to whom disclosure is reasonably necessary for this Action;
9 (c) Experts (as defined in this Order) of the Receiving Party to whom
10 disclosure is reasonably necessary for this Action and who have signed the
11 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
12 (d) the court and its personnel;
13 (e) court reporters and their staff;
14 (f) professional jury or trial consultants, mock jurors, and Professional
15 Vendors to whom disclosure is reasonably necessary for this Action and who have signed
16 the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
17 (g) the author or recipient of a document containing the information or a
18 custodian or other person who otherwise possessed or knew the information;
19 (h) during their depositions, witnesses ,and attorneys for witnesses, in the
20 Action to whom disclosure is reasonably necessary provided: (1) the deposing party
21 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will not
22 be permitted to keep any confidential information unless they sign the “Acknowledgment
23 and Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating
24 Party or ordered by the court. Pages of transcribed deposition testimony or exhibits to
25 depositions that reveal Protected Material may be separately bound by the court reporter
26 and may not be disclosed to anyone except as permitted under this Stipulated Protective
27 Order; and
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1 (i) any mediator or settlement officer, and their supporting personnel,
2 mutually agreed upon by any of the parties engaged in settlement discussions.
3 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN
4 OTHER LITIGATION
5 If a Party is served with a subpoena or a court order issued in other litigation that
6 compels disclosure of any information or items designated in this Action as
7 “CONFIDENTIAL,” that Party must:
8 (a) promptly notification in writing the Designating Party. Such
9 notification shall include a copy of the subpoena or court order;
10 (b) promptly notify in writing the party who caused the subpoena or order
11 to issue in the other litigation that some or all of the material covered by the subpoena or
12 order is subject to this Protective Order. Such notification shall include a copy of this
13 Stipulated Protective Order; and
14 (c) cooperate with respect to all reasonable procedures sought to be
15 pursued by the Designating Party whose Protected Material may be affected.
16 If the Designating Party timely seeks a protective order, the Party served with the
17 subpoena or court order shall not produce any information designated in this action as
18 “CONFIDENTIAL” before a determination by the court from which the subpoena or order
19 issued, unless the Party has obtained the Designating Party’s permission. The Designating
20 Party shall bear the burden and expense of seeking protection in that court of its
21 confidential material and nothing in these provisions should be construed as authorizing or
22 encouraging a Receiving Party in this Action to disobey a lawful directive from another
23 court.
24 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED
25 IN THIS LITIGATION
26 (a) The terms of this Order are applicable to information produced by a
27 Non- Party in this Action and designated as “CONFIDENTIAL.” Such information
28 Produced by Non-Parties in connection with this litigation is protected by the remedies and
1 relief provided by this Order. Nothing in these provisions should be construed as
2 prohibiting a Non-Party from seeking additional protections.
3 (b) In the event that a Party is required, by a valid discovery request, to
4 produce a Non-Party’s confidential information in its possession, and the Party is subject
5 to an agreement with the Non-Party not to produce the Non-Party’s confidential
6 information, then the Party shall:
7 (1) Promptly notify in w writing the Requesting Party and the
8 Non-Party that some or all of the information requested is subject to a
9 confidentiality agreement with a Non-Party;
10 (2) promptly provide the Non-Party with a copy of the
11 Stipulated Protective Order in this Action, the relevant discovery request(s),
12 and a reasonably specific description of the information requested; and
13 (3) make the information requested available for inspection by
14 the Non-Party, if requested.
15 (c) If the Non-Party fails to seek a protective order from this court within
16 14 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. If
18 the Non-Party timely seeks a protective order, the Receiving Party shall not produce any
19 information in its possession or control that is subject to the confidentiality agreement with
20 the Non-Party before a determination by the court. Absent a court order to the contrary, the
21 Non-Party shall bear the burden and expense of seeking protection in this court of its
22 Protected Material.
23 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
24 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
25 Protected Material to any person or in any circumstance not authorized under this
26 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing the
27 Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve all
28 unauthorized copies of the Protected Material, (c) inform the person or persons to whom
1 unauthorized disclosures were made of all the terms of this Order, and (d) request such
2 person or persons to execute the “Acknowledgment and Agreement to Be Bound” that is
3 attached hereto as Exhibit A.
4 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
5 PROTECTED MATERIAL
6 When a Producing Party gives notice to Receiving Parties that certain inadvertently
7 produced material is subject to a claim of privilege or other protection, the obligations of
8 the Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B).
9 This provision is not intended to modify whatever procedure may be established in an e-
10 discovery order that provides for production without prior privilege review. Pursuant to
11 Federal Rule of Evidence 502(d) and (e), insofar as the parties reach an agreement on the
12 effect of disclosure of a communication or information covered by the attorney-client
13 privilege or work product protection, the parties may incorporate their agreement in the
14 stipulated protective order submitted to the court.
15 12. MISCELLANEOUS
16 12.1. Right to Further Relief. Nothing in this Order abridges the right of any person
17 to seek its modification by the Court in the future.
18 12.2. Right to Assert Other Objections. By stipulating to the entry of this Protective
19 Order no Party waives any right it otherwise would have to object to disclosing or
20 producing any information or item on any ground not addressed in this Stipulated
21 Protective Order. Similarly, no Party waives any right to object on any ground to use in
22 evidence of any of the material covered by this Protective Order.
23 12.3. Filing Protected Material. A Party that seeks to file under seal any Protected
24 Material must comply with Civil Local Rule 79-5. Protected Material may only be filed
25 under seal pursuant to a court order authorizing the sealing of the specific Protected
26 Material at issue. If a Party's request to file Protected Material under seal is denied by the
27 court, then the Receiving Party may file the information in the public record unless
28 otherwise instructed by the court.
1 13. FINAL DISPOSITION
2 After the final disposition of this Action, as defined in paragraph 4, within 60 days
3 of a written request by the Designating Party, each Receiving Party must return all
4 Protected Material to the Producing Party or destroy such material. As used in this
5 subdivision, “all Protected Material” includes all copies, abstracts, compilations,
6 summaries, and any other format reproducing or capturing any of the Protected Material.
7 Whether the Protected Material is returned or destroyed, the Receiving Party must submit
8 a written certification to the Producing Party (and, if not the same person or entity, to the
9 Designating Party) by the 60 day deadline that (1) identifies (by category, where
10 appropriate) all the Protected Material that was returned or destroyed and (2)affirms that
11 the Receiving Party has not retained any copies, abstracts, compilations, summaries or any
12 other format reproducing or capturing any of the Protected Material. Notwithstanding this
13 provision, Counsel are entitled to retain an archival copy of all pleadings, motion papers,
14 trial, deposition, and hearing transcripts, legal memoranda, correspondence, deposition and
15 trial exhibits, expert reports, attorney work product, and consultant and expert work
16 product, even if such materials contain Protected Material. Any such archival copies that
17 contain or constitute Protected Material remain subject to this Protective Order as set forth
18 in Section 4 (DURATION).
19 13.1. Any violation of this Order may be punished by any and all appropriate
20 measures including, without limitation, contempt proceedings and/or monetary sanctions.
21 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

22 DATED: July 29, 2026 SEYFARTH SHAW LLP

23
24 By: /s/ Kishaniah Dhamodaran
Mandana Massoumi
25 Kishaniah Dhamodaran
Mackenzie Mullin
26
Attorneys for Defendant
27 TARGET CORPORATION

28
1 {}]DATED: July 29, 2026 MERCER LEGAL GROUP
2
3 By:_/s/ Simon Moshkovich
4 Sara Salinas
5 Attorneys for Plaintiff
6 ALEC MARRUJO

7
8 SIGNATURE ATTESTATION
9 ||Pursuant to Local Rule 5-4.3.4(a)(2), I, Kishaniah Dhamodaran, certify that all other
10 ||signatories listed, on whose behalf the filing was submitted, concur in the filing’s content
11 have authorized the filing.
12
13
14. GOOD CAUSE SHOWN, IT IS SO ORDERED.

16 ||DATED: August 3, 2026 i fv /-
7 HON. DAVID’T. BRISTOW
United States Magistrate Judge
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1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3 I, _____________________________ [full name], of _________________ [full
4 address], declare under penalty of perjury that I have read in its entirety and understand
5 the Stipulated Protective Order that was issued by the United States District Court for the
6 Central District of California on ____________ [date] in the case of ___________ [insert
7 case name and number]. I agree to comply with and to be bound by all the terms of this
8 Stipulated Protective Order and I understand and acknowledge that failure to so comply
9 could expose me to sanctions and punishment in the nature of contempt. I solemnly
10 promise that I will not disclose in any manner any information or item that is subject to
11 this Stipulated Protective Order to any person or entity except in strict compliance with
12 the provisions of this Order. I further agree to submit to the jurisdiction of the United
13 States District Court for the Central District of California for the purpose of enforcing the
14 terms of this Stipulated Protective Order, even if such enforcement proceedings occur
15 after termination of this action. I hereby appoint __________________________ [full
16 name] of _______________________________________ [full address and telephone
17 number] as my California agent for service of process in connection with this action or
18 any proceedings related to enforcement of this Stipulated Protective Order.
19
20 Date: ______________________________________
21 City and State where signed: _________________________________
22 Printed name: _______________________________
23 Signature: __________________________________
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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/11427697. Public record. Not legal advice.