The opinion
|| LUIS A. CARRILLO, SBN 70398
5 MICHAEL S. CARRILLO, SBN 258878
LAURA M. JIMENEZ, SBN 237273
3 ||} CARRILLO LAW FIRM, LLP
1499 Huntington Drive, Suite 402
South Pasadena, California 91030
5 || Tel: (626) 799-9375
Fax: (626) 799-9380
6
7 Attorneys for Plaintiffs
8 UNITED STATES DISTRICT COURT
9 CENTRAL DISTRICT OF CALIFORNIA
10
11 || FRANCISCA JANET LUCERO, Case No.: 2:25—cv—12156-WLH-AGR
1D BRIANNA SINOHUI, JOHN N.L
DOE, A MINOR BY AND Honorable Wesley Hsu
13 || THROUGH HIS GUARDIAN AD Magistrate Judge Christina T. Shay
14 LITEM, MAGGIE CONTRERAS,
JOHN J.L. DOE, A MINOR BY AND
15 || THROUGH HIS GUARDIAN AD
LITEM, MAGGIE CONTRERAS, | STIPULATED PROTECTIVE
16 ORDER
17 Plaintiffs,
18 y [DISCOVERY MATTER]
19
20 COUNTY OF LOS ANGELES, AND Complaint filed: 12/17/2025
DOES | THROUGH 20, FAC filed: 04/21/2026
|| INCLUSIVE,
2 Defendants.
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1 TO THE HONORABLE COURT:
2 By and through their counsel of record in this action, Plaintiffs FRANCISCA
3 || JANET LUCERO; BRIANNA SINOHUI; JOHN N.L. DOE, a MINOR BY and
|| THROUGH HIS GUARDIAN AD LITEM, MAGGIE CONTRERAS; AND JOHN
5 || J.L. DOE, a MINOR BY and THROUGH HIS GUARDIAN AD LITEM, MAGGIE
6||}CONTRERAS (“Plaintiffs”), and Defendant COUNTY OF LOS ANGELES
7 ||(“Defendant’), collectively “the parties” hereby stipulate for the purpose of jointly
8 ||requesting that the Honorable Court enter a protective order re confidential
9 || documents in this matter (and pursuant to Fed. R. Civ. P. Rules 5, 2, 7, and 26, as
|| well as U.S. Dist. Ct. C.D. Cal. Local Rules 7-1 and 52- 4.1; and any applicable
11 || Orders of the Court) as follows:
12|}1. PURPOSES AND LIMITATIONS/GOOD CAUSE STATEMENT
13 Discovery in this action is likely to involve production of confidential,
proprietary, or private information for which special protection from public
15 || disclosure and from use for any purpose other than prosecuting this litigation may
16 ||be warranted. Accordingly, the parties hereby stipulate to and petition the Court to
17||enter the following First Amended Joint Motion for Stipulated Protective Order
18 || (“Stipulated Protective Order”). The parties acknowledge that this Order does not
|| confer blanket protections on all disclosures or responses to discovery and that the
20 || protection it affords from public disclosure and use extends only to the limited
21 ||information or items that are entitled to confidential treatment under the applicable
22 ||legal principles. The parties further acknowledge, as set forth in Section 12.3,
23 || below, that this Stipulated Protective Order does not entitle them to file confidential
24 || information under seal; Civil Local Rule 79-5 sets forth the procedures that must be
25 || followed and the standards that will be applied when a party seeks permission from
26 || the court to file material under seal.
27||2. GOOD CAUSE STATEMENT
28 Plaintiffs and the individual Defendants may produce certain documents in
1 || this case that contain personal medical, employment, or financial information. Such
2 |\|information may implicate the privacy interests of the party and are properly
3 || protected through a Fed. R. Civ. P. 26(c) protective order. Seattle Times Co. v.
4 || Rhinehart, 467 U.S. 20, 35 n.21 (1984) (“Rule 26(c) includes among its express
5 ||purposes the protection of a ‘party or person from annoyance, embarrassment,
6 ||oppression or undue burden or expense.’ Although the Rule contains no specific
7 ||reference to privacy or to other rights or interests that may be implicated, such
8 || matters are implicit in the broad purpose and language of the Rule.”’); Soto v. City of
9 || Concord, 162 F.R.D. 603, 617 (N.D. Cal. 1995) (a party’s privacy rights are to be
10 || protected through a “carefully crafted protective order.”’).
11 As Plaintiffs are seeking and Defendants may produce, among other things,
12 || internal, security sensitive, third party, and law enforcement private and confidential
13 || information, administrative, personnel, and institutional documents, which contain
sensitive information that the County of Los Angeles believes needs special
protection from public disclosure. The documents identified in this Stipulated
16]|| Protective Order, which Defendants believe in good faith constitute or embody
|| confidential information which the County of Los Angeles maintains as strictly
18 || confidential and are otherwise generally unavailable to the public, or which may be
privileged or otherwise protected from disclosure under state or federal statutes,
20 ||court rules, case decisions, or common law, are therefore entitled to heightened
21 || protection from disclosure.
22 ||3. DEFINITIONS
23 3.1. Action: Francisca Janet Lucero, Brianna Sinohui, John N.L . Doe, a
24 ||minor by and through his guardian ad litem, Maggie Contreras, John J.L. Doe, a
25 ||minor by and through his guardian ad litem, Maggie Contreras v. County of Los
26 || Angeles, et al., USDC Case No. 2:25-cv—-12156-WLH-AGR.
27 3.2 Challenging Party: a Party or Non-Party that challenges the designation
28 || of information or items under this Order.
1 3.33. “CONFIDENTIAL” Information or Items: information (regardless of
2\|how it is generated, stored or maintained) or tangible things that qualify for
3 || protection under Federal Rule of Civil Procedure 26(c), and as specified above in
4 || the Good Cause Statement.
5 3.4 Counsel: Outside Counsel of Record and House Counsel (as well as
6 || their support staff).
7 3.5 Designating Party: a Party or Non-Party that designates information or
8|litems that it produces in disclosures or in responses to discovery as
9 || “CONFIDENTIAL.”
10 3.6 Disclosure or Discovery Material: all items or information, regardless
11 || of the medium or manner in which it is generated, stored, or maintained (including,
12 || among other things, testimony, transcripts, and tangible things), that are produced or
13 || generated in disclosures or responses to discovery in this matter.
14 3.7 Expert: a person with specialized knowledge or experience in a
15 || matter pertinent to the litigation who has been retained by a Party or its counsel to
16 || serve as an expert witness or as a consultant in this Action.
17 3.8 House Counsel: attorneys who are employees of a party to this
18 || Action. House Counsel does not include Outside Counsel of Record or any other
19 || outside counsel.
20 3.9 Non-Party: any natural person, partnership, corporation, association,
21 || or other legal entity not named as a Party to this action.
22 3.10 Outside Counsel of Record: attorneys who are not employees of a party
23 || to this Action but are retained to represent or advise a party to this Action and have
24 || appeared in this Action on behalf of that party or are affiliated with a law firm which
25 || has appeared on behalf of that party, and includes support staff.
26 3.11 Party: any party to this Action, including all of its officers, directors,
27 ||employees, consultants, retained experts, and Outside Counsel of Record (and their
28 || support staffs).
1 3.12 Producing Party: a Party or Non-Party that produces Disclosure or
2 || Discovery Material in this Action.
3 3.13 Professional Vendors: persons or entities that provide litigation support
4\lservices (e.g., photocopying, videotaping, translating, preparing exhibits or
5 || demonstrations, and organizing, storing, or retrieving data in any form or medium)
6 || and their employees and subcontractors.
7 3.14 Protected Material: any Disclosure or Discovery Material that is
8 || designated as “CONFIDENTIAL.”
9 3.15 Receiving Party: a Party that receives Disclosure or Discovery Material
10 || from a Producing Party.
11/4. SCOPE
12 The protections conferred by this Stipulation and Order cover not only
13 || Protected Material (as defined above), but also (1) any information copied or
extracted from Protected Material; (2) all copies, excerpts, summaries, or
15||compilations of Protected Material; and (3) any testimony, conversations, or
16 || presentations by Parties or their Counsel that might reveal Protected Material.
17 Any use of Protected Material at trial will be governed by the orders of the
18 || trial judge. This Order does not govern the use of Protected Material at trial.
|/5. DURATION
20 Even after final disposition of this litigation, the confidentiality obligations
21 ||imposed by this Order will remain in effect until a Designating Party agrees
22 || otherwise in writing or a court order otherwise directs. Final disposition will be
23 || deemed to be the later of (1) dismissal of all claims and defenses in this Action, with
24 |}or without prejudice; and (2) final judgment herein after the completion and
25 ||}exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action,
26 || including the time limits for filing any motions or applications for extension of time
27 || pursuant to applicable law.
28 || //
1/6. DESIGNATING PROTECTED MATERIAL
2 6.1 Exercise of Restraint and Care in Designating Material for Protection.
3 Each Party or Non-Party that designates information or_items for protection
4|/under this Order must take care to limit any such designation to specific material
5 || that qualifies under the appropriate standards. The Designating Party must designate
6||for protection only those parts of material, documents, items, or oral or written
7||communications that qualify so that other portions of the material, documents,
8 ||items, or communications for which protection is not warranted are not swept
9 || unjustifiably within the ambit of this Order.
10 Mass, indiscriminate, or routinized designations are prohibited. Designations
11||that are shown to be clearly unjustified or that have been made for an improper
12 || purpose (e.g., to unnecessarily encumber the case development process or to impose
13 ||}unnecessary expenses and burdens on other parties) may expose the Designating
14 || Party to sanctions.
15 If it comes to a Designating Party’s attention that information or items that it
|| designated for protection do not qualify for protection, that Designating Party must
17 || promptly notify all other Parties that it is withdrawing the inapplicable designation.
18 6.2. Manner and Timing of Designations.
19 Except as otherwise provided in this Order (see, e.g., second paragraph of
20 || section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure or Discovery
21 || Material that qualifies for protection under this Order must be clearly so designated
22 || 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
4 || inspection need not designate them for protection until after the inspecting Party has
5 ||indicated which documents it would like copied and produced. During the
6 ||inspection and before the designation, all of the material made available for
7 ||inspection will be deemed “CONFIDENTIAL.” After the inspecting Party has
8 || identified the documents it wants copied and produced, the Producing Party must
9 ||determine which documents, or portions thereof, qualify for protection under this
|| Order. Then, before producing the specified documents, the Producing Party must
11 || affix the “CONFIDENTIAL legend” to each page that contains Protected Material.
12 ||If only a portion or portions of the material on a page qualifies for protection, the
13 || Producing Party also must clearly identify the protected portion(s) (e.g., by making
14 || appropriate markings in the margins). Markings added to documents pursuant to this
15 || paragraph shall not obscure the content or text of the documents produced.
16 (b) for testimony given in depositions that the Designating Party
17 || identify the Disclosure or Discovery Material on the record, before the close of the
18 || deposition all protected testimony.
19 (c) for information produced in some form other than documentary
20 || and for any other tangible items, that the Producing Party affix in a prominent place
21 the exterior of the container or containers in which the information is stored the
22 || legend “CONFIDENTIAL.” [f only a portion or portions of the information warrant
23 || protection, the Producing Party, to the extent practicable, will identify the protected
24 || portion(s).
25 6.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
26 || failure to designate qualified information or items does not, standing alone, waive
27 || the Designating Party’s right to secure protection under this Order for such material.
28 || Upon timely correction of a designation, the Receiving Party must make reasonable
1 || efforts to assure that the material is treated in accordance with the provisions of this
2 || Order.
3 6.4 Privilege Logs. If a party withholds information that is responsive to a
|| discovery request by claiming that it is privileged or otherwise protected from
5 || discovery, that party shall promptly prepare and provide a privilege log that is
6 || sufficiently detailed and informative for the opposing party to assess whether a
7 ||document's designation as privileged is justified. See Fed. R. Civ. P. 26(b)(5). The
8 || privilege log shall set forth the privilege relied upon and specify separately for each
9 || document or for each category of similarly situated documents:
10 (a) the title and description of the document, including number of pages or
11 Bates-number range;
12 (b) the subject matter addressed in the document;
13 (c) the identity and position of its author(s);
14 (d) the identity and position of all addressees and recipients;
15 (ce) the date the document was prepared and, if different, the date(s) on
16 which it was sent to or shared with persons other than its author(s);
17 and
18 (f) the specific basis for the claim that the document is privileged and
19 protected.
20 Communications involving counsel that post-date the filing of the complaint
21 ||need not be placed on a privilege log.
22 However, a party withholding documents or communications on the basis of
23 ||the mediation privilege, whether arising under California Evidence Code sections
24 || 1115-1128 or federal common law, need not log such materials on an item-by-item
25 || basis. Instead, the withholding party may satisfy its obligations under this section by
26 || providing a categorical description identifying the nature of the withheld materials
27 ||as mediation communications and the general subject matter of the dispute
28 ||mediated, without identifying specific documents, their authors, recipients, or
1 || contents.
2 Categorical logging under this provision shall not apply to documents merely
3 ||referencing settlement discussions, underlying facts, or alleged admissions, or to
4 || materials that exist or existed independent of the mediation. Furthermore, materials
5 || otherwise discoverable shall not be withheld merely because they were presented or
6 || discussed in the course of mediation. Such documents must be logged individually if
7 || withheld on another basis.
8 || 7. CHALLENGING CONFIDENTIALITY DESIGNATIONS
9 7.1 Timing of Challenges. Any Party or Non-Party may challenge a
designation of confidentiality at any time that is consistent with the Court’s
11 || Scheduling Order.
12 7.2 Meet _and Confer. The Challenging Party will initiate the dispute
13 || resolution process under Local Rule 37.1 et seq.
14 7.3 The burden of persuasion in any such challenge proceeding will be on
15 ||the Designating Party. Frivolous challenges, and those made for an improper
purpose (e.g., to harass or impose unnecessary expenses and burdens on other
|| parties) may expose the Challenging Party to sanctions. Unless the Designating
18 Party has waived or withdrawn the confidentiality designation, all parties will
19 ||continue to afford the material in question the level of protection to which it is
20 entitled under the Producing Party’s designation until the Court rules on the
21 || challenge.
22/18. ACCESS TO AND USE OF PROTECTED MATERIAL
23 8.1 Basic Principles. A Receiving Party may use Protected Material that is
24 || disclosed or produced by another Party or by a Non-Party in connection with this
25 || Action only for prosecuting, defending, or attempting to settle this Action. Such
26 || Protected Material may be disclosed only to the categories of persons and under the
27||conditions described in this Order. When the Action has been terminated, a
28 || Receiving Party must comply with the provisions of section 13 below (FINAL
1 || DISPOSITION).
2 Protected Material must be stored and maintained by a Receiving Party at a
3 || location and in a secure manner that ensures that access is limited to the persons
4 || authorized under this Order.
5 8.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
6 || otherwise ordered by the court or permitted in writing by the Designating Party, a
7||Receiving Party may disclose any information or item designated
8 || “CONFIDENTIAL” only to:
9 (a) the Receiving Party’s Outside Counsel of Record in this Action,
10 ||as well as employees of said Outside Counsel of Record to whom it is reasonably
11 || necessary to disclose the information for this Action;
12 (b) the officers, directors, and employees (including House Counsel)
13 || of the Receiving Party to whom disclosure is reasonably necessary for this Action;
14 (c) Experts (as defined in this Order) of the Receiving Party to whom
15 ||disclosure is reasonably necessary for this Action, and who have signed the
16 || “Acknowledgment and Agreement to Be Bound” (Exhibit A);
17 (d) the Court and its personnel;
18 (e) court reporters and their staff;
19 (f) professional jury or trial consultants, mock jurors, and
20 || Professional Vendors to whom disclosure is reasonably necessary for this Action
21 ||and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit
22 || A);
23 (g) the author or recipient of a document containing the information
24 || or a custodian or other person who otherwise possessed or knew the information;
25 (h) during their depositions, witnesses, and attorneys for witnesses,
26 □□ □□ the Action to whom disclosure is reasonably necessary provided: (1) the deposing
27 || party requests that the witness sign the form attached as Exhibit A hereto; and (2)
28 || they will not be permitted to keep any confidential information unless they sign the
1 ||““Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
2||agreed by the Designating Party or ordered by the court. Pages of transcribed
3 || deposition testimony or exhibits to depositions that reveal Protected Material may
4 || be separately bound by the court reporter and may not be disclosed to anyone except
5 ||as permitted under this Stipulated Protective Order; and
6 (4) any mediator or settlement officer, and their supporting personnel,
7 ||mutually agreed upon by any of the parties engaged in settlement discussions.
8 || 9. PROTECTED _MATERIAL SUBPOENAED _ ORDERED
9 PRODUCED IN OTHER LITIGATION
10 If a Party is served with a subpoena or a court order issued in other litigation
11||that compels disclosure of any information or items designated in this Action as
12 || “CONFIDENTIAL,” that Party must:
13 (a) promptly notify in writing the Designating Party. Such notification will
14 || include a copy of the subpoena or court order;
15 (b) promptly notify in writing the party who caused the subpoena or order
16||to issue in the other litigation that some or all of the material covered by the
17 || subpoena or order is subject to this Protective Order. Such notification will include a
18 || copy of this Stipulated Protective Order; and
19 (c) cooperate with respect to all reasonable procedures sought to be pursued
20||by the Designating Party whose Protected Material may be affected. If the
Designating Party timely seeks a protective order, the Party served with the
22 || subpoena or court order will not produce any information designated in this action
23 |}as “CONFIDENTIAL” before a determination by the court from which the
24 ||subpoena or order issued, unless the Party has obtained the Designating Party’s
25 ||permission. The Designating Party will bear the burden and expense of seeking
26 || protection in that court of its confidential material and nothing in these provisions
27 || should be construed as authorizing or encouraging a Receiving Party in this Action
28 || to disobey a lawful directive from another court.
1/10. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
2 PRODUCED IN THIS LITIGATION
3 (a) The terms of this Order are applicable to information produced by a Non-
4|/Party in this Action and designated as “CONFIDENTIAL.” Such information
5 ||produced by Non-Parties in connection with this litigation is protected by the
6 ||remedies and relief provided by this Order. Nothing in these provisions should be
7 || construed as prohibiting a Non-Party from seeking additional protections.
8 (b) In the event that a Party is required, by a valid discovery request, to
9 || produce a Non-Party’s confidential information in its possession, and the Party is
10||subject to an agreement with the Non-Party not to produce the Non-Party’s
11 || confidential information, then the Party will:
12 (1) promptly notify in writing the Requesting Party and the Non
13 || Party that some or all of the information requested is subject to a confidentiality
14 || agreement with a Non-Party;
15 (2) promptly provide the Non-Party with a copy of the Stipulated
16 || Protective Order in this Action, the relevant discovery request(s), and a reasonably
specific description of the information requested; and (3) make the information
18 || requested available for inspection by the Non-Party, if requested.
19 (c) If the Non-Party fails to seek a protective order from this court within
20 || 14 days of receiving the notice and accompanying information, the Receiving Party
21||may produce the Non-Party’s confidential information responsive to the discovery
22 ||request. If the Non-Party timely seeks a protective order, the Receiving Party shall
23 ||not produce any information in its possession or control that is subject to the
24 || confidentiality agreement with the Non-Party before a determination by the court.
|| Absent a court order to the contrary, the Non-Party shall bear the burden and
26 || expense of seeking protection in this court of its Protected Material.
27|}11. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
28 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
1 || Protected Material to any person or in any circumstance not authorized under this
2 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
3 || writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
4 || to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
5 || persons to whom unauthorized disclosures were made of all the terms of this Order,
6||and (d) request such person or persons to execute the “Acknowledgment and
7 || Agreement to Be Bound” that is attached hereto as Exhibit A.
8|}12. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
9 PROTECTED MATERIAL
10 When a Producing Party gives notice to Receiving Parties that certain
11 inadvertently produced material is subject to a claim of privilege or other protection,
12 || the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
13 || Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
14||may be established in an e-discovery order that provides for production without
15 || prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar
16 || as the parties reach an agreement on the effect of disclosure of a communication or
17 || information covered by the attorney-client privilege or work product protection, the
18 || parties may incorporate their agreement in the stipulated protective order submitted
19 || to the court.
20|}13. MISCELLANEOUS
21 13.1 Right to Further Relief. Nothing in this Order abridges the right of
22 || any person to seek its modification by the Court in the future.
23 13.2 Right to Assert Other Objections. By stipulating to the entry of this
24 || Protective Order no Party waives any right it otherwise would have to object to
25 || disclosing or producing any information or item on any ground not addressed in this
26 || Stipulated Protective Order. Similarly, no Party waives any right to object on any
27 || ground to use in evidence of any of the material covered by this Protective Order.
28 13.3 Filing Protected Material. A Party that seeks to file under seal any
1 || Protected Material must comply with Civil Local Rule 79-5. Protected Material may
2 ||only be filed under seal pursuant to a court order authorizing the sealing of the
3 || specific Protected Material at issue. If a Party’s request to file Protected Material
4 || under seal is denied by the court, then the Receiving Party may file the information
5 ||in the public record unless otherwise instructed by the court.
6||14. FINAL DISPOSITION
7 After the final disposition of this Action, as defined in paragraph 4, within 60
8 || days of a written request by the Designating Party, each Receiving Party must return
9 Protected Material to the Producing Party or destroy such material. As used in
10 || this subdivision, “all Protected Material” includes all copies, abstracts, compilations,
11 ]}summaries, and any other format reproducing or capturing any of the Protected
12 || Material. Whether the Protected Material is returned or destroyed, the Receiving
13 || Party must submit a written certification to the Producing Party (and, if not the same
14]| person or entity, to the Designating Party) by the 60 day deadline that (1) identifies
category, where appropriate) all the Protected Material that was returned or
16|| destroyed and (2) affirms that the Receiving Party has not retained any copies,
17 || abstracts, compilations, summaries or any other format reproducing or capturing any
18 || of the Protected Material. Notwithstanding this provision, Counsel are entitled to
19 || retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing
20 || transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
21 ||reports, attorney work product, and consultant and expert work product, even if such
22 ||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 || //
27 || //
28 || //
1 15. Any willful violation of this Order may be punished by civil or criminal
2 ||contempt proceedings, financial or evidentiary sanctions, reference to disciplinary
3 || authorities, or other appropriate action at the discretion of the Court.
4
5|}IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
6
7 Dated: August 24, 2026 CARRILLO LAW FIRM, LLP
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/s/ Laura M. Jimenez
10 Michael S. Carrillo, Esq.
1 Laura M. Jimenez, Esq.
Attorneys for Plaintiffs
12
13 |) Dated: August 24, 2026 DAVID WEISS LAW
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15 /s/ David J. Weiss
16 David J. Weiss, Esq.
Nicholas A. Weiss, Esq.
17 Ernie Chen, Esq.
18 County of Los Angeles
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1 HAVING CONSIDERED THE STIPULATION OF THE PARTIES, AND
2||(GOOD CAUSE SHOWN, THE FIRST AMENDED JOINT MOTION FOR
3 || STIPULATED PROTECTIVE ORDER IS GRANTED AND IT IS SO ORDERED
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6|I|DATE: August 24, 2026 CS
7 Honorable Christina T. Shay
United States Magistrate Judge
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1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3 I, [print or type full name], of
4 [print or type full address], declare under penalty of perjury
5 || that I have read in its entirety and understand the Stipulated Protective Order that
6 || was issued by the United States District Court for the Central District of California
7 \lon [date] in the case of Francisca Janet Lucero, Brianna Sinohui, John
8 || N.L. Doe, a minor by and through his guardian ad litem, Maggie Contreras, John
9 || J.L. Doe, a minor by and through his guardian ad litem, Maggie Contreras v. County
10 || of Los Angeles, et al., USDC Case No. 2:25-cv-09230-WLH-AS. I agree to comply
11 || with and to be bound by all the terms of this Stipulated Protective Order and I
12 || understand and acknowledge that failure to so comply could expose me to sanctions
13 || and punishment in the nature of contempt. I solemnly promise that I will not
14 || disclose in any manner any information or item that is subject to this Stipulated
15 || Protective Order to any person or entity except in strict compliance with the
16 || provisions of this Order.
17 I further agree to submit to the jurisdiction of the United States District Court
18 || for the Central District of California for the purpose of enforcing the terms of this
19 || Stipulated Protective Order, even if such enforcement proceedings occur after
20 || termination of this action. I hereby appoint [print or
21 type full name] of [print or type
22 || full address and telephone number] as my California agent for service of process in
23 || connection with this action or any proceedings related to enforcement of this
24 || Stipulated Protective Order.
25 || Date:
26 || City and State where signed:
27 || Printed name:
28 || Signature: