# Opinion

> District Court, C.D. California · August 27, 2026

URL: https://www.frixlaw.com/law-library/cases/11434302

## Case

- **Full name:** Bralin Bell v. County of Los Angeles; Does 1 through 10 inclusive
- **Court:** District Court, C.D. California
- **Decided:** August 27, 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/11434302

## Opinion text

1
2
3
4
5
6
7
8 UNITED STATES DISTRICT COURT
9 CENTRAL DISTRICT OF CALIFORNIA

BRALIN BELL, Cae No. 2:26-cv-03758-JAK-
Plaintiff,
12 DISCOVERY MATTER:
Vv. STIPULATED PROTECTIVE
COUNTY OF LOS ANGELES; and ORDER
14 | DOES 1 through 10 inclusive,
15 Defendants.
16
17
18
19
20
INTRODUCTION
22 1.1 PURPOSES AND LIMITATIONS
23 Discovery in this action is likely to involve production of confidential,
24 | proprietary, or private information for which special protection from public
25 | disclosure and from use for any purpose other than prosecuting this
26 | litigation may be warranted. Accordingly, the parties hereby stipulate to
27 | and petition the Court to enter the following Stipulated Protective Order.
28 | The parties acknowledge that this Order does not confer blanket protections

1 | on all disclosures or responses to discovery and that the protection it affords
2 |from public disclosure and use extends only to the limited information or
3 | items that are entitled to confidential treatment under the applicable legal
4 principles. The parties further acknowledge, as set forth in Section 12.3,
5 | below, that this Stipulated Protective Order does not entitle them to file
6 confidential information under seal; Civil Local Rule 79-5 sets forth the
7 | procedures that must be followed and the standards that will be applied
8 | when a party seeks permission from the court to file material under seal.
9 1.2 GOOD CAUSE STATEMENT
10 Plaintiff Bralin Bell filed this action against the County of Los Angeles
11 | and Doe defendants. The facts underlying Plaintiff's complaint arise from a
12 | September 22, 2024 encounter between Plaintiff and Los Angeles County
13 | Sheriff's Department deputies near Ardmore Avenue and Flower Street in
14 | Bellflower, California, in which deputies detained Plaintiff in connection
15 | with a suspected robbery based on information provided by two juveniles,
16 | and Plaintiff was thereafter released without charges, together with the
17 | Department's subsequent investigation of Plaintiff's government claim
18 | arising from that encounter.
19 As such, there may be voluminous sensitive materials, including police
20 reports, computer-aided dispatch and mobile data terminal records,
21 |criminal history and California Law Enforcement Telecommunications
22 |System returns, video and audio recordings and transcripts thereof,
23 | including body-worn camera footage, records containing the identities and
24 | personal identifying information of the juveniles involved in the underlying
25 incident, and other law enforcement records, which may be protected
26 | pursuant to Government Code § 7923.600 et seq. (formerly Government
27 | Code § 6254(f)), Penal Code §§ 832.5, 832.7, 832.8, and 11105, and Evidence
28 || Code § 1040. Further, it is possible the parties in this action may seek

1 | confidential information relating to individual peace officers, and as such
2 | their privacy rights are also implicated pursuant to Evidence Code § 1043
3 Pitchess v. Superior Court (1974) 11 Cal.8d 531, 535. See also Green v.
4 | Baca, 226 F.R.D. 624, 653 (C.D. Cal. 2005); A. Farber & Partners, Inc. v.
5 | Garber, 234 F.R.D. 186, 189-90 (C.D. Cal. 2006). Federal law also recognizes
6 | a qualified privilege for official information. Kerr v. United States District
7 | Court for the Northern District of California, 511 F.2d 192, 198 (9th Cir.
8 | 1975), aff'd, 426 U.S. 394 (1976); Sanchez v. City of Santa Ana, 936 F.2d
9 11027, 1033 (9th Cir. 1990), cert. denied, 502 U.S. 957 (1991). Without
10 | waiving objections to the production of such documentation and
11 |information, Defendants contend that such information is privileged as
12 | official information Cd.) It is the position of the County of Los Angeles that
13 | the release of such records cannot be considered absent a protective order
14 | and, in some cases, a court order.
15 Further, discovery may require depositions, written discovery, and/or
16 | the production of certain Los Angeles County Sheriff's Department policies
17 | and procedures and peace officer training information, the public disclosure
18 |of which could compromise officer safety and/or raise security issues.
19 | Defendant contends that public disclosure of such material and information
20 | poses a substantial risk of embarrassment, oppression, and/or physical
21 |}harm to peace officers whose confidential information is disclosed.
22 | Defendant further contends that this potential risk of harm to peace officers
23 greater than with other government employees due to the nature of their
24 | profession. Finally, Defendant contends that the benefit of public disclosure
25 |of such confidential information is minimal while the _ potential
26 | disadvantages are great.
27 Accordingly, to expedite the flow of information, to facilitate the
28 | prompt resolution of disputes over confidentiality of discovery materials, to

1 | adequately protect information the parties are entitled to keep confidential,
2 ensure that the parties are permitted reasonable necessary uses of such
3 | material in preparation for and in the conduct of trial, to address the
4 | handling of such material at the end of the litigation, and to serve the ends
5 | of justice, a protective order for such information is justified in this matter.
6 | It is the intent of the parties that information will not be designated as
7 | confidential for tactical reasons and that nothing will be so designated
8 | without a good faith belief that it has been maintained in a confidential,
9 non-public manner, and that there 1s good cause why it should not be part
10 | of the public record of this case.
11/2. DEFINITIONS
12 2.1 Action: Bralin Bell v. County of Los Angeles, et al., United States
13 | District Court, Central District of California, Case No. 2:26-cv-03758-JAK-
14 | PVCx.
15 2.2 Challenging Party: A Party or Non-Party that challenges the
16 | designation of information or items under this Order.
17 2.3 “CONFIDENTIAL” Information or Items: Information
18 | (regardless of how it is generated, stored or maintained) or tangible things
19 | that qualify for protection under Federal Rule of Civil Procedure 26(c), and
20 | as specified above in the Good Cause Statement.
21 2.4 Counsel: Outside Counsel of Record and House Counsel (as well
22 | as their support staff).
23 2.5 Designating Party: A Party or Non-Party that designates
24 | information or items that it produces in disclosures or in responses to
25 | discovery as “CONFIDENTIAL.”
26 2.6 Disclosure or Discovery Material: All items or information,
27 | regardless of the medium or manner in which it is generated, stored, or
28 | maintained (including, among other things, testimony, transcripts, and

1 | tangible things), that are produced or generated in disclosures or responses
2 | to discovery in this matter.
3 2.7 Expert: A person with specialized knowledge or experience in a
4 | matter pertinent to the litigation who has been retained by a Party or its
5 | counsel to serve as an expert witness or as a consultant in this Action.
6 2.8 House Counsel: Attorneys who are employees of a party to this
7 | Action. House Counsel does not include Outside Counsel of Record or any
8 | other outside counsel.
9 2.9 Non-Party: Any natural person, partnership, corporation,
10 | association, or other legal entity not named as a Party to this action.
11 2.10 Outside Counsel of Record: Attorneys who are not employees of
12 | a party to this Action but are retained to represent or advise a party to this
13 | Action and have appeared in this Action on behalf of that party or are
14 | affilated with a law firm which has appeared on behalf of that party, and
15 | includes support staff.
16 2.11 Party: Any party to this Action, including all of its officers,
17 | directors, employees, consultants, retained experts, and Outside Counsel of
18 | Record (and their support staffs).
19 2.12 Producing Party: A Party or Non-Party that produces Disclosure
20 | or Discovery Material in this Action.
21 2.13 Professional Vendors: Persons or entities that provide litigation
22 | support services (e.g., photocopying, videotaping, translating, preparing
23 | exhibits or demonstrations, and organizing, storing, or retrieving data in
24 | any form or medium) and their employees and subcontractors.
25 2.14 Protected Material: Any Disclosure or Discovery Material that
26 designated as “CONFIDENTIAL.”
27 2.15 Receiving Party: A Party that receives Disclosure or Discovery
28 | Material from a Producing Party.

SCOPE
2 The protections conferred by this Stipulation and Order cover not only
3 | Protected Material (as defined above), but also (1) any information copied or
4 | extracted from Protected Material; (2) all copies, excerpts, summaries, or
5 | compilations of Protected Material; and (3) any testimony, conversations, or
6 presentations by Parties or their Counsel that might reveal Protected
7 | Material.
8 Any use of Protected Material at trial will be governed by the orders
9 | of the trial judge. This Order does not govern the use of Protected Material
10 | at trial.
11/4. DURATION
12 Even after final disposition of this litigation, the confidentiality
13 | obligations imposed by this Order will remain in effect until a Designating
14 | Party agrees otherwise in writing or a court order otherwise directs. Final
15 | disposition will be deemed to be the later of (1) dismissal of all claims and
16 | defenses in this Action, with or without prejudice; and (2) final judgment
17 | herein after the completion and exhaustion of all appeals, rehearing’s,
18 | remands, trials, or reviews of this Action, including the time limits for filing
19 | any motions or applications for extension of time pursuant to applicable law.
20/5. DESIGNATING PROTECTED MATERIAL
21 5.1 Exercise of Restraint and Care in Designating Material for
22 | Protection: Each Party or Non-Party that designates information or items
23 | for protection under this Order must take care to limit any such designation
24 | to specific material that qualifies under the appropriate standards. The
25 | Designating Party must designate for protection only those parts of
26 | material, documents, items, or oral or written communications that qualify
27 | so that other portions of the material, documents, items, or communications
28 | for which protection is not warranted are not swept unjustifiably within the

1 | ambit of this Order.
2 Mass, indiscriminate, or routinized designations are prohibited.
3 | Designations that are shown to be clearly unjustified or that have been
4 |made for an improper purpose (e.g., to unnecessarily encumber the case
5 development process or to impose unnecessary expenses and burdens on
6 | other parties) may expose the Designating Party to sanctions.
7 If it comes to a Designating Party’s attention that information or items
8 |that it designated for protection do not qualify for protection, that
9 | Designating Party must promptly notify all other Parties that it is
10 | withdrawing the inapplicable designation.
11 5.2 Manner and Timing of Designations: Except as otherwise
12 | provided in this Order (see, e.g., second paragraph of section 5.2(a) below),
13 | or as otherwise stipulated or ordered, Disclosure or Discovery Material that
14 | qualifies for protection under this Order must be clearly so designated
15 | before the material is disclosed or 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
19 or trial proceedings), that the Producing Party affix at a minimum, the
20 legend “CONFIDENTIAL?” (hereinafter “CONFIDENTIAL legend”), to
21 each page that contains protected material. If only a portion or
22 portions of the material on a page qualifies for protection, the
23 Producing Party also must clearly identify the protected portion(s)
24 (e.g., by making appropriate markings in the margins).
25 A Party or Non-Party that makes original documents available for
26 | inspection need not designate them for protection until after the inspecting
27 | Party has indicated which documents it would like copied and produced.
28 | During the inspection and before the designation, all of the material made

1 | available for inspection will be deemed “CONFIDENTIAL.” After the
2 inspecting Party has identified the documents it wants copied and produced,
3 | the Producing Party must determine which documents, or portions thereof,
4 | qualify for protection under this Order. Then, before producing the specified
5 | documents, the Producing Party must affix the “CONFIDENTIAL legend”
6 | to each page that contains Protected Material. If only a portion or portions
7 | of the material on a page qualifies for protection, the Producing Party also
8 | must clearly identify the protected portion(s) (e.g., by making appropriate
9 | markings in the margins).
10 (b) For testimony given in depositions that the Designating Party
11 identify the Disclosure or Discovery Material on the record, before the
12 close of the deposition all protected testimony.
13 (c) For information produced in some form other than documentary
14 and for any other tangible items, that the Producing Party affix in a
15 prominent place on the exterior of the container or containers in which
16 the information is stored the legend “CONFIDENTIAL.” If only a
17 portion or portions of the information warrants protection, the
18 Producing Party, to the extent practicable, will identify the protected
19 portion(s).
20 5.3 Inadvertent Failures to Designate: If timely corrected, an
21 | inadvertent failure to designate qualified information or items does not,
22 | standing alone, waive the Designating Party’s right to secure protection
23 | under this Order for such material. Upon timely correction of a designation,
24 |the Receiving Party must make reasonable efforts to assure that the
25 || material is treated in accordance with the provisions of this Order.
26/6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
27 6.1 Timing of Challenges: Any Party or Non-Party may challenge a
28 || designation of confidentiality at any time that is consistent with the Court’s

1 | Scheduling Order.
2 6.2 Meet and Confer: The Challenging Party will initiate the dispute
3 | resolution process (and, if necessary, file a discovery motion) under Local
4 | Rule 387.1 et seq.
5 6.3 The burden of persuasion in any such challenge proceeding will
6 | be on the Designating Party. Frivolous challenges, and those made for an
7 |improper purpose (e.g., to harass or impose unnecessary expenses and
8 | burdens on other parties) may expose the Challenging Party to sanctions.
9 | Unless the Designating Party has waived or withdrawn the confidentiality
10 | designation, all parties will continue to afford the material in question the
11 level of protection to which it is entitled under the Producing Party’s
12 | designation until the Court rules on the challenge.
ACCESS TO AND USE OF PROTECTED MATERIAL
14 7.1 Basic Principles: A Receiving Party may use Protected Material
15 |that is disclosed or produced by another Party or by a Non-Party in
16 | connection with this Action only for prosecuting, defending, or attempting
17 | to settle this Action. Such Protected Material may be disclosed only to the
18 | categories of persons and under the conditions described in this Order.
19 | When the Action has been terminated, a Receiving Party must comply with
20 || the provisions of section 13 below (FINAL DISPOSITION).
21 Protected Material must be stored and maintained by a Receiving
22 | Party at a location and in a secure manner that ensures that access is
23 | limited to the persons authorized under this Order.
24 7.2 Disclosure of “CONFIDENTIAL” Information or Items: Unless
25 | otherwise ordered by the court or permitted in writing by the Designating
26 | Party, a Receiving Party may disclose any information or item designated
27 | “CONFIDENTIAL?” only to:
28 (a) The Receiving Party’s Outside Counsel of Record in this Action, as

1 well as employees of said Outside Counsel of Record to whom it is
2 reasonably necessary to disclose the information for this Action;
3 (b) The officers, directors, and employees (including House Counsel) of
4 the Receiving Party to whom disclosure is reasonably necessary for
5 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
8 the “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
13 and who have signed the “Acknowledgment and Agreement to Be
14 Bound” (Exhibit A);
15 (g) The author or recipient of a document containing the information
16 or a custodian or other person who otherwise possessed or knew the
17 information;
18 (h) During their depositions, witnesses, and attorneys for witnesses,
19 in the Action to whom disclosure is reasonably necessary provided: (1)
20 the deposing party requests that the witness sign the form attached
21 as Exhibit A hereto; and (2) they will not be permitted to keep any
22 confidential information unless they sign the “Acknowledgment and
23 Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the
24 Designating Party or ordered by the court. Pages of transcribed
25 deposition testimony or exhibits to depositions that reveal Protected
26 Material may be separately bound by the court reporter and may not
27 be disclosed to anyone except as permitted under this Stipulated
28 Protective Order; and

1 (i) Any mediator or settlement officer, and their supporting personnel,
2 mutually agreed upon by any of the parties engaged in settlement
3 discussions.
4/8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
5 PRODUCED IN OTHER LITIGATION
6 If a Party is served with a subpoena or a court order issued in other
7 | litigation that compels disclosure of any information or items designated in
8 | this Action as “CONFIDENTIAL,” that Party must:
9 (a) Promptly notify in writing the Designating Party. Such notification
10 will include a copy of the subpoena or court order;
11 (b) Promptly notify in writing the party who caused the subpoena or
12 order to issue in the other litigation that some or all of the material
13 covered by the subpoena or order is subject to this Protective Order.
14 Such notification will include a copy of this Stipulated Protective
15 Order; and
16 (c) Cooperate with respect to all reasonable procedures sought to be
17 pursued by the Designating Party whose Protected Material may be
18 affected.
19 If the Designating Party timely seeks a protective order, the Party
20 | served with the subpoena or court order will not produce any information
21 | designated in this action as “CONFIDENTIAL?” before a determination by
22 court from which the subpoena or order issued, unless the Party has
23 | obtained the Designating Party’s permission. The Designating Party will
24 | bear the burden and expense of seeking protection in that court of its
25 | confidential material and nothing in these provisions should be construed
26 authorizing or encouraging a Receiving Party in this Action to disobey a
27 | lawful directive from another court.
28

1/9. A NON-PARTYS PROTECTED MATERIAL SOUGHT TO BE
2 PRODUCED IN THIS LITIGATION
3 (a) The terms of this Order are applicable to information produced by
4 a Non-Party in this Action and designated as “CONFIDENTIAL.”
5 Such information produced by Non-Parties in connection with this
6 litigation is protected by the remedies and relief provided by this
7 Order. Nothing in these provisions should be construed as prohibiting
8 a Non-Party from seeking additional protections.
9 (b) In the event that a Party is required, by a valid discovery request,
10 to produce a Non-Party’s confidential information in its possession,
11 and the Party is subject to an agreement with the Non-Party not to
12 produce the Non-Party’s confidential information, then the Party will:
13 (1) Promptly notify in writing the Requesting Party and the Non-
14 Party that some or all of the information requested is subject to a
15 confidentiality agreement with a Non-Party;
16 (2) Promptly provide the Non-Party with a copy of the Stipulated
17 Protective Order in this Action, the relevant discovery request(s),
18 and a reasonably specific description of the information requested;
19 and
20 (3) Make the information requested available for inspection by the
21 Non-Party, if requested.
22 (c) If the Non-Party fails to seek a protective order from this court
23 within 14 days of receiving the notice and accompanying information,
24 the Receiving Party may produce the Non-Party’s confidential
25 information responsive to the discovery request. If the Non-Party
26 timely seeks a protective order, the Receiving Party will not produce
27 any information in its possession or control that is subject to the
28 confidentiality agreement with the Non-Party before a determination

1 by the court. Absent a court order to the contrary, the Non-Party will
2 bear the burden and expense of seeking protection in this court of its
3 Protected Material.
UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
5 If a Receiving Party learns that, by inadvertence or otherwise, it has
6 | disclosed Protected Material to any person or in any circumstance not
7 | authorized under this Stipulated Protective Order, the Receiving Party
8 | must immediately (a) notify in writing the Designating Party of the
9 | unauthorized disclosures, (b) use its best efforts to retrieve all unauthorized
10 | copies of the Protected Material, (c) inform the person or persons to whom
11 | unauthorized disclosures were made of all the terms of this Order, and (d)
12 |request such person or persons to execute the “Acknowledgment and
13 | Agreement to Be Bound” that is attached hereto as Exhibit A.
INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
15 PROTECTED MATERIAL
16 When a Producing Party gives notice to Receiving Parties that certain
17 | inadvertently produced material is subject to a claim of privilege or other
18 | protection, the obligations of the Receiving Parties are those set forth in
19 | Federal Rule of Civil Procedure 26(b)(5)(B). This provision is not intended
20 || to modify whatever procedure may be established in an e-discovery order
21 that provides for production without prior privilege review. Pursuant to
22 || Federal Rule of Evidence 502(d) and (e), insofar as the parties reach an
23 | agreement on the effect of disclosure of a communication or information
24 ||covered by the attorney-client privilege or work product protection, the
25 | parties may incorporate their agreement in the stipulated protective order
26 | submitted to the court.
2712. MISCELLANEOUS
28 12.1 Right to Further Relief: Nothing in this Order abridges the right

1 | of any person to seek its modification by the Court in the future.
2 12.2 Right to Assert Other Objections: By stipulating to the entry of
3 | this Protective Order no Party waives any right it otherwise would have to
4 | object to disclosing or producing any information or item on any ground not
5 | addressed in this Stipulated Protective Order. Similarly, no Party waives
6 | any right to object on any ground to use in evidence of any of the material
7 | covered by this Protective Order.
8 12.3 Filing Protected Material: A Party that seeks to file under seal
9 | any Protected Material must comply with Civil Local Rule 79-5. Protected
10 | Material may only be filed under seal pursuant to a court order authorizing
11 | the sealing of the specific Protected Material at issue. If a Party's request
12 |to file Protected Material under seal is denied by the court, then the
13 | Receiving Party may file the information in the public record unless
14 | otherwise instructed by the court.
FINAL DISPOSITION
16 After the final disposition of this Action, as defined in paragraph 4,
17 | within 60 days of a written request by the Designating Party, each Receiving
18 | Party must return all Protected Material to the Producing Party or destroy
19 | such material. As used in this subdivision, “all Protected Material” includes
20 | all copies, abstracts, compilations, summaries, and any other format
21 reproducing or capturing any of the Protected Material. Whether the
22 | Protected Material is returned or destroyed, the Receiving Party must
23 | submit a written certification to the Producing Party (and, if not the same
24 || person or entity, to the Designating Party) by the 60 day deadline that (1)
25 identifies (by category, where appropriate) all the Protected Material that
26 | was returned or destroyed and (2) affirms that the Receiving Party has not
27 | retained any copies, abstracts, compilations, summaries or any other format
28 | reproducing or capturing any of the Protected Material. Notwithstanding
-14-

1 |this provision, Counsel are entitled to retain an archival copy of all
2 | pleadings, motion papers, trial, deposition, and hearing transcripts, legal
3 | memoranda, correspondence, deposition and trial exhibits, expert reports,
4 | attorney work product, and consultant and expert work product, even if
5 |such materials contain Protected Material. Any such archival copies that
6 | contain or constitute Protected Material remain subject to this Protective
7 | Order as set forth in Section 4 (DURATION).
8 14. Any willful violation of this Order may be punished by civil or
9 | criminal contempt proceedings, financial or evidentiary sanctions, reference
10 | to disciplinary authorities, or other appropriate action at the discretion of
11 | the Court.
12
13
14
IS FOR GOOD CAUSE SHOWN BY THE PARTIES’ STIPULATION,
16 IT IS SO ORDERED.
7 fu Wh
18
19 Dated: August 27, 2026 HONORABLE PEDRO V. CASTILLO
UNITED STATES MAGISTRATE JUDGE
20
21
22
23
24

25
26

28

1 EXHIBIT A - ACKNOWLEDGMENT AND AGREEMENT TO BE
2 BOUND
3 I, [full name], of
4 [full address], declare under penalty of perjury that I have read in its
5 | entirety and understand the Stipulated Protective Order that was issued by
6 | the United States District Court for the Central District of California on
7 | [date] in the case of Bralin Bell v. County of Los Angeles, et al., United States
8 | District Court, Central District of California, Case No. 2:26-cv-03758-JAK-
9 | PVCx. I agree to comply with and to be bound by all the terms of this
10 | Stipulated Protective Order and I understand and acknowledge that failure
11 | 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
14 | person 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
16 | District Court for the Central District of California for the purpose of
17 enforcing the terms of this Stipulated Protective Order, even if such
18 | enforcement proceedings occur after termination of this action. I hereby
19 | appoint [full name] of
20 [full address and telephone
21 number] as my California agent for service of process in connection with
22 this action or any proceedings related to enforcement of this Stipulated
23 | Protective Order.
24
25 Date:
26 City and State where signed:
27 Printed name:
28 Signature:

---

Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/11434302. Public record. Not legal advice.