The opinion
1 || Eugene P. Ramirez (State Bar No. 134865)
eugene.ramirez@manningkass.com
2 Kayleigh Andersen (State Bar No. 306442)
kayleigh.andersen@manningkass.com
MANNING & KASS
|| ELLROD, RAMIREZ, TRESTER LLP
5 || 801 S. Figueroa St, 15" Floor
Los Angeles, California 90017-3012
6 || Telephone: (213) 624-6900
7 Facsimile: (213) 624-6999
Attorneys for Defendants, SHERIFF CHAD
9 || BIANCO, COUNTY OF RIVERSIDE, and
10 RIVERSIDE COUNTY SHERIFF’S
w DEPARTMENT.
11
— 12
= 13 UNITED STATES DISTRICT COURT
Ss 14 CENTRAL DISTRICT OF CALIFORNIA
<
= 15
16 || JOHNATHIN JAMES ONELLO, Case No. 5:25-cv-02703-MEMF-DTB
17 Plaintiff,
18 V. STIPULATED PROTECTIVE
ORDER RE CONFIDENTIAL
19 || SHERIFF CHAD BIANCO, in his DOCUMENTS
20 individual and official capacities;
COUNTY OF RIVERSIDE, a public Filed On: 10/14/25
21 || entity; RIVERSIDE COUNTY
5 || SHERIFF’S DEPARTMENT; and Trial Date: None Set
DOES 1-25,
23
Defendants.
25
26/11. | A. PURPOSES AND LIMITATIONS
27 Discovery in this action is likely to involve production of confidential,
28 proprietary, or private information for which special protection from public disclosure
1 |] and from use for any purpose other than prosecuting this litigation may be warranted.
2 || Accordingly, the parties hereby stipulate to and petition the Court to enter the
3 || following Stipulated Protective Order. The parties acknowledge that this Order does
4 ||not confer blanket protections on all disclosures or responses to discovery and that
5 || the protection it affords from public disclosure and use extends only to the limited
6 information or items that are entitled to confidential treatment under the applicable
7 || legal principles. The parties further acknowledge, as set forth in Section 12.3, below,
8 that this Stipulated Protective Order does not entitle them to file confidential
9 || information under seal; Civil Local Rule 79-5 sets forth the procedures that must be
n 10 || followed and the standards that will be applied when a party seeks permission from
2 11 || the court to file material under seal.
12 B. GOOD CAUSE STATEMENT
> 13 This action is likely to involve medical records, sensitive and confidential
14 || documents related to a death, documents containing private information from third
15 || parties, police investigation procedures and tactics, and other confidential and private
16 || information for which special protection from public disclosure and from use for any
17 || purpose other than prosecution of this action is warranted. Such confidential and
18 || proprietary materials and information consist of, among other things, confidential
personal information of non-parties, private medical and autopsy records, internal
20 □□ police reviews and procedures, and other confidential and sensitive information
21 || otherwise generally unavailable to the public, or which may be privileged or otherwise
22 || protected from disclosure under state or federal statutes, court rules, case decisions,
23 || or common law. Defendants contend that there is good cause for a protective order to
24 || maintain the confidentiality of peace officer personnel records. They emphasize that
25 ||releasing these records, which include internal analyses and legal communications,
26 || could hinder law enforcement investigations.
27 Accordingly, to expedite the flow of information, to facilitate the prompt
28 ||resolution of disputes over confidentiality of discovery materials, to adequately
1 || protect information the parties are entitled to keep confidential, to ensure that the
2 || parties are permitted reasonable necessary uses of such material in preparation for and
3 |/in the conduct of trial, to address their handling at the end of the litigation, and serve
4 || the ends of justice, a protective order for such information is justified in this matter.
5 || It is the intent of the parties that information will not be designated as confidential for
6 || tactical reasons and that nothing be so designated without a good faith belief that it
7||has been maintained in a confidential, non-public manner, and there is good cause
8 || why it should not be part of the public record of this case.
9 || 2. DEFINITIONS
n 10 2.1 Action: this pending federal law suit.
2 11 2.2 Challenging Party: a Party or Non-Party that challenges the designation of
12 || information or items under this Order.
> 13 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how
S 14]|it 1s generated, stored or maintained) or tangible things that qualify for protection
15 ||under Federal Rule of Civil Procedure 26(c), and as specified above in the Good
16 || Cause Statement.
17 2.4 Counsel: Counsel of Record and House Counsel (as well as their support
18 || staff).
19 2.5 Designating Party: a Party or Non-Party that designates information or
20 ||items that it produces in disclosures or in responses to discovery as
21 ||““CONFIDENTIAL.”
22 2.6 Disclosure or Discovery Material: all 1ttems or information, regardless of
23 ||the medium or manner in which it is generated, stored, or maintained (including,
24 ||among other things, testimony, transcripts, and tangible things), that are produced or
25 || generated in 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
28 || an expert witness or as a consultant in this Action.
1 2.8 House Counsel: attorneys who are employees of a party to this Action.
2 || House Counsel does not include Counsel of Record or any other outside counsel.
3 2.9 Non-Party: any natural person, partnership, corporation, association, or
4 || other legal entity not named as a Party to this action.
5 2.10 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
7 ||in this Action on behalf of that party or are affiliated with a law firm which has
8 || appeared on behalf of that party, and includes support staff.
9 2.11 Party: any party to this Action, including all of its officers, directors,
n 10 ||employees, consultants, retained experts, and Counsel of Record (and their support
< 11 || staffs).
12 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
> 13 || Discovery 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
16 || demonstrations, and organizing, storing, or retrieving data in any form or medium)
17 || and their employees and subcontractors.
18 2.14 Protected Material: any Disclosure or Discovery Material that is
19 || designated as “CONFIDENTIAL.”
20 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material
21 || from a Producing Party.
22 ||3. SCOPE
23 The protections conferred by this Stipulation and its associated Order cover not
24 || only Protected Material/Confidential Documents (as defined above), but also (1) any
25 ||information copied or extracted from Protected Material; (2) all copies, excerpts,
26 ||summaries, or compilations of Protected Material; and (3) any testimony,
27 || conversations, or presentations by Parties or their Counsel that might reveal Protected
28 || Material. However, the protections conferred by this Stipulation and its associated
1 || Order do not cover the following information: (a) any information that is in the public
2 || domain at the time of disclosure to a Receiving Party or becomes part of the public
3 || domain after its disclosure to a Receiving Party as a result of publication not involving
4 || a violation of this Order, including becoming part of the public record through trial or
5 ||otherwise; and (b) any information known to the Receiving Party prior to the
6 || disclosure or obtained by the Receiving Party after the disclosure from a source who
7 || obtained the information lawfully and under no obligation of confidentiality to the
8 || Designating Party.
9 Any use of Protected Material at trial shall be governed by the orders of the
n 10 || trial judge. This Order does not govern the use of Protected Material at trial.
11|/4. DURATION
12 Once a case proceeds to trial, all of the information that was designated as
> 13 || confidential or maintained pursuant to this protective order used or introduced as
14 || an exhibit at trial becomes public and will be presumptively available to all member
15 || of the public, including the press, unless compelling reasons supported by specific
factual findings to proceed otherwise are made to the trial judge in advance of the
17 || trial. See Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1180-81 (9%
18 || Cir. 2006) (distinguishing “good cause” showing for sealing documents produced in
19 || discovery from “compelling reasons” standard when merits-related documents are
20 || part of court record). Accordingly, the terms of this protective order do not extend
21 || beyond the commencement of the trial except as in accordance with this Section.
22/5. DESIGNATION OF PROTECTED MATERIAL
23 5.1. Exercise of Restraint and Care in Designating Material for Protection.
24 Each Party or non-party that designates information or items for protection
25 ||under this Stipulation and its associated Order must take care to limit any such
26 || designation to specific material that qualifies under the appropriate standards. A
27 || Designating Party must take care to designate for protection only those parts of
28 || material, documents, items, or oral or written communications that qualify — so that
1 |/other portions of the material, documents, items or communications for which
2 || protection is not warranted are not swept unjustifiably within the ambit of this Order.
3 Mass, indiscriminate, or routine designations are prohibited. Designations that
4 || are shown to be clearly unjustified, or that have been made for an improper purpose
5 || (e.g., to unnecessarily encumber or retard the case development process, or to impose
6 || unnecessary expenses and burdens on other parties), expose the Designating Party to
7 || 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
n 10 || promptly notify all other Parties that it is withdrawing the inapplicable designation.
2 11 5.2. Manner and Timing of Designations. Except as otherwise provided in
x 12 || this Order, or as otherwise stipulated or ordered, material that qualifies for protection
> 13 |}under this Order must be clearly so designated before the material is disclosed or
Ss 14 || produced.
15 Designation in conformity with this Order requires:
16 (a) for information in documentary form (apart from transcripts of
17 || depositions or other pretrial or trial proceedings, and regardless of whether produced
18||in hardcopy or electronic form), that the Producing Party affix the legend
19 || “CONFIDENTIAL: THESE DOCUMENTS ARE SUBJECT TO THE TERMS AND
20 |} CONDITIONS OF A PROTECTIVE ORDER, Case No. 5:24-cv-00777-KK-DTB”
21||to each page that contains Protected Material. If only a portion or portions of the
22 ||material on a page qualifies for protection, the Producing Party also must clearly
23 || identify the protected portion(s) (e.g., by making appropriate markings in the margins)
24 must specify, for each portion that it is “CONFIDENTIAL.” The placement of
25 ||}such “CONFIDENTIAL” stamp on such page(s) shall not obstruct the substance of
26 || the page’s (or pages’) text or content and shall be in the margin of the document
27 || whenever possible.
28 A Party or Non-Party that makes original documents or materials available for
1 |] inspection need not designate them for protection until after the inspecting Party has
2 ||indicated which material it would like copied and produced. During the inspection
3 || and before the designation, all of the material made available for inspection shall be
4 || deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents
5 || it wants copied and produced, the Producing Party must determine which documents,
6 || or portions thereof, qualify for protection under this Order. Then, before producing
7 ||the specified documents, the Producing Party must affix the “CONFIDENTIAL”
8 || legend to each page that contains Protected Material. If only a portion or portions of
9 || the material on a page qualifies for protection, the Producing Party also must clearly
n 10 ||identify the protected portion(s) (e.g., by making appropriate markings in the
2 11 || margins).
12 (b) fortestimony given in depositions that the Designating Party identify the
> 13 || Disclosure or Discovery Material on the record, before the close of the deposition all
S 14 || protected testimony.
15 (c) for information produced in some form other than documentary, and for
16 || any other tangible items (including but not limited to information produced on disc or
17 || electronic data storage device), that the Producing Party affix in a prominent place on
18 || the exterior of the container or containers in which the information or item is stored
19 || the legend “CONFIDENTIAL.” If only portions of the information or item warrant
20 || protection, the Producing Party, to the extent practicable, shall identify the protected
21 || portions, specifying the material as “CONFIDENTIAL.”
22 5.3. Inadvertent Failures to Designate. If timely corrected (preferably,
23 || though not necessarily, within 30 days of production or disclosure of such material),
24 |}an inadvertent failure to designate qualified information or items as
25 || “CONFIDENTIAL” does not, standing alone, waive the Designating Party’s right to
26 ||secure protection under this Stipulation and its associated Order for such material.
27 If material is appropriately designated as “CONFIDENTIAL” after the material
28 || was initially produced, the Receiving Party, on timely notification of the designation,
1 || must make reasonable efforts to assure that the material is treated in accordance with
2 || this Stipulation and its associated Order.
3 || 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS.
4 6.1. Timing of Challenges. Any Party or Non-Party may challenge a
5||designation of confidentiality at any time that is consistent with the Court's
6 || Scheduling Order.
7 6.2. Meet and Confer. The Challenging Party shall initiate the dispute
8 || resolution process under Local Rule 37.1 ef seq.
9 6.3. The burden of persuasion in any such challenge proceeding shall be on
n 10 || the Designating Party. Frivolous challenges, and those made for an improper purpose
2 11 ||(e.g., to harass or impose unnecessary expenses and burdens on other parties) may
x 12 || expose the Challenging Party to sanctions. Unless the Designating Party has waived
> 13 || or withdrawn the confidentiality designation, all parties shall continue to afford the
S 14 || material in question the level of protection to which it is entitled under the Producing
15 || Party’s designation until the Court rules on the challenge.
16 6.4. Withdrawal of “CONFIDENTIAL” Designation. At its discretion, a
17 || Designating Party may remove Protected Material/Confidential Documents from
18 ||some or all of the protections and provisions of this Stipulation and its associated
19 || Order at any time by any of the following methods:
20 (a) Express Written Withdrawal. A Designating Party may withdraw a
21 ||“CONFIDENTIAL” designation made to any specified Protected Material
22 ||/Confidential Documents from some or all of the protections of this Stipulation and
23 ||1ts associated Order by an express withdrawal in a writing signed by such Party (or
24 ||such Party’s Counsel, but not including staff of such Counsel) that specifies and
25 ||itemizes the Disclosure or Discovery Material previously designated as Protected
26 || Material/Confidential Documents that shall no longer be subject to all or some of the
27 || provisions of this Stipulation and Order. Such express withdrawal shall be effective
28 || when transmitted or served upon the Receiving Party. If a Designating Party is
1 || withdrawing Protected Material from only some of the provisions/ protections of this
2 || Stipulation and Order, such Party must state which specific provisions are no longer
3 ||to be enforced as to the specified material for which confidentiality protection
4\|hereunder is withdrawn: otherwise, such withdrawal shall be construed as a
5 || withdrawal of such material from all of the protections/provisions of this Stipulation
6 || and Order;
7 (b) Express Withdrawal on the Record. A Designating Party may withdraw
8jfa “CONFIDENTIAL” designation made to any _ specified Protected
9 || Material/Confidential Documents from all of the provisions/protections of this
n 10 || Stipulation and its associated Order by verbally consenting in court proceedings on
2 11||the record to such withdrawal — provided that such withdrawal specifies the
12 || Disclosure or Discovery Material previously designated as Protected Material/
> 13 || Confidential Documents that shall no longer be subject to any of the provisions of this
S 14]| Stipulation and Order. A Designating Party is not permitted to withdraw Protected
15 || Material from only some of the protections/provisions of this Stipulation and Order
16 || by this method;
17 (c) Implicit Withdrawal by Publication or Failure to Oppose Challenge. A
18 || Designating Party shall be construed to have withdrawn a “CONFIDENTIAL”
19 || designation made to any specified Protected Material/Confidential Documents from
20 || all of the provisions/protections of this Stipulation and Order by either (1) making
21 such Protected Material/Confidential Records part of the public record — including
22 ||but not limited to attaching such as exhibits to any filing with the court without
23 || moving, prior to such filing, for the court to seal such records; or (2) failing to timely
24 || oppose a Challenging Party’s motion to remove a “CONFIDENTIAL” designation to
25 || specified Protected Material/Confidential Documents. Nothing in this Stipulation and
26||Order shall be construed so as to require any Party to file Protected
27 || Material/Confidential Documents under seal, unless expressly specified herein.
28
1||7. ACCESS TO AND USE OF PROTECTED MATERIAL.
2 7.1. Basic Principles. A Receiving Party may use Protected Material that is
3 || disclosed or produced by another Party or by a non-party in connection with this case
4 || only for preparing, prosecuting, defending, or attempting to settle this litigation — up
5 || to and including final disposition of the above-entitled action — and not for any other
6 || purpose, including any other litigation or dispute outside the scope of this action.
7 || Such Protected Material may be disclosed only to the categories of persons and under
8 || the conditions described in this Stipulation and its associated Order. When the above
9 |/entitled litigation has been terminated, a Receiving Party must comply with the
n 10 || provisions of section 13, below (FINAL DISPOSITION).
2 11 Protected Material must be stored and maintained by a Receiving Party at a
x 12 location and in a secure manner that ensures that access is limited to the persons
> 13 || authorized under this Stipulation and its Order.
14 7.2. Disclosure _of “CONFIDENTIAL” Information or Items. Unless
15 || otherwise ordered by the Court or permitted in writing by the Designating Party, a
16 || Receiving Party may disclose any information or item designated CONFIDENTIAL
17 || only to:
18 (a) the Receiving Party’s Counsel of record in this action, as well as
19||employees of such Counsel to whom it is reasonably necessary to disclose the
20 || information for this litigation;
21 (b) the officers, directors, and employees (including House Counsel) of the
22 || Receiving Party to whom disclosure is reasonably necessary for this litigation — each
23 || of whom, by accepting receipt of such Protected Material, thereby agree to be bound
24 || by this Stipulation and Order;
25 (c) Experts (as defined in this Stipulation and Order) of the Receiving Party
26 ||to whom disclosure is reasonably necessary for this litigation — each of whom, by
27 || accepting receipt of such Protected Material, thereby agree to be bound by this
28 || Stipulation and Order;
1 (d) court reporters, their staffs, professional jury or trial consultants, mock
2 || jurors, and Professional Vendors to whom disclosure is reasonably necessary for this
3 || litigation — each of whom, by accepting receipt of such Protected Material, thereby
4 || agree to be bound by this Stipulation and Order;
5 (ec) during their depositions, witnesses in the action to whom disclosure is
6 ||reasonably necessary — each of whom, by accepting receipt of such Protected
7||Material, thereby agree to be bound by this Stipulation and Order. Pages of
8 || transcribed deposition testimony or exhibits to depositions that reveal Protected
9 || Material must have a confidential designation affixed by the court reporter to such
n 10 || pages containing Protected Material and such may not be disclosed to anyone except
2 11 || as permitted under this Stipulation and its Protective Order.
12 (f) the author or custodian of a document containing the information that
> 13 || constitutes Protected Material, or other person who otherwise possessed or knew the
Ss 14 || information.
15 (g) any mediator or settlement officer, and their supporting personnel,
16 || mutually agreed upon by any of the parties engaged in settlement discussions.
17 7.3. Notice of Confidentiality. Prior to producing or disclosing Protected
18 || Material/Confidential Documents to persons to whom this Stipulation and its Order
permits disclosure or production (see section 8.2, supra), a Receiving Party shall
20 || provide a copy of this Stipulation and Order to such persons so as to put such persons
21 |/on notice as to the restrictions imposed upon them herein: except that, for court
22 ||reporters, Professional Vendors, and for witnesses being provided with Protected
23 || Material during a deposition, it shall be sufficient notice for Counsel for the Receiving
24 || Party to give the witness a verbal admonition (on the record, for witnesses) regarding
25 || the provisions of this Stipulation and its Order and such provisions’ applicability to
26 || specified Protected Material at issue.
27 7.4. Reservation of Rights. Nothing in this Stipulation and Order shall be
28 || construed so as to require any Producing Party to designate any records or materials
1 |}as “CONFIDENTIAL.” Nothing in this Stipulation and Order shall be construed so
2 ||as to prevent the admission of Protected Material into evidence at the trial of this
3 || action, or in any appellate proceedings for this action, solely on the basis that such
4||Disclosure or Discovery Material has been designated as _ Protected
5 || Material/Confidential Documents. Notwithstanding the foregoing, nothing in this
6 || Stipulation and Order shall be construed as a waiver of any privileges or of any rights
7 ||to object to the use or admission into evidence of any Protected Material in any
8 || proceeding; nor shall anything herein be construed as a concession that any privileges
9 ||asserted or objections made are valid or applicable. Nothing in this Stipulation and
n 10 || Order shall be construed so as to prevent the Designating Party (or its Counsel or
2 11 || custodian of records) from having access to and using Protected Material designated
12 || by that Party in the manner in which such persons or entities would typically use such
> 13 || materials in the normal course of their duties or profession — except that the waiver of
14 || confidentiality provisions shall apply (see section 6.4(c), supra).
15 7.5. Requirement to File Confidential Documents Under Seal. Confidential
16 || Documents may be submitted in all law and motion proceedings before the Court if
17 || done so under seal pursuant to Federal Rules of Civil Procedure 5.2 and 26 and/or
18 || United States District Court, Central District of California Local Rules 79-5.1 and 79-
19||5.2 (as applicable) and pursuant to the provisions of this Stipulation and any
20 || associated Order. If any Receiving Party attaches any Confidential Documents to any
21 || pleading, motion, or other paper to be filed, lodged, or otherwise submitted to the
22 || Court, such Confidential Document(s) shall be filed/lodged under seal pursuant to
23 Federal Rules of Civil Procedure 5.2 and 26 and/or United States District Court,
24 || Central District of California Local Rules 79-5.1 and 79-5.2 to the extent applicable.
25 However, this paragraph (§] 7.5) shall not be construed so as to prevent a
26 || Designating Party or counsel from submitting, filing, lodging, or publishing any
||document it has previously designated as a Confidential Document without
28 || compliance with this paragraph’s requirement to do so under seal (1.e., a producing-
1 || disclosing party or counsel may submit or publish its own Confidential Documents
2 || without being in violation of the terms of this Stipulation and its Protective Order).
3 Furthermore, a Receiving Party shall be exempted from the requirements of
4||this paragraph as to any specifically identified Confidential Document(s) where —
5 || prior to the submission or publication of the Confidential Document(s) at issue — the
6 || Designating Party of such specifically identified Confidential Document(s) has
7 || waived/withdrawn the protections of this Stipulation and its Order (pursuant to
8 || paragraph 6.4, supra).
9 A Receiving Party shall also be exempt from the sealing requirements of this
n 10 || paragraph (4 7.5) where the Confidential Documents/Protected Material at issue is/are
2 11 ||not documents, records, or information regarding or incorporating:
12 (1) _ private, personal information contained in peace officer personnel files
> 13 (such as social security numbers, driver’s license numbers or comparable personal
14 || government identification numbers, residential addresses, compensation or pension
15 || or personal property information, credit card numbers or credit information, dates of
16 || birth, tax records and information, information related to the identity of an officer’s
17||family members or co-residents, and comparable personal information about the
18 || officer or his family);
19 (2) any internal affairs or comparable investigation by any law enforcement
20 || agency into alleged officer misconduct; and/or
21 (3) the medical records or records of psychiatric or psychological treatment
22 || of any peace officer or party to this action.
23 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
34 PRODUCED IN OTHER LITIGATION.
25 If a Party is served with a subpoena or a court order issued in other litigation
26 ||that compels disclosure of any information or items designated in this action as
27 || “CONFIDENTIAL,” that Party must:
28 (a) promptly notify in writing the Designating Party, preferably (though not
1 || necessarily) by facsimile or electronic mail. Such notification shall include a copy of
2 || the subpoena or court order at issue;
3 (b) promptly notify in writing the party who caused the subpoena or order to
4 ||issue in the other litigation that some or all of the material covered by the subpoena
5 || or order is subject to this Stipulation and its Protective Order. Such notification shall
6 || include a copy of this Stipulation and its Protective Order; and
7 (c) cooperate with respect to all reasonable procedures sought to be pursued
8 || by all sides in any such situation, while adhering to the terms of this Stipulation and
9 || its Order.
n 10 If the Designating Party timely seeks a protective order, the Party served with
2 11 || the subpoena or court order shall not produce any information designated in this action
12 “CONFIDENTIAL” before a determination by the court from which the subpoena
> 13 || or order issued, unless the Party has obtained the Designating Party’s permission. The
14 || Designating Party shall bear the burden and expense of seeking protection in that court
15 || of its confidential material — and nothing in these provisions should be construed as
authorizing or encouraging a Receiving Party in this action to disobey a lawful
17 || directive from another court.
18 The purpose of this section is to ensure that the affected Party has a meaningful
19 ||opportunity to preserve its confidentiality interests in the court from which the
20 || subpoena or court order issued.
21|}9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
PRODUCED IN THIS LITIGATION
(a) The terms of this Order are applicable to information produced by a Non-
Party in this Action and designated as “CONFIDENTIAL.” Such information
produced by Non-Parties in connection with this litigation is protected by the
remedies and relief provided by this Order. Nothing in these provisions should be
construed as prohibiting a Non-Party from seeking additional protections.
(b) In the event that a Party is required, by a valid discovery request, to
1 || produce a Non-Party’s confidential information in its possession, and the Party is
2||subject to an agreement with the Non-Party not to produce the Non-Party’s
3 || confidential information, then the Party shall:
4 (1) promptly notify in writing the Requesting Party and the Non-Party
5 that some or all of the information requested is subject to a
6 confidentiality agreement with a Non-Party;
7 (2) promptly provide the Non-Party with a copy of the Stipulated
8 Protective Order in this Action, the relevant discovery request(s),
9 and a reasonably specific description of the information requested;
10 and
11 (3) make the information requested available for inspection by the
12 Non-Party, if requested.
> 13||(c) Ifthe Non-Party fails to seek a protective order from this court within 14 days
14 ||of receiving the notice and accompanying information, the Receiving Party may
15 || produce the Non-Party’s confidential information responsive to the discovery request.
16 || Ifthe Non-Party timely seeks a protective order, the Receiving Party shall not produce
17||any information in its possession or control that is subject to the confidentiality
18 || 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 expense of seeking
20 || protection in this court of its Protected Material.
21|}10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL.
22 9.1. Unauthorized Disclosure of Protected Material.
23 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
24 || Protected Material to any person or in any circumstance not authorized under this
25 || Stipulation and Order, the Receiving Party must immediately:
26 (a) notify in writing the Designating Party of the unauthorized disclosures;
27 (b) use its best efforts to retrieve all copies of the Protected Material;
28 (c) inform the person or persons to whom unauthorized disclosures were made
1 || of all the terms of this Order; and
2 (d) request such person or persons consent to be bound by the Stipulation and
3 || Order.
4|/11. Inadvertent Production of Privileged or Otherwise Protected Material.
5 When a Producing Party gives notice to Receiving Parties that certain
6 || inadvertently produced material is subject to a claim of privilege or other protection,
7 obligations of the Receiving Parties are those set forth in Federal Rule of Civil
8 || Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
9 || may be established in an e-discovery order that provides for production without prior
n 10 || privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
2 11 parties reach an agreement on the effect of disclosure of a communication or
12 || information covered by the attorney-client privilege or work product protection, the
> 13 || parties may incorporate their agreement in the stipulated protective order submitted
Ss 14 || to the court.
15|}12. MISCELLANEOUS
16 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
17 || person 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 Order no Party waives any right it otherwise would have to object to
20 || disclosing or producing any information or item on any ground not addressed in this
21 || Stipulated Protective Order. Similarly, no Party waives any right to object on any
22 || ground to use in 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
24 || Protected Material must comply with Civil Local Rule 79-5. Protected Material may
25 || only be filed under seal pursuant to a court order authorizing the sealing of the specific
26 || Protected Material at issue. If a Party's request to file Protected Material under seal is
27 || denied by the court, then the Receiving Party may file the information in the public
28 || record unless otherwise instructed by the court.
1/13. FINAL DISPOSITION.
2 Unless otherwise ordered or agreed in writing by the Producing Party, within
3 || sixty (60) days after the final termination of this action (defined as the dismissal or
4 || entry of judgment by the above named court, or if an appeal is filed, the disposition
5 ||of the appeal), upon written request by the Producing Party, each Receiving Party
6 ||must return all Protected Material to the Producing Party or destroy — whether
7 || retained by the Receiving Party or its Counsel, Experts, Professional Vendors, agents,
8 ||or any non-party to whom the Receiving Party produced or shared such records or
9 || information. As used in this subdivision, “all Protected Material” includes all
n || copies, abstracts, compilations, summaries or any other form of reproducing or
2 11 ||capturing any of the Protected Material, regardless of the medium (hardcopy,
12 || electronic, or otherwise) in which such Protected Material is stored or retained.
> 13 In the alternative, at the discretion of the Receiving Party, the Receiving Party
|| may destroy some or all of the Protected Material instead of returning it — unless such
15 || Protected Material is an original, in which case, the Receiving Party must obtain the
16 || Producing Party’s written consent before destroying such original Protected Material.
17 Whether the Protected Material is returned or destroyed, the Receiving Party
18 || must submit a written certification to the Producing Party (and, if not the same person
□□ entity, to the Designating Party) within sixty (60) days of the aforementioned
20 || written request by the Designating Party that specifically identifies (by category,
21 || where appropriate) all the Protected Material that was returned or destroyed and that
22 || affirms that the Receiving Party has not retained any copies, abstracts, compilations,
23 ||summaries or other forms of reproducing or capturing any of the Protected material
24 || (in any medium, including but not limited to any hardcopy, electronic or digital copy,
25 || or otherwise).
26 Notwithstanding this provision, Counsel are entitled to retain an archival copy
27 ||of all pleadings, motion papers, transcripts, legal memoranda, deposition and trial
28 || exhibits, filed with the court in this action, as well as any correspondence or attorney
1 || work product prepared by Counsel for the Receiving Party, even if such materials
2 ||contain Protected Material; however, any such archival copies that contain or
3 || constitute Protected Material remain subject to this Protective Order as set forth in
4 || Section 4 (DURATION), above.
5 Any violation of this Order may be punished by any and all appropriate
6 ||including, without limitation, contempt proceedings and/or monetary sanctions.
7 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
|| DATED: September 3, 2026 MANNING & KASS
10 ELLROD, RAMIREZ, TRESTER LLP
v
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= 13 Eugene P. Ramirez
= 14 Kayleigh A. Andersen
<x Attorneys for Defendants, SHERIFF CHAD
= 15 BIANCO, COUNTY OF RIVERSIDE, and
RIVERSIDE COUNTY SHERIFF’S
16 DEPARTMENT.
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19 DATED: September 3, 2026 WALTER CLARK LEGAL GROUP, APC
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By: /s/ Dan C. Bolton
22 Walter T. Clark
3 Dan C. Bolton
Attorneys for Plaintiff, JOHNATHIN JAMES
24 ONELLO
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1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3 I, [print or type full
4 ||name], of [print or type full address], declare
5 || under penalty of perjury that I have read in its entirety and understand the Stipulated
6 || Protective Order that was issued by the United States District Court for the Central
7 || District of California on [date] inthe case □□ Johnathin James Onello
8 || v. County of Riverside, et al., Case No. 5:25-cv-02703-MEMF-DTB. I agree to
9 || comply with and to be bound by all the terms of this Stipulated Protective Order and
n 10 || I understand and acknowledge that failure to so comply could expose me to sanctions
2 11 || and punishment in the nature of contempt. I solemnly promise that I will not disclose
12 ||in any manner any information or item that is subject to this Stipulated Protective
> 13 || Order to any person or entity except in strict compliance with the provisions of this
14 || 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 [print
19 || or type full name] of [print or type
20 || full address and telephone number] as my California agent for service of process
21 ||in connection with this action or any proceedings related to enforcement of this
22 || Stipulated Protective Order.
23 || Date:
24 || City and State where sworn and signed:
25 || Printed name:
26 || Signature:
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* FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
3
4 DATED: September 3, 2026
5
8 || HON. DAVID T. BRISTOW
9 United States Magistrate Judge
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