ESTATE OF FRANCISCO NUNEZ by and through his successors in interest; MERCEDES SALINAS DE NUNEZ, individually; FRANCISCO NUNEZ NINO, individually; A.N.1, a minor, by and through their guardian ad litem

• Court: District Court, C.D. California
• Decided: October 20, 2025
• Docket: 2:25-cv-02588
• Status: Unknown

Opinion

1 LEWIS BRISBOIS BISGAARD & SMITH LLP TONY M. SAIN, SB# 251626 2 E-Mail: Tony.Sain@lewisbrisbois.com TORI L. N. BAKKEN, SB# 329069 3 E-Mail: Tori.Bakken@lewisbrisbois.com ABIGAIL J. R. McLAUGHLIN, SB# 313208 4 E-Mail: Abigail.McLaughlin@lewisbrisbois.com 633 West 5th Street, Suite 4000 5 Los Angeles, California 90071 Telephone: 213.250.1800 6 Facsimile: 213.250.7900

7 Attorneys for Defendants, COUNTY OF LOS ANGELES (erroneously sued as 8 LOS ANGELES COUNTY), LOGAN SIMI, SHANE QUESADA, and NOEL 9 WITTY

10 UNITED STATES DISTRICT COURT 11 CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION 12 13 ESTATE OF FRANCISCO NUNEZ by Case No. 2:25-cv-02588-MWC (AGR) and through his successors in interest; [Hon. Michelle Williams Court, Dist. 14 MERCEDES SALINAS DE NUNEZ, Judge; Hon. Alicia G. Rosenburg, M. individually; FRANCISCO NUNEZ Judge] 15 NINO, individually; A.N.1, a minor, by and through their guardian ad litem 16 ADRIANA HERNANDEZ; A.N.2, a [DISCOVERY MATTER] minor, by and through their guardian ad 17 litem, ADRIANA HERNANDEZ; F.N., a minor, by and through their guardian PROTECTIVE ORDER RE 18 VANESSA RODRIGUEZ; B.N., a CONFIDENTIAL DOCUMENTS minor, by and through their guardian 19 VANESSA RODRIGUEZ; ALEXUS ROUGHFACE, individually; Trial Date: November 30, 2026 20 MARIANNA NUNEZ, individually,

21 Plaintiffs,

22 vs.

23 LOS ANGELES COUNTY SHERIFF’S DEPARTMENT, a public 24 entity; LOS ANGELES COUNTY, a public entity; LOGAN SIMI, an 25 individual; SHANE QUESADA, an individual; NOEL WITTY, an 26 individual; DOES 1 through 10, individually, 27 Defendants. 1 1. A. PURPOSES AND LIMITATIONS 2 Discovery in this action is likely to involve production of confidential, 3 proprietary, or private information for which special protection from public disclosure 4 and from use for any purpose other than prosecuting this litigation would be 5 warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter 6 the following Stipulated Protective Order. The parties acknowledge that this Order 7 does not confer blanket protections on all disclosures or responses to discovery and 8 that the protection it affords from public disclosure and use extends only to the limited 9 information or items that are entitled to a confidential treatment under the applicable 10 legal principles. The parties further acknowledge, as set forth in Section 12.3, below, 11 that this Stipulated Protective Order does not entitle them to file confidential 12 information under seal; Civil Local Rule 79-5 sets forth the procedures that must be 13 followed and the standards that will be applied when a party seeks permission from 14 the court to file material under seal. 15 B. GOOD CAUSE STATEMENT 16 Defendants contend that there is good cause and a particularized need for a 17 protective order to preserve the interests of confidentiality and privacy in peace officer 18 personnel file records and associated investigative or confidential records for the 19 following reasons. 20 First, Defendants contend that peace officers have a federal privilege of privacy 21 in their personnel file records: a reasonable expectation of privacy therein that is 22 underscored, specified, and arguably heightened by the Pitchess protective procedure 23 of California law. See Sanchez v. Santa Ana Police Dept., 936 F.2d 1027, 1033–34 24 (9th Cir. 1990); Hallon v. City of Stockton, 2012 U.S. Dist. LEXIS 14665, *2-3, 12- 25 13 (E.D. Cal. 2012) (concluding that “while “[f]ederal law applies to privilege based 26 discovery disputes involving federal claims,” the “state privilege law which is 27 consistent with its federal equivalent significantly assists in applying [federal] 1 n. 4, 616 (N.D. Cal. 1995) (peace officers have constitutionally-based “privacy rights 2 [that] are not inconsequential” in their police personnel records); cf. Cal. Penal Code 3 §§ 832.7, 832.8; Cal. Evid. Code §§ 1040-1047. Defendants further contend that 4 uncontrolled disclosure of such personnel file information can threaten the safety of 5 non-party witnesses, officers, and their families/associates. 6 Second, Defendants contend that municipalities and law enforcement agencies 7 have federal deliberative-executive process privilege, federal official information 8 privilege, federal law enforcement privilege, and federal attorney-client privilege 9 (and/or attorney work product protection) interests in the personnel files of their peace 10 officers – particularly as to those portions of peace officer personnel files that contain 11 critical self-analysis, internal deliberation/decision-making or evaluation/analysis, or 12 communications for the purposes of obtaining or rendering legal advice or analysis – 13 potentially including but not limited to evaluative/analytical portions of Internal 14 Affairs type records or reports, evaluative/analytical portions of supervisory records 15 or reports, and/or reports prepared at the direction of counsel, or for the purpose of 16 obtaining or rendering legal advice. See Sanchez, 936 F.2d at 1033–34; Maricopa 17 Audubon Soc’y v. United States Forest Serv., 108 F.3d 1089, 1092–95 (9th Cir. 1997); 18 Soto, 162 F.R.D. at 613 & n4; Kelly v. City of San Jose, 114 F.R.D. 654, 668–71 (N.D. 19 Cal. 1987); Tuite v. Henry, 181 F.R.D. 175, 176–77 (D. D.C. 1998); Hamstreet v. 20 Duncan, 2007 U.S. Dist. LEXIS 89702 (D. Or. 2007); Admiral Ins. Co. v. United 21 States Dist. Ct., 881 F.2d 1486, 1492, 1495 (9th Cir. 1988). Defendants further 22 contend that such personnel file records are restricted from disclosure by the public 23 entity’s custodian of records pursuant to applicable California law and that 24 uncontrolled release is likely to result in needless intrusion of officer privacy; 25 impairment in the collection of third-party witness information and statements 26 and related legitimate law enforcement investigations/interests; and a chilling of 27 open and honest discussion regarding and/or investigation into alleged 1 any remedial measures that may be required. 2 Third, Defendants contend that, since peace officers do not have the same rights 3 as other private citizens to avoid giving compelled statements, it is contrary to the 4 fundamental principles of fairness to permit uncontrolled release of officers’ 5 compelled statements. See generally Lybarger v. City of Los Angeles, 40 Cal.3d 822, 6 828–30 (1985); cf. U.S. Const., amend V. 7 Accordingly, Defendants contend that, without a protective order preventing 8 such, production of confidential records in the case can and will likely substantially 9 impair and harm defendant public entity’s interests in candid self-critical analysis, 10 frank internal deliberations, obtaining candid information from witnesses, preserving 11 the safety of witnesses, preserving the safety of peace officers and peace officers’ 12 families and associates, protecting the privacy officers of peace officers, and 13 preventing pending investigations from being detrimentally undermined by 14 publication of private, sensitive, or confidential information – as can and often does 15 result in litigation. 16 Plaintiffs do not agree with and do not stipulate to Defendants’ contentions 17 stated above. Plaintiffs agree, however, that there is good cause for a Protective Order 18 so as to preserve the respective interests of the parties. Plaintiffs recognize that, 19 absent this Stipulated Protective Order, the parties' respective privilege interests may 20 be impaired or harmed, and that this Stipulated Protective Order may mitigate such 21 harm by permitting the parties to facilitate discovery with reduced risk that 22 confidential information will become matters of public record. 23 The parties jointly contend that there is typically a particularized need for 24 protection as to any medical or psychotherapeutic records and autopsy photographs, 25 because of the privacy interests at stake therein. Plaintiffs A.N.1, A.N.2, F.N., and 26 B.N. are minors, and there may be a need to protect certain records pertaining to them. 27 Because of these sensitive interests, a Court Order should address these documents 1 2. DEFINITIONS 2 2.1 Action: this pending federal law suit. 3 2.2 Challenging Party: a Party or Non-Party that challenges the designation 4 of information or items under this Order. 5 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 6 the medium or how generated, stored, or maintained) or tangible things that qualify 7 for protection under Federal Rule of Civil Procedure 26(c), as specified above in the 8 Good Cause Statement, and other applicable federal privileges. 9 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 10 support staff). 11 2.5 Designating Party: a Party or Non-Party that designates information or 12 items that it produces in disclosures or in responses to discovery as 13 “CONFIDENTIAL.” 14 2.6 Disclosure or Discovery Material: all items or information, regardless 15 of the medium or manner generated, stored, or maintained (including, among other 16 things, testimony, transcripts, or tangible things), that are produced or generated in 17 disclosures or responses to discovery in this matter. 18 2.7 Expert: a person with specialized knowledge or experience in a matter 19 pertinent to the litigation who has been retained by a Party or its counsel to serve as 20 an expert witness or as a consultant in this Action. 21 2.8 House Counsel: attorneys who are employees of a Party to this Action. 22 House Counsel does not include Outside Counsel of Record or any other outside 23 counsel. 24 2.9 Non-Party: any natural person, partnership, corporation, association, or 25 other legal entity not named as a Party to this action. 26 2.10 Outside Counsel of Record: attorneys who are not employees of a party 27 to this Action but are retained to represent or advise a party to this Action and have 1 has appeared on behalf of that party, and includes support staff. 2 2.11 Party: any part to this Action, including all of its officers, directors, 3 employees, consultants, retained experts, and Outside Counsel of Record (and their 4 support staffs). 5 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 6 Discovery Material in this Action. 7 2.13 Professional Vendors: persons or entities that provide litigation support 8 services (e.g., photocopying; videotaping; translating; preparing exhibits or 9 demonstrations; and organizing, storing, or retrieving data in any form or medium) 10 and their employees and subcontractors. 11 2.14 Protected Material: any Disclosure or Discovery Material that is 12 designated as “CONFIDENTIAL.” 13 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 14 from a Producing Party. 15 3. SCOPE 16 The protections conferred by this Stipulation and Order cover not only 17 Protected Material (as defined above), but also (1) any information copied or 18 extracted from Protected Material; (2) all copies, excerpts, summaries, or 19 compilations of Protected Material; and (3) any testimony, conversations, or 20 presentations by Parties or their Counsel that might reveal Protected Material. 21 Any use of Protected Material at trial shall be governed by the Orders of the 22 trial judge. This Order does not govern the use of Protected Material at trial. 23 4. DURATION 24 Even after final disposition of this litigation, the confidentiality obligations 25 imposed by this Order shall remain in effect until a Designating Party agrees 26 otherwise in writing or a court order otherwise directs. Final disposition shall be 27 deemed to be the later of (1) dismissal of all claims and defenses in this Action, with 1 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 2 including the time limits for filing any motions or applications for extension of time 3 pursuant to applicable law. 4 5. DESIGNATING PROTECTED MATERIAL 5 5.1 Exercise of Restraint and Care in Designating Material for Protection. 6 Each Party or Non-Party that designates information or items for protection 7 under this Order must take care to limit any such designation to specific material that 8 qualifies under the appropriate standards. The Designating Party must designate for 9 protection only those parts of material, documents, items, or oral or written 10 communications that qualify so that other portions of the material, documents, items, 11 or communications for which protection is not warranted are not swept unjustifiably 12 within the ambit of this Order. 13 Mass, indiscriminate, or routine designations are prohibited. Designations that 14 are shown to be clearly unjustified, or that have been made for an improper purpose 15 (e.g., to unnecessarily encumber the case development process or to impose 16 unnecessary expenses and burdens on other parties) may expose the Designating Party 17 to sanctions. 18 If it comes to a Designating Party’s attention that information or items that it 19 designated for protection do not qualify for protection, that Designating Party must 20 promptly notify all other parties that it is withdrawing the inapplicable designation. 21 5.2 Manner and Timing of Designations. Except as otherwise provided in 22 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 23 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 24 under this Order must be clearly so designated before the material is disclosed or 25 produced. 26 Designation in conformity with this Order requires: 27 (a) for information in documentary form (e.g., paper or electronic 1 proceedings), that the Producing Party affix at a minimum, the legend 2 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 3 contains protected material. If only a portion or portions of the material on a page 4 qualifies for protection, the Producing Party also must clearly identify the protected 5 portion(s) (e.g., by making appropriate markings in the margins). 6 A Party or Non-Party that makes original documents available for inspection 7 need not designate them for protection until after the inspecting Party has indicated 8 which documents it would like copied and produced. During the inspection and before 9 the designation, all of the material made available for inspection shall be deemed 10 “CONFIDENTIAL.” After the inspecting Party has identified the documents it wants 11 copied and produced, the Producing Party must determine which documents, or 12 portions thereof, qualify for protection under this Order. Then, before producing the 13 specified documents, the Producing Party must affix the “CONFIDENTIAL legend” 14 to each page that contains Protected Material. If only a portion or portions of the 15 material on a page qualifies for protection, the Producing Party also must clearly 16 identify the protected portion(s) (e.g., by making appropriate markings in the 17 margins). Markings added to documents pursuant to this paragraph shall not obscure 18 the content or text of the documents produced. 19 (b) for testimony given in depositions that the Designating Party 20 identify the Disclosure or Discovery Material on the record, before the close of the 21 deposition all protected testimony. The court reporter must affix to each such 22 transcript page containing Protected Material the “CONFIDENTIAL legend”, as 23 instructed by the Designating Party. 24 (c) for information produced in some form other than documentary 25 and for any other tangible items, that the Producing Party affix in a prominent place 26 on the exterior of the container or containers in which the information or item is stored 27 the legend “CONFIDENTIAL.” If only a portions or portions of the information or 1 the protected portion(s). 2 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 3 failure to designate qualified information or items as “CONFIDENTIAL” does not, 4 standing alone, waive the Designating Party’s right to secure protection under this 5 Stipulation and its associated Order for such material. Upon timely correction of a 6 designation, the Receiving Party must make reasonable efforts to assure that the 7 material is treated in accordance with the provisions of this Order. 8 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 9 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 10 designation of confidentiality at any time that is consistent with the Court's 11 Scheduling Order. 12 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 13 resolution process under Local Rule 37.1 et seq. 14 6.3 The burden of persuasion in any such challenge proceeding shall be on 15 the Designating Party. Frivolous challenges, and those made for an improper purpose 16 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 17 expose the Challenging Party to sanctions. Unless the Designating Party has waived 18 or withdrawn the confidentiality designation, all parties shall continue to afford the 19 material in question the level of protection to which it is entitled under the Producing 20 Party’s designation until the Court rules on the challenge. 21 6.4 Withdrawal of “CONFIDENTIAL” Designation. At its discretion, a 22 Designating Party may remove Protected Material from some or all of the protections 23 and provisions of this Stipulated Protective Order at any time by any of the following 24 methods: 25 (a) Express Written Withdrawal. A Designating Party may withdraw a 26 “CONFIDENTIAL” designation made to any specified Protected Material from some 27 or all of the protections of this Stipulated Protective Order by an express withdrawal 1 including staff of such counsel) that specifies and itemizes the Disclosure or 2 Discovery Material previously designated as Protected Material that shall not longer 3 be subject to some or all of the provisions of this Stipulated Protective Order. Such 4 express withdrawal shall be effective when transmitted or served upon the Receiving 5 Party. If a Designating Party is withdrawing Protected Material from only some of 6 the provisions/protections of this Stipulated Protective Order, the Designating Party 7 must state which specific provisions are no longer to be enforced as to the specified 8 material for which confidentiality protection hereunder is withdrawn: otherwise, such 9 withdrawal shall be construed as a withdrawal of such material from all of the 10 protections/provisions of this Stipulated Protective Order; 11 (b) Express Withdrawal on the Record. A Designating Party may withdraw 12 a “CONFIDENTIAL” designation made to any specified Protected Material from all 13 of the provisions/protections of this Stipulated Protective Order by verbally 14 consenting in court proceedings on the record to such withdrawal – provided that such 15 withdrawal specifies the Disclosure or Discovery Material previously designated as 16 Protected Material shall no longer be subject to any of the provisions of this 17 Stipulation and Order; 18 (c) Implicit Withdrawal by Publication or Failure to Oppose Challenge. A 19 Designating Party shall be construed to have withdrawn a “CONFIDENTIAL” 20 designation made to any specified Protected Material from all of the 21 provisions/protections of this Stipulated Protective Order by either (1) making such 22 Protected Material part of the public record – including but not limited to attaching 23 such as exhibits to any filing with the court without moving, prior to such filing, for 24 the court to seal such records; or (2) failing to timely oppose a Challenging Party’s 25 motion to remove a “CONFIDENTIAL” designation to specified Protected Material. 26 7. ACCESS TO AND USE OF PROTECTED MATERIAL 27 7.1 Basic Principles. A Receiving Party may use Protected Material that is 1 Action only for prosecuting, defending, or attempting to settle this Action. Such 2 Protected Material may be disclosed only to the categories of persons and under the 3 conditions prescribed in this Order. When the Action has been terminated, a 4 Receiving Party must comply with the provisions of section 13 below (FINAL 5 DISPOSITION). 6 Protected Material must be stored and maintained by a Receiving Party at a 7 location and in a secure manner that ensures that access is limited to the persons 8 authorized under this Order. 9 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 10 otherwise ordered by the Court or permitted in writing by the Designating Party, a 11 Receiving Party may disclose any information or item designated 12 “CONFIDENTIAL” only to: 13 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 14 as employees of such Counsel to whom it is reasonably necessary to disclose the 15 information for this Action; 16 (b) the officers, directors, and employees (including House Counsel) of the 17 Receiving Party to whom disclosure is reasonably necessary for this Action; 18 (c) Experts (as defined in this Order) of the Receiving Party to whom 19 disclosure is reasonably necessary for this Action and who have signed the 20 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 21 (d) the court and its personnel; 22 (e) court reporters and their staff; 23 (f) professional jury or trial consultants, mock jurors, and Professional 24 Vendors to whom disclosure is reasonably necessary for this Action and who have 25 signed the “ Acknowledgment and Agreement to Be Bound” (Exhibit A); 26 (g) the author or recipient of a document containing the information or a 27 custodian or other person who otherwise possessed or knew the information; 1 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 2 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will 3 not be permitted to keep any confidential information unless they sign the 4 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 5 agreed by the Designating Party or ordered by the court. Pages of transcribed 6 deposition testimony or exhibits to depositions that reveal Protected Material may be 7 separately bound by the court reporter and may not be disclosed to anyone except as 8 permitted under this Stipulated Protective Order; and 9 (i) any mediator or settlement officer, and their supporting personnel, 10 mutually agreed upon by any of the parties engaged in settlement discussions. 11 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER LITIGATION 12 If a Party is served with a subpoena or a court order issued in other litigation 13 that compels disclosure of any information or items designated in this Action as 14 “CONFIDENTIAL,” that Party must: 15 (a) promptly notify in writing the Designating Party. Such notification shall 16 include a copy of the subpoena or court order; 17 (b) promptly notify in writing the party who caused the subpoena or order to 18 issue in the other litigation that some or all of the material covered by the subpoena 19 or order is subject to Protective Order. Such notification shall include a copy of this 20 Stipulated Protective Order; and 21 (c) cooperate with respect to all reasonable procedures sought to be pursued 22 by the Designating Party whose Protected Material may be affected. 23 If the Designating Party timely seeks a protective order, the Party served with 24 the subpoena or court order shall not produce any information designated in this action 25 as “CONFIDENTIAL” before a determination by the court from which the subpoena 26 or order issued, unless the Party has obtained the Designating Party’s permission. The 27 Designating Party shall bear the burden and expense of seeking protection in that court 1 of its confidential material and nothing in these provisions should be construed as 2 authorizing or encouraging a Receiving Party in this action to disobey a lawful 3 directive from another court. 4 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS LITIGATION 5 (a) The terms of this Order are applicable to information produced by a Non- 6 Party in this Action and designated as “CONFIDENTIAL.” Such information 7 produced by Non-Parties in connection with this litigation is protected by the 8 remedies and relief provided by this Order. Nothing in these provisions should be 9 construed as prohibiting a Non-Party from seeking additional protections. 10 (b) In the event that a Party is required, by a valid discovery request, to 11 produce a Non-Party’s confidential information in its possession, and the Party is 12 subject to an agreement with the Non-Party not to produce the Non-Party’s 13 confidential information, then the Party shall: 14 (1) promptly notify in writing the Requesting Party and the Non-Party 15 that some or all of the information requested is subject to a confidentiality agreement 16 with a Non-Party; 17 (2) promptly provide the Non-Party with a copy of the Stipulated 18 Protective Order in this Action, the relevant discovery request(s), and a reasonably 19 specific description of the information requested; 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 within 14 23 days of receiving the notice and accompanying information, the Receiving Party may 24 produce the Non-Party’s confidential information responsive to the discovery request. 25 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce 26 any information in its possession or control that is subject to the confidentiality 27 agreement with the Non-Party before a determination by the court. Absent a court 1 order to the contrary, the Non-Party shall bear the burden and expense of seeking 2 protection in this court of its Protected Material. 3 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 4 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 5 Protected Material to any person or in any circumstance not authorized under this 6 Stipulation and Order, the Receiving Party must immediately: (a) notify in writing the 7 Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 8 all unauthorized copies of the Protected Material, (c) inform the person or persons to 9 whom unauthorized disclosures were made of all the terms of this Order, and (d) 10 request such person or persons execute the Acknowledgement and Agreement to Be 11 Bound” that is attached hereto as Exhibit A. 12 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED MATERIAL 13 When a Producing Party gives notice to Receiving Parties that certain 14 inadvertently produced material is subject to a claim of privilege or other protection, 15 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 16 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 17 may be established in an e-discovery order that provides for production without prior 18 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 19 parties reach an agreement on the effect of disclosure of a communication or 20 information covered by the attorney-client privilege or work product protection, the 21 parties may incorporate their agreement in the stipulated protective order submitted 22 to the court. 23 12. MISCELLANEOUS 24 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 25 person to seek modification by the Court in the future. 26 12.2 Right to Assert Other Objections. By stipulating to the entry of this 27 Protective Order no Party waives any right it otherwise would have to object to 1 disclosing or producing any information or item on any ground not addressed in this 2 Stipulated Protective Order. Similarly, no Party waives any right to object on any 3 ground to use in evidence of any of the material covered by this Protective Order. 4 12.3 Filing of Protected Material. A party that seeks to file under seal any 5 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 6 only be filed under seal pursuant to a court order authorizing the sealing of the specific 7 Protected Material at issue. If a Party’s request to file Protected Material under seal 8 is denied by the court, then the Receiving Party may file the information in the public 9 record unless otherwise instructed by the court. 10 13. FINAL DISPOSITION 11 After the final disposition of this Action, as defined in paragraph 4, within 60 12 days of a written request by the Designating Party, each Receiving Party must return 13 all Protected Material to the Producing Party or destroy such material. As used in this 14 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 15 summaries, and any other format reproducing or capturing any of the Protected 16 Material. Whether the Protected Material is returned or destroyed, the Receiving 17 Party must submit a written certification to the Producing Party (and, if not the same 18 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 19 (by category, where appropriate) all the Protected Material that was returned or 20 destroyed and (2) affirms that the Receiving Party has not retained any copies, 21 abstracts, compilations, summaries or any other format reproducing or capturing any 22 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 23 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 24 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 25 reports, attorney work product, and consultant and expert work product, even if such 26 materials contain Protected Material. Any such archival copies that contain or 27 constitute Protected Material remain subject to this Protective Order as set forth in 1 14. Any violation of this Order may be punished by any and all appropriate 2 measures including, without limitation, contempt proceedings and/or monetary 3 sanctions. 4 5 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 6 7 DATED: September 19, 2025 LEWIS BRISBOIS BISGAARD & SMITH LLP

9 By: /s/ Aaron E. Kircher 10 TONY M. SAIN 11 TORI L.N. BAKKEN 12 ABIGAIL J.R. MCLAUGHLIN AARON E. KIRCHER 13 Attorneys for Defendants, COUNTY OF 14 LOS ANGELES, LOGAN SIMI, SHANE QUESADA, and NOEL WITTY 15 16 17 18 19 20 21 22 23 24 25 26 27 1 DATED: September 18, 2025 GASTÉLUM LAW, APC

3 By: /s/ Denisse Gastélum 4 DENISSE O. GASTÉLUM 5 Attorney for Plaintiffs, 6 A.N.1, a minor by and through their Guardian Ad Litem Adriana Hernandez; 7 A.N.2, a minor by and through their 8 Guardian Ad Litem Adriana Hernandez; F.N., a minor by and through their 9 Guardian Ad Litem Adriana Hernandez; 10 B.N., a minor by and through their Guardian Ad Litem Adriana Hernandez 11 12 DATED: September 18, 2025 LAW OFFICES OF CHRISTIAN 13 CONTRERAS PLC 14

15 16 By: __/s/ _Christian Contreras_________ CHRISTIAN M. CONTRERAS 17 CLAIRE MCCALL 18 Attorney for Plaintiff, ESTATE OF FRANCISCO NUNEZ, by 19 and through his successors in interest 20 DATED: September 17, 2025 LAW OFFICES OF HUMBERTO 21 GUIZAR 22

23 By: ____/s/ Humberto Guizar__________ 24 HUMBERTO M. GUIZAR Attorney for Plaintiffs, 25 A.N.1, a minor by and through their 26 Guardian Ad Litem Adriana Hernandez; A.N.2, a minor by and through their 27 Guardian Ad Litem Adriana Hernandez 1 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 2 3 || Dated: October 20, 2025 Ubias A Keane 6|| United States Magistrate Judge 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 162399515.1 12

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 that 5 I have read in its entirety and understand the Stipulated Protective Order that was 6 issued by the United States District Court for the Central District of California on 7 [date] in the case of ___________ [insert formal name of the case and the number and 8 initials assigned to it by the court]. I agree to comply with and to be bound by all the 9 terms of this Stipulated Protective Order and I understand and acknowledge that 10 failure to so comply could expose me to sanctions and punishment in the nature of 11 contempt. I solemnly promise that I will not disclose in any manner any information 12 or item that is subject to this Stipulated Protective Order to any person or entity except 13 in strict compliance with the provisions of this Order. I further agree to submit to the 14 jurisdiction of the United States District Court for the Central District of California 15 for the purpose of enforcing the terms of this Stipulated Protective Order, even if such 16 enforcement proceedings occur after termination of this action. I hereby appoint 17 __________________________ [print or type full name] of 18 _______________________________________ [print or type full address and 19 telephone number] as my California agent for service of process in connection with 20 this action or any proceedings related to enforcement of this Stipulated Protective 21 Order. 22 Date: ______________________________________ 23 City and State where sworn and signed: _________________________________ 24 25 Printed name: _______________________________ 26 27 Signature: __________________________________