Gina Youngblood v. County of Los Angeles

• Court: District Court, C.D. California
• Decided: September 18, 2025
• Docket: 2:25-cv-04413
• Status: Unknown

Opinion

1 UNITED STATES DISTRICT COURT 2 CENTRAL DISTRICT OF CALIFORNIA - 3 WESTERN DIVISION 4 5 GINA YOUNGBLOOD, EUGENIA CASE NO. 2:25-cv-04413-WLH (MBK) YOUNGBLOOD, JANEL [Assigned to Hon. Wesley L. Hsu, Dept. 9B1 6 HERNDERSON, and JAMIE 7 HENDERSON, INDIVIDUALLY DISCOVERY MATTER AND AS SUCCESSORS IN 8 INTEREST TO EUGENE [PROPOSED] STIPULATED 9 YOUNGBLOOD, DECEASED, PROTECTIVE ORDER 10 Plaintiffs, 11 Complaint Filed: 05/16/2025 VS. Trial Date: None 12 13 COUNTY OF LOS ANGELES, and DOES 1-10, 14 15 Defendants. 16 Pursuant to Federal Rule of Civil 17 Procedure 26(cc), Plaintiffs Gina Youngblood, Eugenia Youngblood, Janel Henderson, and Jamie Henderson and Defendant County of Los Angeles (collectively, the Parties) 18 19 hereby stipulate to, and move the Court to enter, this Protective Order', on the grounds that the discovery sought is highly sensitive. 20 21 1. GENERAL 22 1.1 Purposes and Limitations Discovery in this action is likely to involve production of confidential, 23 proprietary, or private information for which special protection from public disclosure 24 and from use for any purpose other than prosecuting this litigation may be warranted. 25 Accordingly, the Parties hereby stipulate to and petition the Court to enter the following 26 Stipulated Protective Order. The Parties acknowledge that this Order does 27 28 1 This Stipulated Protective Order is substantially based on the motel protective order published and used throughout the Central District. 1 1 not confer blanket protections on all disclosures or responses to discovery and that the 2 protection it affords from public disclosure and use extends only to the limited 3 information or items that are entitled to confidential treatment under the applicable legal 4 principles. The Parties further acknowledge, as set forth in Section 12.3, below, that this 5 Stipulated Protective Order does not entitle them to file confidential information under 6 seal; Civil Local Rule 79-5 sets forth the procedures that must be followed and the 7 standards that will be applied when a Party seeks permission from the court to file material 8 under seal. 9 1.2 Good Cause Statement 10 This action involves the County of Los Angeles and peace officers employed by 11 Los Angeles Sheriff Department. Plaintiff will seek materials and information the 12 County of Los Angeles ("County") maintains as confidential, such as personnel files of 13 the officers involved in the Incident, Internal Affairs materials and information, video 14 recordings, local criminal history information, body work camera footage, criminal 15 investigative files, and other administrative materials and other information that the 16 County believes needs special protection from public disclosure and from use for any 17 purpose other than prosecuting this litigation is warranted. Such confidential and 18 proprietary materials and information consist of, among other things, confidential 19 business, information regarding confidential business practices, or other confidential 20 commercial information (including information implicating privacy rights of third 21 Parties), information otherwise generally unavailable to the public, or which may be 22 privileged or otherwise protected from disclosure under state or federal statutes, court 23 rules, case decisions, or common law. Accordingly, to expedite the flow of information, 24 to facilitate the prompt resolution of disputes over confidentiality of discovery materials, 25 to adequately protect information the Parties are entitled to keep confidential, to ensure 26 that the Parties are permitted reasonable necessary uses of such material in preparation 27 for and in the conduct of trial, to address their handling at the end of the litigation, and 28 serve the ends of justice, a protective order for such 1 information is justified in this matter. It is the intent of the Parties that information will 2 not be designated as confidential for tactical reasons and that nothing be so designated 3 without a good faith belief that it has been maintained in a confidential, non-public 4 manner, and there is good cause why it should not be part of the public record of this 5 case. 6 2. DEFINITIONS 7 2.1 Action: Gina Youngblood, et al., v. County of Los Angeles, et al. 8 2.2 Challenging Party: a Party or Non-Party that challenges the designation 9 of information or items under this Order. 10 2.3 "CONFIDENTIAL" Information or Items: information (regardless of 11 how it is generated, stored or maintained) or tangible things that qualify for protection 12 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 13 Cause Statement. 14 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their 15 support staff). 16 2.5 Designating Party: a Party or Non-Party that designates information or 17 items that it produces in disclosures or in responses to discovery as 18 "CONFIDENTIAL." 19 2.6 Disclosure or Discovery Material: all items or information, regardless of 20 the medium or manner in which it is generated, stored, or maintained (including, 21 among other things, testimony, transcripts, and tangible things), that are produced or 22 generated in disclosures or responses to discovery in this matter. 23 2.7 Expert: a person with specialized knowledge or experience in a matter 24 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 25 expert witness or as a consultant in this Action. 26 /// 27 //I 28 1 2.8 House Counsel: attorneys who are employees of a Party to this Action. 2 House Counsel does not include Outside Counsel of Record or any other outside 3 counsel. 4 2.9 Non-Party: any natural person, partnership, corporation, association, or 5 other legal entity not named as a Party to this action. 6 2.10 Outside Counsel of Record: attorneys who are not employees of a Party to 7 this Action but are retained to represent or advise a Party to this Action and have 8 appeared in this Action on behalf of that Party or are affiliated with a law firm that has 9 appeared on behalf of that Party, including support staff. 10 2.11 Party: any Party to this Action, including all of its officers, directors, 11 employees, consultants, retained experts, and Outside Counsel of Record (and their 12 support staffs). 13 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 14 Discovery Material in this Action. 15 2.13 Professional Vendors: persons or entities that provide litigation support 16 services (e.g., photocopying, videotaping, translating, preparing exhibits or 17 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 18 their employees and subcontractors. 19 2.14 Protected Material: any Disclosure or Discovery Material that is designated 20 as "CONFIDENTIAL." 21 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 22 from a Producing Party. 23 3. SCOPE 24 The protections conferred by this Stipulation and Order cover not only Protected 25 Material (as defined above), but also (1) any information copied or extracted from 26 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 27 Material; and (3) any testimony, conversations, or presentations by Parties or their Counsel 28 that might reveal Protected Material. 4 1 Any use of Protected Material at trial shall be governed by the orders of the trial 2 judge. This Order does not govern the use of Protected Material at trial. 3 4. DURATION 4 Once a case proceeds to trial, all of the court-filed information to be introduced 5 that was previously designated as confidential or maintained pursuant to this protective 6 order becomes public and will be presumptively available to all members of the public, 7 including the press, unless compelling reasons supported by specific factual findings to 8 proceed otherwise are made to the trial judge in advance of the trial. See Kamakana v. 9 City and Cty. of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing "good 10 cause" showing for sealing documents produced in discovery from "compelling reasons" 11 standard when merits-related documents are part of court record). Accordingly, the terms 12 of this protective order do not extend beyond the commencement of the trial. The fact a 13 document was designated as confidential will not impact the admissibility of any trial 14 documents. 15 5. DESIGNATING PROTECTED MATERIAL 16 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each 17 Party or Non-Party that designates information or items for protection under this Order 18 must take care to limit any such designation to specific material that qualifies under the 19 appropriate standards. The Designating Party must designate for protection only those 20 parts of material, documents, items, or oral or written communications that qualify so 21 that other portions of the material, documents, items, or communications for which 22 protection is not warranted are not swept unjustifiably within the ambit of this Order. If 23 there is a challenge to the confidentiality designation the counsel making such 24 designation will have the burden of demonstrating that the document(s) is (are) actually 25 confidential. 26 Mass, indiscriminate, or routinized designations are prohibited. Designations that 27 are shown to be clearly unjustified or that have been made for an improper purpose (e.g., 28 to unnecessarily encumber the case development process or to impose 1 unnecessary expenses and burdens on other parties) may expose the Designating Party 2 to sanctions. 3 If it comes to a Designating Party's attention that information or items that it 4 designated for protection do not qualify for protection, that Designating Party must 5 promptly notify all other Parties that it is withdrawing the inapplicable designation. 6 5.2 Manner and Timing of Designations. Except as otherwise provided in this 7 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated 8 or ordered, Disclosure or Discovery Material that qualifies for protection under this 9 Order must be clearly so designated before the material is disclosed or produced. 10 However, the designation shall not cover up any portion of the documents that are 11 designated as confidential. 12 Designation in conformity with this Order requires: 13 (a) for information in documentary form (e.g., paper or electronic 14 documents, but excluding transcripts of depositions or other pretrial or trial 15 proceedings), that the Producing Party affix, at a minimum, the legend 16 "CONFIDENTIAL" (hereinafter "CONFIDENTIAL legend"), to each page that 17 contains protected material. If only a portion or portions of the material on a page 18 qualifies for protection, the Producing Party also must clearly identify the protected 19 portion(s) (e.g., by making appropriate markings in the margins). 20 A Party or Non-Party that makes original documents available for inspection need 21 not designate them for protection until after the inspecting Party has indicated which 22 documents it would like copied and produced. During the inspection and before the 23 designation, all of the material made available for inspection shall be deemed 24 "CONFIDENTIAL." After the inspecting Party has identified the documents it wants 25 copied and produced, the Producing Party must determine which documents, or portions 26 thereof, qualify for protection under this Order. Then, before producing the specified 27 documents, the Producing Party must affix the "CONFIDENTIAL legend" to each page 28 that contains Protected Material. If only a portion or portions of the 6 1 material on a page qualifies for protection, the Producing Party also must clearly identify 2 the protected portion(s) (e.g., by making appropriate markings in the margins). 3 (b) for testimony given in depositions that the Designating Party identify 4 the Disclosure or Discovery Material on the record, before the close of the deposition. 5 (c) for information produced in some form other than documentary and for 6 any other tangible items, that the Producing Party affix in a prominent place on the 7 exterior of the container or containers in which the information is stored the legend 8 "CONFIDENTIAL." If only a portion or portions of the information warrants protection, 9 the Producing Party, to the extent practicable, shall identify the protected portion(s). 10 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 11 failure to designate qualified information or items does not, standing alone, waive the 12 Designating Party's right to secure protection under this Order for such material. Upon 13 timely correction of a designation, the Receiving Party must make reasonable efforts to 14 assure that the material is treated in accordance with the provisions of this Order. 15 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 16 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 17 designation of confidentiality at any time that is consistent with the Court's Scheduling 18 Order. 19 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 20 resolution process under Local Rule 37-1, et seq, as modified by Judge Kaufman's 21 Procedures. See https://www.cacd.uscourts.gov/honorable-michael-b-kaufman. Any 22 discovery motion must strictly comply with these procedures. 23 6.3 Burden. The burden of persuasion in any such challenge proceeding shall 24 be on the Designating Party. Frivolous challenges, and those made for an improper 25 purpose (e.g., to harass or impose unnecessary expenses and burdens on other parties) 26 may expose the Challenging Party to sanctions. Unless the Designating Party has waived 27 or withdrawn the confidentiality designation, all parties shall continue to afford 28 7 [PROPOSED] STIPULATED PROTECEIVE ORDER 1 the material in question the level of protection to which it is entitled under the 2 Producing Party's designation until the Court rules on the challenge. 3 7. ACCESS TO AND USE OF PROTECTED MATERIAL 4 7.1 Basic Principles. A Receiving Party may use Protected Material that is 5 disclosed or produced by another Party or by a Non-Party in connection with this Action 6 only for prosecuting, defending, or attempting to settle this Action. Such Protected 7 Material may be disclosed only to the categories of persons and under the conditions 8 described in this Order. When the Action has been terminated, a Receiving Party must 9 comply with the provisions of section 13 below (FINAL DISPOSITION). 10 Protected Material must be stored and maintained by a Receiving Party at a location 11 and in a secure manner that ensures that access is limited to the persons authorized under 12 this Order. 13 7.2 Disclosure of "CONFIDENTIAL" Information or Items. Unless 14 otherwise ordered by the Court or permitted in writing by the Designating Party, a 15 Receiving Party may disclose any information or item designated "CONFIDENTIAL" 16 only to: 17 (a) the Receiving Party's Outside Counsel of Record in this Action, as well 18 as employees of said Outside Counsel of Record to whom it is reasonably necessary to 19 disclose the information for this Action; 20 (b) the officers, directors, and employees (including House Counsel) of the 21 Receiving Party to whom disclosure is reasonably necessary for this Action as well as the 22 plaintiffs; 23 (c) Experts (as defined in this Order) of the Receiving Party to whom 24 disclosure is reasonably necessary for this Action and who have signed the 25 "Acknowledgment and Agreement to Be Bound" (Exhibit A); 26 (d) the Court and its personnel; 27 (e) court reporters and their staff 28 8 1 (f) professional jury or trial consultants, mock jurors, and Professional 2 Vendors to whom disclosure is reasonably necessary for this Action and who have 3 signed the "Acknowledgment and Agreement to Be Bound" (Exhibit A); 4 (g) the author or recipient of a document containing the information or a 5 custodian or other person who otherwise possessed or knew the information; 6 (h) during their depositions, witnesses, and attorneys for witnesses, in the 7 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 8 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will 9 not be permitted to keep any confidential information unless they sign the 10 "Acknowledgment and Agreement to Be Bound" (Exhibit A), unless otherwise agreed 11 by the Designating Party or ordered by the Court. Pages of transcribed deposition 12 testimony or exhibits to depositions that reveal Protected Material may be separately 13 bound by the court reporter and may not be disclosed to anyone except as permitted 14 under this Stipulated Protective Order; and 15 (i) any mediator or settlement officer, and their supporting personnel, 16 mutually agreed upon by any of the parties engaged in settlement discussions. 17 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 18 PRODUCED 19 IN OTHER LITIGATION 20 If a Party is served with a subpoena or a court order issued in other litigation that 21 compels disclosure of any information or items designated in this Action as 22 "CONFIDENTIAL," that Party must: 23 (a) promptly notify in writing the Designating Party. Such notification shall 24 include a copy of the subpoena or court order; 25 (b) promptly notify in writing the party who caused the subpoena or order to 26 issue in the other litigation that some or all of the material covered by the subpoena or 27 order is subject to this Protective Order. Such notification shall include a copy of this 28 Stipulated Protective Order; and 1 (c) cooperate with respect to all reasonable procedures sought to be pursued by 2 the Designating Party whose Protected Material may be affected. 3 If the Designating Party timely seeks a protective order, the Party served with the 4 subpoena or court order shall not produce any information designated in this action as 5 "CONFIDENTIAL" before a determination by the court from which the subpoena or 6 order issued, unless the Party has obtained the Designating Party's permission. The 7 Designating Party shall bear the burden and expense of seeking protection in that court of 8 its confidential material and nothing in these provisions should be construed as 9 authorizing or encouraging a Receiving Party in this Action to disobey a lawful directive 10 from another court. If there is a court order to produce documents in another case, the 11 party subject to that order shall comply with that order notwithstanding this protective 12 order. 13 9.A NON-PARTY'S PROTECTED MATERIAL SOUGHT TO BE PRODUCED 14 IN THIS LITIGATION 15 (a) The terms of this Order are applicable to information produced by a Non- 16 Party in this Action and designated as "CONFIDENTIAL." Such information produced 17 by Non-Parties in connection with this litigation is protected by the remedies and relief 18 provided by this Order. Nothing in these provisions should be construed as prohibiting 19 a Non-Party from seeking additional protections. 20 (b) In the event that a Party is required, by a valid discovery request, to produce 21 a Non-Party's confidential information in its possession, and the Party is subject to an 22 agreement with the Non-Party not to produce the Non-Party's confidential information, 23 then the Party shall: 24 (1)promptly notify in writing the Requesting Party and the Non-Party that 25 some or all of the information requested is subject to a confidentiality agreement with 26 a Non-Party; 27 28 10 1 (2) promptly provide the Non-Party with a copy of the Stipulated 2 Protective Order in this Action, the relevant discovery request(s), and a reasonably 3 specific description of the information requested; and 4 (0) make the information requested available for inspection by the Non- 5 Party, if requested. 6 (c) If the Non-Party fails to seek a protective order from this Court within seven 7 days of receiving the notice and accompanying information, the Receiving Party may 8 produce the Non-Party's confidential information responsive to the discovery request. If 9 the Non-Party timely seeks a protective order, the Receiving Party shall not produce any 10 information in its possession or control that is subject to the confidentiality agreement 11 with the Non-Party before a determination by the Court. Absent a court order to the 12 contrary, the Non-Party shall bear the burden and expense of seeking protection in this 13 Court of its Protected Material. 14 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 15 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 16 Protected Material to any person or in any circumstance not authorized under this 17 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 18 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 19 all unauthorized copies of the Protected Material, (c) inform the person or persons to 20 whom unauthorized disclosures were made of all the terms of this Order, and (d) request 21 such person or persons to execute the "Acknowledgment and Agreement to Be Bound" 22 that is attached hereto as Exhibit A. 23 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 24 PROTECTED MATERIAL 25 When a Producing Party gives notice to Receiving Parties that certain 26 inadvertently produced material is subject to a claim of privilege or other protection, 27 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 28 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 1 may be established in an e-discovery order that provides for production without prior 2 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 3 parties reach an agreement on the effect of disclosure of a communication or information 4 covered by the attorney-client privilege or work product protection, the parties may 5 incorporate their agreement in the stipulated protective order submitted to the Court. 6 12. MISCELLANEOUS 7 12.1 Right to Further Relief. Nothing in this Order abridges the right of any person 8 to seek its modification by the Court in the future. 9 12.2 Right to Assert Other Objections. By stipulating to the entry of this Protective 10 Order, no Party waives any right it otherwise would have to object to disclosing or 11 producing any information or item on any ground not addressed in this Stipulated 12 Protective Order. Similarly, no Party waives any right to object on any ground to use in 13 evidence of any of the material covered by this Protective Order. 14 12.3 Filing Protected Material. A Party that seeks to file under seal any Protected 15 Material must comply with Civil Local Rule 79-5. Protected Material may only be filed 16 under seal pursuant to a court order authorizing the sealing of the specific Protected 17 Material at issue; good cause must be shown in the request to file under seal. If a Party's 18 request to file Protected Material under seal is denied by the Court, then the Receiving 19 Party may file the information in the public record unless otherwise instructed by the 20 Court. 21 13. FINAL DISPOSITION 22 After the final disposition of this Action, within 60 days of a written request by 23 the Designating Party, each Receiving Party must return all Protected Material to the 24 Producing Party or destroy such material. As used in this subdivision, "all Protected 25 Material" includes all copies, abstracts, compilations, summaries, and any other format 26 reproducing or capturing any of the Protected Material. Whether the Protected Material 27 is returned or destroyed, the Receiving Party must submit a written 28 12 [PROPOSED] STIPULATED PROTECEIVE ORDER 1 |\certification to the Producing Party (and, if not the same person or entity, to the 2 ||Designating Party) by the 60 day deadline that (1) identifies (by category, where 3 llappropriate) all the Protected Material that was returned or destroyed, and (2) affirms 4 |\that the Receiving Party has not retained any copies, abstracts, compilations, summaries |lor any other format reproducing or capturing any of the Protected Material. © |\Notwithstanding this provision, counsel are entitled to retain an archival copy of all |I\pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda, % |\correspondence, deposition and trial exhibits, expert reports, attorney work product, |land consultant and expert work product, even if such materials contain Protected 1U |/Material. Any such archival copies that contain or constitute Protected Material remain 11 |\subject to this Protective Order as set forth in Section 4 (DURATION). TZ |i/// |i/// 14 |\/// 15 |\/// 16 |\/// a |\/// 18 |I/// 19 |}1// zu |i/// zi |i/// 22 |i/// z3 |i/// 24 |i/// ||\/// 26 ||/// ze |\/// 28 ||\/// 13 [PROPOSED] STIPULATED PROTECEIVE ORDER

1 1/14. VIOLATION OF ORDER 2 Any violation of this Order may be punished by any and all appropriate measures 3 |lincluding, without limitation, contempt proceedings and/or monetary sanctions. |ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD. 5 6 DATED: 9/16/25 BRAD GAGE LAW. AP

8 By: \BRABEEY C. GAGE 9 \rtorneys for Plaintiffs 10 Gina Youngblood, Eugenia Youngblood, Janel Henderson, & Jamie Henderson DATED: [Category] COLLINS + COLLINS LLP 12 9/16/25

14 By: _MALTHA E, MARTINEZ TOMAS A. GUTERRES 15 Attorneys for Defendant 16 COUNTY OF LOS ANGELES 47_||{T ISSO ORDERED. 18 4g ||DATED: September 18, 2025 ~ MICHAEL B. KAUFMAN 20 UNITED STATES MAGISTRATE JUDGE 21 22 23 24 25 26 27 28

[PROPOSED] STIPULATED PROTECEIVE ORDER

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 _____________________________________________ [print or type full name], 4 of _____________________ [print or type full address], declare under penalty of perjury 5 that I have read in its entirety and understand the Stipulated Protective Order that was 6 issued by the United States District Court for the Central District of California on [date] 7 in the case Of EUGENIA YOUNGBLOOD, ET AL., V, COUNTY OF LOS ANGELES, 8 ET AL., CASE NO. 2:25-cv-04413-WLH (MBK). I agree to comply with and to be 9 bound by all the terms of this Stipulated Protective Order and I understand and 10 acknowledge that failure to so comply could expose me to sanctions and punishment in 11 the nature of contempt. I solemnly promise that I will not disclose in any manner any 12 information or item that is subject to this Stipulated Protective Order to any person or 13 entity except in strict compliance with the provisions of this Order. I further agree to 14 submit to the jurisdiction of the United States District Court for the Central District of 15 California for the purpose of enforcing the terms of this Stipulated Protective Order, even 16 if such enforcement proceedings occur after termination of this 17 action. I hereby appoint ______________________________ [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 this 20 action or any proceedings related to enforcement of this Stipulated Protective Order. 21 Date:

22 City and State where sworn and signed: 23 24 Printed name: 25 26 Signature: 27 28 15 [PROPOSED] STIPULATED PROTECEIVE ORDER PROOF OF SERVICE 1 (CCP §§ 1013(a) and 2015.5; FRCP 5) State of California, 2 SS. County of Los Angeles. 3 I am employed in the County of Los Angeles. I am over the age of 18 and not a party to the within action. My business 4 address is 790 E. Colorado Boulevard, Suite 600, Pasadena, CA 91101. On this date, I served the foregoing document described as PROPOSED] STIPULATED PROTECTIVE ORDER on the 5 interested parties in this action by placing same in a sealed envelope, addressed as follows: 6 SEE ATTACHED SERVICE LIST e (BY MAIL.) - I caused such envelope(s) with postage thereon fully prepaid to be placed in the United States mail in Pasadena. 7 California to be served on the parties as indicated on the attached service list. | am "readily familiar" with the firm's practice of collection and processing correspondence for mailing. Under that practice, it would be deposited with the U.S. Postal Service 8 on that same day with postage thereon fully prepaid at Pasadena, California in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day 9 after date of deposit for mailing in affidavit. D{(BY CERTIFIED MAILI- I caused such envelope(s) with postage thereon fully prepaid via Certified Mail Return Receipt 10 Requested to be placed in the United States Mail in Pasadena, California. 11 O FEDERAL EXPRESS - I caused the envelope to be delivered to an authorized courier or driver authorized to receive documents with delivery fees provided for. 12 x (BY ELECTRONIC FILING AND/OR SERVICE) -I I served a true copy, with all exhibits, electronically on designated 3 recipients listed on the attached service list. e (ELECTRONIC SERVICE PER CODE CIV. PROC., 1010.6) - By prior consent or request or as required by rules of 14 court (Code Civ. Proc., § 1010.6 (amended Jan. 1, 2021); Code Civ. Proc., § 1013(g); Cal. Rules of Court, rule 2.251(a)). 15 e {BY PERSONAL SERVICEI - I caused such envelope(s) to be delivered by hand to the office(s) of the addressee(s). 16 Executed on 9/16/25 at Pasadena, California. 17 e (STATE) - I declare under penalty of perjury under the laws of the State of California that the above is true and correct. e (FEDERAL) - I declare that Iam employed in the office of a member of the bar of this court at whose direction the service 18 was made. 19 20 Yesenia Ramirez Yramirez@ccllp.law 21 22 23 24 25 26 27 28 16 [PROPOSED] STIPULATED PROTECEIVE ORDER

1 GINA YOUCNaGseB NLuOmObDer V: 2. :C2O5-UcvN-0T4Y4 1O3F-W LLOHS (AMNBGKE)L ES CCLLP File Number: 27432 2 SERVICE LIST 3 Bradley C. Gage Milad Sadr 4 BRAD GAGE LAW, APC 23002 Victory Boulevard 5 Woodland Hills, CA 91367 T: (818) 340-9252 - F: (818) 340-9088 6 brad@bradgagelaw.com milad@bradgagelaw.com yanira@bradgagelaw.com 7 sarah@bradgagelaw.com gabriela@bradgagelaw.com 8 ATTORNEYS FOR PLAINTIFFS, GINA YOUNGBLOOD, EUGENIA YOUNGBLOOD, 9 JANEL HERNDERSON, and JAMIE HENDERSON 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28