Zarah Zambrano, a deceased minor, by and through her successors in interest, Dutchlynn Broitzmann and Oscar Zambrano; Dutchlynn Broitzmann, an individual; Oscar Zambrano, an individual, by and through their respective guardians ad litem Larry Broitzmann and Nancy Sanchez

• Court: District Court, E.D. California
• Decided: November 12, 2025
• Docket: 1:24-cv-01234
• Status: Unknown

Opinion

1 MARGO A. RAISON, COUNTY COUNSEL Marshall S. Fontes, Chief Deputy (SBN 139567) 2 Kimberly L. Marshall, Deputy (SBN 186838) By: Andrew C. Hamilton, Deputy (SBN 299877) 3 Kern County Administrative Center 1115 Truxtun Avenue, Fourth Floor 4 Bakersfield, CA 93301 Telephone: (661) 868-3800 5 Facsimile: (661) 868-3805 Email: ahamilton@kerncounty.com 6 marshallkim@kerncounty.com sfontes@kerncounty.com 7 Attorneys for County of Kern, Guadelupe 8 Monreal, Sabrina Neubauer, Sharon Flemming, Tiffany Jones, Tanya Winston, 9 Jennifer Ramirez, and Christina Alegria

10 UNITED STATES DISTRICT COURT

11 EASTERN DISTRICT OF CALIFORNIA

12 ZARAH ZAMBRANO, a deceased minor, by Case No. 1:24-CV-01234-KES-CDB and through her successors in interest, 13 DUTCHLYNN BROITZMANN and OSCAR STIPULATION AND [PROPOSED] ZAMBRANO; DUTCHLYNN PROTECTIVE ORDER AS MODIFIED 14 BROITZMANN, an individual; OSCAR ZAMBRANO, an individual, by and through 15 their respective guardians ad litem Larry Broitzmann and Nancy Sanchez, 16 Plaintiffs, 17 vs. 18 COUNTY OF KERN, a public entity; 19 GUADALUPE MONREAL, an individual; JENNIFER RAMIREZ, an individual; 20 SABRINA NEUBAUER, an individual; CHRISTINA ALEGRIA, an individual; 21 TANYA WINSTON, an individual; SHARON FLEMMING, an individual; TIFFANY JONES, 22 an individual; KOINONIA FOSTER HOMES, INC., DBA KOINONIA FAMILY SERVICES 23 a California Corporation; DEVIN RAMEY, an individual; MONICA CASTRO, an individual; 24 DEBORAH KARSGOR, an individual; and DOES 1 through 50, inclusive, 25 Defendants. 26 27 / / / 1 WHEREAS, Plaintiffs’ complaint alleges, inter alia, that County of Kern personnel 2 improperly removed and placed Dutchlynn Broitzmann and Zarah Zambrano, resulting in the death 3 of Zarah Zambrano; 4 WHEREAS, discovery seeks information relating to the foster parent(s) that implicates the 5 state and federal rights to privacy and California Welfare and Institutions Code § 10850 (see M.B. by 6 and through Brashears v. County of Butte (E.D. Cal., July 22, 2025) 2025 WL 2051090, at *6), as 7 well as medical records of the parents also protected by the right to privacy and likely falling under 8 HIPAA, information that the Parties agree is relevant to the resolution of this matter; 9 WHEREAS, a private agreement is likely to be insufficient because such records will need to 10 be exchanged with the Parties’ experts, insurance carriers, officers, directors, and employees, the 11 court and its personnel, court reporters and their staff, professional jury or trial consultants, mock 12 jurors, and professional vendors to whom disclosure is reasonably necessary for this litigation and 13 would not necessarily be parties to such an agreement; 14 THEREFORE, pursuant to Local Rule 141.1, the Parties stipulate as follows: 15 1. PURPOSES AND LIMITATIONS 16 1.1. Disclosure and discovery activity in this action are likely to involve production of 17 confidential, proprietary, or private information for which special protection from public disclosure 18 and from use for any purpose other than prosecuting this litigation may be warranted. Accordingly, 19 the parties hereby stipulate to and petition the court to enter the following Stipulated Protective Order. 20 The parties acknowledge that this Order does not confer blanket protections on all disclosures or 21 responses to discovery and that the protection it affords from public disclosure and use extends only 22 to the limited information or items that are entitled to confidential treatment under the applicable 23 legal principles. The parties further acknowledge, as set forth in Section 12.3, below, that this 24 Stipulated Protective Order does not entitle them to file confidential information under seal; Local 25 Rule 141 sets forth the procedures that must be followed and the standards that will be applied when 26 a party seeks permission from the court to file material under seal. 27 2. DEFINITIONS 1 information or items under this Order. 2 2.2. “CONFIDENTIAL” Information or Items: information (regardless of how it is 3 generated, stored or maintained) or tangible things that qualify for protection under Federal Rule of 4 Civil Procedure 26(c), including but not limited to, resource family files and medical records. 5 2.3. “Counsel” (without qualifier): Outside Counsel of Record and House Counsel (as well 6 as their support staff). 7 2.4. “Designating Party”: a Party or Non-Party that designates information or items that it 8 produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 9 2.5. “Disclosure” or “Discovery Material”: all items or information, regardless of the 10 medium or manner in which it is generated, stored, or maintained (including, among other things, 11 testimony, transcripts, and tangible things), that are produced or generated in disclosures or responses 12 to discovery in this matter. 13 2.6. “Expert”: a person with specialized knowledge or experience in a matter pertinent to 14 the litigation who has been retained by a Party or its counsel to serve as an expert witness or as a 15 consultant in this action. 16 2.7. “House Counsel”: attorneys who are employees of a party to this action. House 17 Counsel does not include Outside Counsel of Record or any other outside counsel. 18 2.8. “Non-Party”: any natural person, partnership, corporation, association, or other legal 19 entity not named as a Party to this action. 20 2.9. “Outside Counsel of Record”: attorneys who are not employees of a party to this action 21 but are retained to represent or advise a party to this action and have appeared in this action on behalf 22 of that party or are affiliated with a law firm which has appeared on behalf of that party. 23 2.10. “Party”: any party to this action, including all of its officers, directors, employees, 24 consultants, retained experts, and Outside Counsel of Record (and their support staffs). 25 2.11. “Producing Party”: a Party or Non-Party that produces Disclosure or Discovery 26 Material in this action. 27 2.12. “Professional Vendors”: persons or entities that provide litigation support services 1 storing, or retrieving data in any form or medium) and their employees and subcontractors. 2 2.13. “Protected Material”: any Disclosure or Discovery Material that is designated as 3 “CONFIDENTIAL.” 4 2.14. “Receiving Party”: a Party that receives Disclosure or Discovery Material from a 5 Producing Party. 6 3. SCOPE 7 3.1. The protections conferred by this Stipulation and Order cover not only Protected 8 Material (as defined above), but also (1) any information copied or extracted from Protected Material; 9 (2) all copies, excerpts, summaries, or compilations of Protected Material; and (3) any testimony, 10 conversations, or presentations by Parties or their Counsel that might reveal Protected Material. 11 However, the protections conferred by this Stipulation and Order do not cover the following 12 information: (a) any information that is in the public domain at the time of disclosure to a Receiving 13 Party or becomes part of the public domain after its disclosure to a Receiving Party as a result of 14 publication not involving a violation of this Order, including becoming part of the public record 15 through trial or otherwise; and (b) any information known to the Receiving Party prior to the 16 disclosure or obtained by the Receiving Party after the disclosure from a source who obtained the 17 information lawfully and under no obligation of confidentiality to the Designating Party. Any use of 18 Protected Material at trial shall be governed by a separate agreement or order. 19 4. DURATION 20 4.1. Even after final disposition of this litigation, the confidentiality obligations imposed 21 by this Order shall remain in effect until a Designating Party agrees otherwise in writing or a court 22 order otherwise directs. Final disposition shall be deemed to be the later of (1) dismissal of all claims 23 and defenses in this action, with or without prejudice; and (2) final judgment herein after the 24 completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of this action, 25 including the time limits for filing any motions or applications for extension of time pursuant to 26 applicable law. 27 5. DESIGNATING PROTECTED MATERIAL 1 Non-Party that designates information or items for protection under this Order must take care to limit 2 any such designation to specific material that qualifies under the appropriate standards. The 3 Designating Party must designate for protection only those parts of material, documents, items, or 4 oral or written communications that qualify – so that other portions of the material, documents, items, 5 or communications for which protection is not warranted are not swept unjustifiably within the ambit 6 of this Order. 7 Mass, indiscriminate, or routinized designations are prohibited. Designations that are shown 8 to be clearly unjustified or that have been made for an improper purpose (e.g., to unnecessarily 9 encumber or retard the case development process or to impose unnecessary expenses and burdens on 10 other parties) expose the Designating Party to sanctions. 11 If it comes to a Designating Party’s attention that information or items that it designated for 12 protection do not qualify for protection, that Designating Party must promptly notify all other Parties 13 that it is withdrawing the mistaken designation. 14 5.2. Manner and Timing of Designations. Except as otherwise provided in this Order (see, 15 e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure or 16 Discovery Material that qualifies for protection under this Order must be clearly so designated before 17 the material is disclosed or produced. 18 Designation in conformity with this Order requires: 19 (a) For information in documentary form (e.g., paper or electronic documents, but 20 excluding transcripts of depositions or other pretrial or trial proceedings), that the Producing Party 21 affix the legend “CONFIDENTIAL” to each page that contains protected material. If only a portion 22 or portions of the 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 A Party or Non-Party that makes original documents or materials available for inspection need 25 not designate them for protection until after the inspecting Party has indicated which material it would 26 like copied and produced. During the inspection and before the designation, all of the material made 27 available for inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has 1 documents, or portions thereof, qualify for protection under this Order. Then, before producing the 2 specified documents, the Producing Party must affix the “CONFIDENTIAL” legend to each page 3 that contains Protected Material. If only a portion or portions of the material on a page qualifies for 4 protection, the Producing Party also must clearly identify the protected portion(s) (e.g., by making 5 appropriate markings in the margins). 6 (b) for testimony given in deposition or in other pretrial or trial proceedings, that 7 the Designating Party identify on the record, before the close of the deposition, hearing, or other 8 proceeding, all protected testimony. 9 (c) for information produced in some form other than documentary and for any 10 other tangible items, that the Producing Party affix in a prominent place on the exterior of the 11 container or containers in which the information or item is stored the legend “CONFIDENTIAL.” If 12 only a portion or portions of the information or item warrant protection, the Producing Party, to the 13 extent practicable, shall identify the protected portion(s). 14 5.3. Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to 15 designate qualified information or items does not, standing alone, waive the Designating Party’s right 16 to secure protection under this Order for such material. Upon timely correction of a designation, the 17 Receiving Party must make reasonable efforts to assure that the material is treated in accordance with 18 the provisions of this Order. 19 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 20 6.1. Timing of Challenges. Any Party or Non-Party may challenge a designation of 21 confidentiality at any time. Unless a prompt challenge to a Designating Party’s confidentiality 22 designation is necessary to avoid foreseeable, substantial unfairness, unnecessary economic burdens, 23 or a significant disruption or delay of the litigation, a Party does not waive its right to challenge a 24 confidentiality designation by electing not to mount a challenge promptly after the original 25 designation is disclosed. 26 6.2. Meet and Confer. The Challenging Party shall initiate the dispute resolution process 27 by providing written notice of each designation it is challenging and describing the basis for each 1 that the challenge to confidentiality is being made in accordance with this specific paragraph of the 2 Protective Order. The parties shall attempt to resolve each challenge in good faith and must begin the 3 process by conferring directly (in voice to voice dialogue; other forms of communication are not 4 sufficient) within 14 days of the date of service of notice. In conferring, the Challenging Party must 5 explain the basis for its belief that the confidentiality designation was not proper and must give the 6 Designating Party an opportunity to review the designated material, to reconsider the circumstances, 7 and, if no change in designation is offered, to explain the basis for the chosen designation. A 8 Challenging Party may proceed to the next stage of the challenge process only if it has engaged in 9 this meet and confer process first or establishes that the Designating Party is unwilling to participate 10 in the meet and confer process in a timely manner. 11 6.3. Judicial Intervention. Pursuant to Local Rule 302(c)(1), any challenge to a 12 confidentiality designation will be brought as a motion before the Court only after having exhausted 13 the Court’s mandatory informal discovery dispute procedures as set forth herein: No written 14 discovery motions shall be filed without the prior approval of Judge Baker. A party with a discovery 15 dispute must first confer with the opposing party in a good faith effort to resolve by agreement the 16 issues in dispute. If that good faith effort is unsuccessful, prior to making any filing, the requesting 17 party promptly shall seek a conference with all involved parties and Judge Baker. To schedule this 18 conference, the parties should contact the Courtroom Deputy Clerk, Cori Boren, at (661) 326-6620 19 or via email at CBoren@caed.uscourts.gov. At least two days before the conference, counsel shall 20 file a joint, informal letter brief detailing each party’s position. Each party’s narrative shall not 21 exceed five pages, excluding exhibits, and shall cite relevant authority in support of the party’s 22 position. At the commencement of the conference, if the parties jointly agree to Judge Baker’s 23 consideration and resolution of the discovery disputes outside the formal Local Rule 251 procedures, 24 the Court will entertain arguments by the parties and issue a written ruling. If the parties do not jointly 25 agree to the informal discovery dispute resolution procedures set forth herein, the requesting party 26 may then seek relief through motion to compel. Counsel must comply with Local Rule 251 with 27 respect to discovery disputes and certify their compliance in any discovery motion. Failure by the 1 for each challenged designation. In addition, the Challenging Party may file a motion challenging a 2 confidentiality designation only after having exhausted the Court’s mandatory informal discovery 3 dispute procedures as referenced above, including a challenge to the designation of a deposition 4 transcript or any portions thereof. Any motion brought pursuant to this provision must be 5 accompanied by a competent declaration affirming that the movant has complied with the meet and 6 confer requirements imposed by the preceding paragraph and has exhausted the Court’s mandatory 7 informal discovery dispute procedures as referenced above. 8 The burden of persuasion in any such challenge proceeding shall be on the Designating Party. 9 Frivolous challenges, and those made for an improper purpose (e.g., to harass or impose unnecessary 10 expenses and burdens on other parties) may expose the Challenging Party to sanctions. Unless the 11 Designating Party has waived the confidentiality designation by failing to file a motion to retain 12 confidentiality as described above, all parties shall continue to afford the material in question the 13 level of protection to which it is entitled under the Producing Party’s designation until the court rules 14 on the challenge. 15 7. ACCESS TO AND USE OF PROTECTED MATERIAL 16 7.1. Basic Principles. A Receiving Party may use Protected Material that is disclosed or 17 produced by another Party or by a Non-Party in connection with this case only for prosecuting, 18 defending, or attempting to settle this litigation. Such Protected Material may be disclosed only to the 19 categories of persons and under the conditions described in this Order. When the litigation has been 20 terminated, a Receiving Party must comply with the provisions of section 13 below (FINAL 21 DISPOSITION). 22 Protected Material must be stored and maintained by a Receiving Party at a location and in a 23 secure manner that ensures that access is limited to the persons authorized under this Order. 24 7.2. Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise ordered by 25 the court or permitted in writing by the Designating Party, a Receiving Party may disclose any 26 information or item designated “CONFIDENTIAL” only to: 27 (a) the Receiving Party’s Outside Counsel of Record in this action, as well as 1 information for this litigation and who have signed the “Acknowledgment and Agreement to Be 2 Bound” that is attached hereto as Exhibit A; 3 (b) the officers, directors, and employees (including House Counsel) of the 4 Receiving Party to whom disclosure is reasonably necessary for this litigation and who have signed 5 the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 6 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure 7 is reasonably necessary for this litigation and who have signed the “Acknowledgment and Agreement 8 to Be Bound” (Exhibit A); 9 (d) the court and its personnel; 10 (e) court reporters and their staff, professional jury or trial consultants, mock 11 jurors, and Professional Vendors to whom disclosure is reasonably necessary for this litigation and 12 who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 13 (f) during their depositions, witnesses in the action to whom disclosure is 14 reasonably necessary and who have signed the “Acknowledgment and Agreement to Be Bound” 15 (Exhibit A), unless otherwise agreed by the Designating Party or ordered by the court. Pages of 16 transcribed deposition testimony or exhibits to depositions that reveal Protected Material must be 17 separately bound by the court reporter and may not be disclosed to anyone except as permitted under 18 this Stipulated Protective Order; 19 (g) the author or recipient of a document containing the information or a custodian 20 or other person who otherwise possessed or knew the information; and 21 (h) insurance carriers of a Party for the purpose of evaluating all claims and 22 defenses and securing coverage for claims relating to this action. 23 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 24 OTHER LITIGATION 25 8.1. If a Party is served with a subpoena or a court order issued in other litigation that 26 compels disclosure of any information or items designated in this action as “CONFIDENTIAL,” that 27 Party must: 1 include a copy of the subpoena or court order; 2 (b) promptly notify in writing the party who caused the subpoena or order to issue 3 in the other litigation that some or all of the material covered by the subpoena or order is subject to 4 this Protective Order. Such notification shall include a copy of this Stipulated Protective Order; and 5 (c) cooperate with respect to all reasonable procedures sought to be pursued by 6 the Designating Party whose Protected Material may be affected. 7 If the Designating Party timely seeks a protective order, the Party served with the subpoena 8 or court order shall not produce any information designated in this action as “CONFIDENTIAL” 9 before a determination by the court from which the subpoena or order issued, unless the Party has 10 obtained the Designating Party’s permission. The Designating Party shall bear the burden and 11 expense of seeking protection in that court of its confidential material – and nothing in these 12 provisions should be construed as authorizing or encouraging a Receiving Party in this action to 13 disobey a lawful directive from another court. 14 / / / 15 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN 16 THIS LITIGATION 17 (a) The terms of this Order are applicable to information produced by a Non-Party 18 in this action and designated as “CONFIDENTIAL.” Such information produced by Non-Parties in 19 connection with this litigation is protected by the remedies and relief provided by this Order. Nothing 20 in these provisions should be construed as prohibiting a Non-Party from seeking additional 21 protections. 22 (b) In the event that a Party is required, by a valid discovery request, to produce a 23 Non-Party’s confidential information in its possession, and the Party is subject to an agreement with 24 the Non-Party not to produce the Non-Party’s confidential information, then the Party shall: 25 (1) promptly notify in writing the Requesting Party and the Non-Party that 26 some or all of the information requested is subject to a confidentiality agreement with a Non-Party; 27 (2) promptly provide the Non-Party with a copy of the Stipulated 1 description of the information requested; and 2 (3) make the information requested available for inspection by the Non- 3 Party. 4 (c) If the Non-Party fails to object or seek a protective order from this court within 5 14 days of receiving the notice and accompanying information, the Receiving Party may produce the 6 Non-Party’s confidential information responsive to the discovery request. If the Non-Party timely 7 seeks a protective order, the Receiving Party shall not produce any information in its possession or 8 control that is subject to the confidentiality agreement with the Non-Party before a determination by 9 the court. Absent a court order to the contrary, the Non-Party shall bear the burden and expense of 10 seeking protection in this court of its Protected Material. 11 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 12 10.1. If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 13 Protected Material to any person or in any circumstance not authorized under this Stipulated 14 Protective Order, the Receiving Party must immediately (a) notify in writing the Designating Party 15 of the unauthorized disclosures, (b) use its best efforts to retrieve all unauthorized copies of the 16 Protected Material, (c) inform the person or persons to whom unauthorized disclosures were made of 17 all the terms of this Order, and (d) request such person or persons to execute the “Acknowledgment 18 and Agreement to Be Bound” that is attached hereto as Exhibit A. 19 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 20 PROTECTED MATERIAL 21 11.1. When a Producing Party gives notice to Receiving Parties that certain inadvertently 22 produced material is subject to a claim of privilege or other protection, the obligations of the 23 Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This provision 24 is not intended to modify whatever procedure may be established in an e-discovery order that provides 25 for production without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), 26 insofar as the parties reach an agreement on the effect of disclosure of a communication or 27 information covered by the attorney-client privilege or work product protection, the parties may 1 12. MISCELLANEOUS 2 12.1. Right to Further Relief. Nothing in this Order abridges the right of any person to seek 3 its modification by the court in the future. 4 12.2. Right to Assert Other Objections. By stipulating to the entry of this Protective Order 5 no Party waives any right it otherwise would have to object to disclosing or producing any 6 information or item on any ground not addressed in this Stipulated Protective Order. Similarly, no 7 Party waives any right to object on any ground to use in evidence of any of the material covered by 8 this Protective Order. 9 12.3. Filing Protected Material. Without written permission from the Designating Party or 10 a court order secured after appropriate notice to all interested persons, a Party may not file in the 11 public record in this action any Protected Material. A Party that seeks to file under seal any Protected 12 Material must comply with Local Rule 141. Protected Material may only be filed under seal pursuant 13 to a court order authorizing the sealing of the specific Protected Material at issue. Pursuant to Local 14 Rule 141, a sealing order will issue only upon a request establishing that the Protected Material at 15 issue is privileged, protectable as a trade secret, or otherwise entitled to protection under the law. If 16 a Receiving Party’s request to file Protected Material under seal pursuant to Local Rule 141 is denied 17 by the court, then the Receiving Party may file the information in the public record pursuant to Local 18 Rule 141 unless otherwise instructed by the court. 19 13. FINAL DISPOSITION 20 13.1. Within 60 days after the final disposition of this action, as defined in paragraph 4, each 21 Receiving Party must return all Protected Material to the Producing Party or destroy such material. 22 As used in this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 23 summaries, and any other format reproducing or capturing any of the Protected Material. Whether 24 the Protected Material is returned or destroyed, the Receiving Party must submit a written 25 certification to the Producing Party (and, if not the same person or entity, to the Designating Party) 26 by the 60 day deadline that (1) identifies (by category, where appropriate) all the Protected Material 27 that was returned or destroyed and (2) affirms that the Receiving Party has not retained any copies, 1 Material. Notwithstanding this provision, Counsel are entitled to retain an archival copy of all 2 pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda, 3 correspondence, deposition and trial exhibits, expert reports, attorney work product, and consultant 4 and expert work product, even if such materials contain Protected Material. Any such archival copies 5 that contain or constitute Protected Material remain subject to this Protective Order as set forth in 6 Section 4 (DURATION). 7 / / / 8 / / / 9 / / / 10 / / / 11 / / / 12 / / / 13 / / / 14 / / / 15 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 16 DATED: November 12, 2025 Respectfully Submitted, 17 KENDRA L. GRAHAM, 18 INTERIM COUNTY COUNSEL 19 By: /s/ Andrew C. Hamilton Andrew C. Hamilton, Deputy 20 Attorneys for County of Kern, Guadelupe Monreal, Sabrina Neubauer, Sharon 21 Flemming, Tiffany Jones, Tanya Winston, Jennifer Ramirez, and Christina Alegria 22

23 DATED: November 12, 2025 THE LAW OFFICES OF SHAWN A. MCMILLAN, APC 24 By: /s/ Shawn A. McMillan* 25 Shawn A. McMillan, Esq. Attorneys for Plaintiffs 26

27 DATED: November 12, 2025 LAW OFFICES OF TIFFANY CHUNG 1 Tiffany T. Chung, Esq. 5 Attorneys for Plaintiffs

3 || DATED: November 12, 2025 MESSNER REEVES, LLP 4 By: /s/ Samuel Follis* Andrew Hollins, Esq. 5 Samuel Follis, Esq. Attorneys for Koinonia Foster Homes, Inc. ® *e-Signed with permission, 11/12/2025 7 8 IT IS SO ORDERED. Dated: November 12, 2025 | Mw Vv R~ 10 UNITED STATES MAGISTRATE JUDGE 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

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 5 penalty of perjury that I have read in its entirety and understand the Stipulated Protective Order that 6 was issued by the United States District Court for the Eastern District of California on November 12, 7 2025, in the case of Zara Zambrano, et al. v. County of Kern, et al., Case No. 1:24-cv-01234-KES- 8 CDB. I agree to comply with and to be bound by all the terms of this Stipulated Protective Order and 9 I understand and acknowledge that failure to so comply could expose me to sanctions and punishment 10 in the nature of contempt. I solemnly promise that I will not disclose in any manner any information 11 or item that is subject to this Stipulated Protective Order to any person or entity except in strict 12 compliance with the provisions of this Order. 13 I further agree to submit to the jurisdiction of the United States District Court for the Eastern 14 District of California for the purpose of enforcing the terms of this Stipulated Protective Order, even 15 if such enforcement proceedings occur after termination of this action. 16 I hereby appoint __________________________ [print or type full name] of 17 _______________________________________ [print or type full address and telephone number] as 18 my California agent for service of process in connection with this action or any proceedings related 19 to enforcement of this Stipulated Protective Order. 20 21 Date: ______________________________________ 22 City and State where sworn and signed: _________________________________ 23 24 Printed name: _______________________________ 25 26 Signature: __________________________________ 27