Kimberly Freeman v. County of Los Angeles

David J. Weiss, Esq., SBN 78542 Nicholas A. Weiss, Esq., SBN 260606

DAVID WEISS LAW

3019 Ocean Park Blvd #392 Santa Monica, CA 90405 4 Phone: (310) 575-9566 Fax: (310) 575-9576 weissn@djwlaw.com

Attorneys for Defendants, COUNTY OF LOS ANGELES and LOS

ANGELES COUNTY SHERIFF’S

DEPARTMENT

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

12 KIMBERLY FREEMAN, individually ,CASE NO. 2:24-cv-01600 MWF(AJRx) 13 and as the personal representative of TRAVIS CULVER FREEMAN, deceased; KENT FREEMAN, [PROPOSED] 15 individually and as the personal PROTECTIVE ORDER representative of TRAVIS CULVER FREEMAN, deceased, 17 Plaintiffs, v. Complaint Filed: 19 February 27, 2024

COUNTY OF LOS ANGELES, LOS

ANGELES COUNTY SHERIFF’S DEPARTMENT, and DOES 1 TO 10,

Defendants.

27 1. PURPOSES AND LIMITATIONS Discovery in this action is likely to involve production of confidential, proprietary or private information for which special protection from public disclosure and from use for any purpose other than pursuing this…