2 aVbiunrckewnti tCz@onPtrBerBaGs,B ESs.qC. OBMar No. : 3401 32 vcontreras@PBBGBS.COM 3 PETERSON BRADFORD BURKWITZ

GREGORIO BURKWITZ & SU, LLP

4 100 North First Street, Suite 300 Burbank, California 91502, 5 T: 818.562.5800

F: 818.562.5810

6 Attorneys for Defendants, 7 COUNTY OF LOS ANGELES, JEANNETE ARZATE, ANTHONY OKELOLA, and ESPERANZA LOPEZ 8 9 UNITED STATES DISTRICT COURT 10 CENTRAL DISTRICT OF CALIFORNIA 11 LUIS ENRIQUE AGUILERA Case No.: 2:23-cv-00875-FMO-MAR 12 ANGELES, an individual; ROSA Assigned to the Honorable: Fernando M. EMELIA CEBALLOS LOPEZ, an Olguin 13 individual; Y.A., a minor, by and through Magistrate Judge: Margo A. Rocconi her guardian ad litem, LUIS [Room 6D] 14 AGUILERA; and Q.A.., a minor, by and through her guardian ad litem, LUIS STIPULATED PROTECTIVE 15 AGUILERA ORDER1

16 Plaintiffs,

17 vs.

18 COUNTY OF LOS ANGELES; JEANETTE ARZATE, an individual; 19 ANTHONY OKELOLA, an individual;

E. LOPEZ, an individual; ERIKA

20 BARRALES, an individual; NORMA DISON, an individual; LISETTE SOLIS, 21 an individual; MARICELA OCHOA, an individual; CITY OF LOS ANGELES, 22 LOS ANGELES POLICE DEPARTMENT (LAPD), a public entity, 23 LAPD OFFICER RAMIREZ, Hollenbeck Division, serial number 24 31010; LAPD OFFICER BRAVO, Hollenbeck Division, serial number 25 36154; and DOES 1-20 inclusive,

26 Defendants. 27 1 This Stipulated Protective Order is substantially based on the model protective order provided 28 under Magistrate Judge Margo A. Rocconi’s Procedures. 2 1.1. PURPOSES AND LIMITATIONS 3 Discovery in this action is likely to involve production of confidential, 4 5 proprietary, or private information for which special protection from public 6 disclosure and from use for any purpose other than prosecuting this litigation may 7 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 8 9 enter the following Stipulated Protective Order. The parties acknowledge that this 10 Order does not confer blanket protections on all disclosures or responses to 11 12 discovery and that the protection it affords from public disclosure and use extends 13 only to the limited information or items that are entitled to confidential treatment 14 under the applicable legal principles. The parties further acknowledge, as set forth in 15 16 Section 12.3, below, that this Stipulated Protective Order does not entitle them to 17 file confidential information under seal; Civil Local Rule 79-5 sets forth the 18 procedures that must be followed and the standards that will be applied when a party 19 20 seeks permission from the court to file material under seal. 21 1.2. GOOD CAUSE STATEMENT 22 Plaintiffs Y.A., and Q.A., are former dependents of the Superior Court of the 23 24 State of California, County of Los Angeles, and the subject of Los Angeles County 25 Superior Court Juvenile Case Nos. 21CCJPOO619A and 21CCJPOO619B 26 (“Juvenile Dependency Court”). Information regarding dependents and information 27 28 contained in their case files of the juvenile court are highly confidential, private and 2 827, California Rules of Court 5.552, and other applicable statutes, regulations and 3 laws. Moreover, the Plaintiffs juvenile dependency court records contains highly 4 5 confidential information of mandated reporters reporting suspected abuse or neglect. 6 Penal Code §§ 11166, 11166.2, 11166.05, and 11167.5. Further, as to release of 7 Plaintiffs juvenile dependency court records, it was ordered by the Court to be 8 9 subject to a protective order. See Dkt. 58. 10 Between 2021 and 2023, the City of Los Angeles and the Los Angeles Police 11 12 Department investigated allegations of child sexual abuse perpetrated against 13 Plaintiffs Y.A., and Q.A. as well as two of their siblings. The investigation included 14 interviews of victims who were abused as children and information about the alleged 15 16 perpetrator of the crimes who is a non-party and whose privacy rights are also 17 implicated. As such, there may be voluminous sensitive materials including police 18 reports, recorded interviews depicting graphic sexual abuse of minors, and other law 19 20 enforcement records, which may be protected pursuant to Government Code § 21 6254(f), Penal Code §§ 832.5, 832.7, 832.8 and 11105, and Evidence Code § 1040. 22 Further, it is possible the parties in this action may seek confidential information 23 24 relating to individual police officers and as such their privacy rights are also 25 implicated pursuant to Evidence Code § 1043, and Pitchess v. Superior Court (1974) 26 11 Cal.3d 531, 535. See also Green v. Baca, 226 F.R.D. 624, 653 (C.D. Cal. 2005) 27 28 and A. Farber and Partners, Inc., 234 F.R.D. 186, 189-90 (C.D. Cal. 2006). Federal 2 States District Court for the Northern District of California, 511 F.2d 192, 198 (9th 3 Cir.1975), aff’d, 426 U.S. 394 (1976); Sanchez v. City of Santa Ana, 936 F.2d 1027, 4 5 1033 (9th Cir. 1990), cert. denied, 502 U.S. 957 (1991). It is the position of the City 6 of Los Angeles and the Los Angeles Police Department that the release of such 7 records cannot be considered absent a protective order and, in some cases, a court 8 9 order. 10 2. DEFINITIONS 11 12 2.1 Action: Case No.: 2:23-cv-00875-FMO-MAR 13 2.2 Challenging Party: a Party or Non-Party that challenges the designation 14 of information or items under this Order. 15 16 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 17 how it is generated, stored or maintained) or tangible things that qualify for 18 protection under Federal Rule of Civil Procedure 26(c), and as specified above in the 19 20 Good Cause Statement. 21 2.4 Counsel: Attorneys of record in the action and their affiliated attorneys, 22 paralegals, clerical, and secretarial staff employed by such attorneys who are actively 23 24 involved in the action, and retained by a party, and are not employees of any party. 25 In-House counsel to the undersigned Parties and the paralegal, clerical, and 26 secretarial staff employed by such counsel. Provided, however that each non-lawyer 27 28 given access to Confidential Materials shall be advised that such Materials are being 2 Order and that they may not be disclosed other than pursuant to its terms; Outside 3 Counsel of Record and House Counsel (as well as their support staff). 4 5 2.5 Designating Party: a Party or Non-Party that designates information or 6 items that it produces in disclosures or in responses to discovery as 7 “CONFIDENTIAL.” 8 9 2.6 Disclosure or Discovery Material: all items or information, regardless 10 of the medium or manner in which it is generated, stored, or maintained (including, 11 12 among other things, testimony, transcripts, and tangible things), that are produced or 13 generated in disclosures or responses to discovery in this matter. 14 2.7 Expert: a person with specialized knowledge or experience in a matter 15 16 pertinent to the litigation who has been retained by a Party or its counsel to serve as 17 an expert witness or as a consultant in this Action. 18 2.8 House Counsel: attorneys who are employees of a party to this Action. 19 20 House Counsel does not include Outside Counsel of Record or any other outside 21 counsel. 22 2.9 Non-Party: any natural person, partnership, corporation, association, or 23 24 other legal entity not named as a Party to this action. 25 2.10 Outside Counsel of Record: attorneys who are not employees of a party 26 to this Action but are retained to represent or advise a party to this Action and have 27 28 appeared in this Action on behalf of that party or are affiliated with a law firm which 2 2.11 Party: any party to this Action, including all of its officers, directors, 3 employees, consultants, retained experts, and Outside Counsel of Record (and their 4 5 support staff). 6 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 7 Discovery Material in this Action. 8 9 2.13 Professional Vendors: persons or entities that provide litigation support 10 services (e.g., photocopying, videotaping, translating, preparing exhibits or 11 12 demonstrations, and organizing, storing, or retrieving data in any form or medium) 13 and their employees and subcontractors. 14 2.14 Protected Material: any Disclosure or Discovery Material that is 15 16 designated as “CONFIDENTIAL.” 17 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 18 from a Producing Party. 19 20 3. SCOPE 21 The protections conferred by this Stipulation and Order cover not only 22 Protected Material (as defined above), but also (1) any information copied or 23 24 extracted from Protected Material; (2) all copies, excerpts, summaries, or 25 compilations of Protected Material; and (3) any testimony, conversations, or 26 presentations by Parties or their Counsel that might reveal Protected Material. 27 28 2 trial judge. This Order does not govern the use of Protected Material at trial. 3 4. DURATION 4 5 Once a case proceeds to a trial, all of the information that was designated as 6 confidential or maintained pursuant to this protective order becomes public and will 7 8 be presumptively available to all members of the public, including the press, unless 9 compelling reasons supported by specific factual findings to proceed otherwise are 10 made to the trial judge in advance of the trial. See Kamakana v. City and County of 11 12 Honolulu, 447 F.3d 1172, 1180–81 (9th Cir. 2006) (distinguishing “good cause” 13 showing for sealing documents produced in discovery from “compelling reasons” 14 standard when merits-related documents are part of court record). Accordingly, the 15 16 terms of this protective order do not extend beyond the commencement of the trial. 17 5. DESIGNATING PROTECTED MATERIAL 18 19 5.1 Exercise of Restraint and Care in Designating Material for Protection. 20 Each Party or Non-Party that designates information or items for protection 21 under this Order must take care to limit any such designation to specific material that 22 23 qualifies under the appropriate standards. The Designating Party must designate for 24 protection only those parts of material, documents, items, or oral or written 25 communications that qualify so that other portions of the material, documents, items, 26 27 or communications for which protection is not warranted are not swept unjustifiably 28 2 Mass, indiscriminate, or routinized designations are prohibited. Designations 3 that are shown to be clearly unjustified or that have been made for an improper 4 5 purpose (e.g., to unnecessarily encumber the case development process or to impose 6 unnecessary expenses and burdens on other parties) may expose the Designating 7 Party to sanctions. 8 9 If it comes to a Designating Party’s attention that information or items that it 10 designated for protection do not qualify for protection, that Designating Party must 11 12 promptly notify all other Parties that it is withdrawing the inapplicable designation. 13 5.2 Manner and Timing of Designations. Except as otherwise provided in 14 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 15 16 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 17 under this Order must be clearly so designated before the material is disclosed or 18 produced. 19 20 Designation in conformity with this Order requires: 21 (a) for information in documentary form (e.g., paper or electronic 22 documents, but excluding transcripts of depositions or other pretrial or trial 23 24 proceedings), that the Producing Party affix, at a minimum, the legend 25 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 26 contains protected material. If only a portion or portions of the material on a page 27 28 qualifies for protection, the Producing Party also must clearly identify the protected 2 A Party or Non-Party that makes original documents available for inspection 3 need not designate them for protection until after the inspecting Party has indicated 4 5 which documents it would like copied and produced. During the inspection and 6 before the designation, all of the material made available for inspection shall be 7 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 8 9 documents it wants copied and produced, the Producing Party must determine which 10 documents, or portions thereof, qualify for protection under this Order. Then, before 11 12 producing the specified documents, the Producing Party must affix the 13 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 14 portion or portions of the material on a page qualifies for protection, the Producing 15 16 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 17 markings in the margins). 18 (b) for testimony given in depositions that the Designating Party identify 19 20 the Disclosure or Discovery Material on the record, before the close of the deposition 21 all protected testimony. 22 (c) for information produced in some form other than documentary and for 23 24 any other tangible items, that the Producing Party affix in a prominent place on the 25 exterior of the container or containers in which the information is stored the legend 26 “CONFIDENTIAL.” If only a portion or portions of the information warrants 27 28 protection, the Producing Party, to the extent practicable, shall identify the protected 2 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 3 failure to designate qualified information or items does not, standing alone, waive 4 5 the Designating Party’s right to secure protection under this Order for such material. 6 Upon timely correction of a designation, the Receiving Party must make reasonable 7 efforts to assure that the material is treated in accordance with the provisions of this 8 9 Order. 10 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 11 12 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 13 designation of confidentiality at any time that is consistent with the Court’s 14 Scheduling Order. 15 16 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 17 resolution process under Local Rule 37.1 et seq. 18 6.3 The burden of persuasion in any such challenge proceeding shall be on 19 20 the Designating Party. Frivolous challenges, and those made for an improper purpose 21 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 22 expose the Challenging Party to sanctions. Unless the Designating Party has waived 23 24 or withdrawn the confidentiality designation, all parties shall continue to afford the 25 material in question the level of protection to which it is entitled under the Producing 26 Party’s designation until the Court rules on the challenge. 27 28 /// 2 7.1 Basic Principles. A Receiving Party may use Protected Material that is 3 4 disclosed or produced by another Party or by a Non-Party in connection with this 5 Action only for prosecuting, defending, or attempting to settle this Action. Such 6 Protected Material may be disclosed only to the categories of persons and under the 7 8 conditions described in this Order. When the Action has been terminated, a 9 Receiving Party must comply with the provisions of section 13 below (FINAL 10

DISPOSITION).

11 12 Protected Material must be stored and maintained by a Receiving Party at a 13 location and in a secure manner that ensures that access is limited to the persons 14 authorized under this Order. 15 16 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 17 otherwise ordered by the court or permitted in writing by the Designating Party, a 18 Receiving Party may disclose any information or item designated 19 20 “CONFIDENTIAL” only to: 21 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 22 as employees of said Outside Counsel of Record to whom it is reasonably necessary 23 24 to disclose the information for this Action; 25 (b) the officers, directors, and employees (including House Counsel) of the 26 Receiving Party to whom disclosure is reasonably necessary for this Action; 27 28 (c) Experts (as defined in this Order) of the Receiving Party to whom 2 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 3 (d) the court and its personnel; 4 5 (e) court reporters and their staff; 6 (f) professional jury or trial consultants, mock jurors, and Professional 7 Vendors to whom disclosure is reasonably necessary for this Action and who have 8 9 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 10 (g) the author or recipient of a document containing the information or a 11 12 custodian or other person who otherwise possessed or knew the information; 13 (h) during their depositions, witnesses ,and attorneys for witnesses, in the 14 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 15 16 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will 17 not be permitted to keep any confidential information unless they sign the 18 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 19 20 agreed by the Designating Party or ordered by the court. Pages of transcribed 21 deposition testimony or exhibits to depositions that reveal Protected Material may 22 be separately bound by the court reporter and may not be disclosed to anyone except 23 24 as permitted under this Stipulated Protective Order; and 25 (i) any mediator or settlement officer, and their supporting personnel, 26 mutually agreed upon by any of the parties engaged in settlement discussions. 27 28 2

IN OTHER LITIGATION.

3 4 If a Party is served with a subpoena or a court order issued in other litigation 5 that compels disclosure of any information or items designated in this Action as 6 “CONFIDENTIAL,” that Party must: 7 8 (a) promptly notify in writing the Designating Party. Such notification shall 9 include a copy of the subpoena or court order; 10 11 (b) promptly notify in writing the party who caused the subpoena or order 12 to issue in the other litigation that some or all of the material covered by the subpoena 13 or order is subject to this Protective Order. Such notification shall include a copy of 14 15 this Stipulated Protective Order; and 16 (c) cooperate with respect to all reasonable procedures sought to be pursued 17 by the Designating Party whose Protected Material may be affected. 18 19 If the Designating Party timely seeks a protective order, the Party served 20 with the subpoena or court order shall not produce any information designated in this 21 action as “CONFIDENTIAL” before a determination by the court from which the 22 23 subpoena or order issued, unless the Party has obtained the Designating Party’s 24 permission. The Designating Party shall bear the burden and expense of seeking 25 protection in that court of its confidential material and nothing in these provisions 26 27 should be construed as authorizing or encouraging a Receiving Party in this Action 28 to disobey a lawful directive from another court. 2

BE PRODUCED IN THIS LITIGATION

3 4 (a) The terms of this Order are applicable to information produced by a 5 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 6 produced by Non-Parties in connection with this litigation is protected by the 7 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 12 produce a Non-Party’s confidential information in its possession, and the Party is 13 subject to an agreement with the Non-Party not to produce the Non-Party’s 14 confidential information, then the Party shall: 15 16 (1) promptly notify in writing the Requesting Party and the Non-Party 17 that some or all of the information requested is subject to a confidentiality agreement 18 19 with a Non-Party; 20 (2) promptly provide the Non-Party with a copy of the Stipulated 21 Protective Order in this Action, the relevant discovery request(s), and a reasonably 22 23 specific description of the information requested; and 24 (3) make the information requested available for inspection by the 25 Non-Party, if requested. 26 27 (c) If the Non-Party fails to seek a protective order from this court within 28 14 days of receiving the notice and accompanying information, the Receiving Party 2 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 3 not produce any information in its possession or control that is subject to the 4 5 confidentiality agreement with the Non-Party before a determination by the court. 6 Absent a court order to the contrary, the Non-Party shall bear the burden and expense 7 of seeking protection in this court of its Protected Material. 8 9 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 10 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 11 12 Protected Material to any person or in any circumstance not authorized under this 13 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 14 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 15 16 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 17 persons to whom unauthorized disclosures were made of all the terms of this Order, 18 and (d) request such person or persons to execute the “Acknowledgment and 19 20 Agreement to Be Bound” that is attached hereto as Exhibit A. 21 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 22 23 PROTECTED MATERIAL 24 When a Producing Party gives notice to Receiving Parties that certain 25 inadvertently produced material is subject to a claim of privilege or other protection, 26 27 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 28 2 may be established in an e-discovery order that provides for production without prior 3 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 4 5 parties reach an agreement on the effect of disclosure of a communication or 6 information covered by the attorney-client privilege or work product protection, the 7 parties may incorporate their agreement in the stipulated protective order submitted 8 9 to the court. 10 12. MISCELLANEOUS 11 12 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 13 person to seek its modification by the Court in the future. 14 12.2 Right to Assert Other Objections. By stipulating to the entry of this 15 16 Protective Order no Party waives any right it otherwise would have to object to 17 disclosing or producing any information or item on any ground not addressed in this 18 Stipulated Protective Order. Similarly, no Party waives any right to object on any 19 20 ground to use in evidence of any of the material covered by this Protective Order. 21 12.3 Filing Protected Material. A Party that seeks to file under seal any 22 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 23 24 only be filed under seal pursuant to a court order authorizing the sealing of the 25 specific Protected Material at issue. If a Party's request to file Protected Material 26 under seal is denied by the court, then the Receiving Party may file the information 27 28 in the public record unless otherwise instructed by the court. 2 After the final disposition of this Action, as defined in paragraph 4, within 60 3 4 days of a written request by the Designating Party, each Receiving Party must return 5 all Protected Material to the Producing Party or destroy such material. As used in 6 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 7 8 summaries, and any other format reproducing or capturing any of the Protected 9 Material. Whether the Protected Material is returned or destroyed, the Receiving 10 Party must submit a written certification to the Producing Party (and, if not the same 11 12 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 13 (by category, where appropriate) all the Protected Material that was returned or 14 destroyed and (2)affirms that the Receiving Party has not retained any copies, 15 16 abstracts, compilations, summaries or any other format reproducing or capturing any 17 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 18 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 19 20 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 21 reports, attorney work product, and consultant and expert work product, even if such 22 materials contain Protected Material. Any such archival copies that contain or 23 24 constitute Protected Material remain subject to this Protective Order as set forth in 25 Section 4 (DURATION). This provision shall not apply to the parties who are 26 entitled to the juvenile case file as defined in Welfare and Institution Code § 27 28 827(a)(1)(A-T). 1/114. Any violation of this Order may be punished by any and all appropriate 2 measures including, without limitation, contempt proceedings and/or monetary 3 4 || Sanctions. > || IT SO STIPULATED, THROUGH COUNSEL OF RECORD. 6 7 DATED: March 13, 2025 /s/ Robert Powell 3 Attorneys for Plaintiffs 9 0 DATED: March 13, 2025 /s/ Vincent Contreras

“4 Attorneys for Defendants, County of Los Angeles 49 and its social workers 8 20 13 DATED: March 13, 2025 /s/ Sasha Lazarevich 8 45 Attorneys for Defendants City of Los Angeles and 3 16 its police officers a “18 3 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED

99 || DATED: 3/25/2025 21 22 23 || Honorable Margo A. Rocconi 24 || United States Magistrate Judge 25 26 27 28 18

QRTTPTT ATED PROTRCTIVE ORDER

2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, ________________________ [print or type full 4 name], of _________________ [print or type full address], declare under 5 penalty of perjury under the laws of the United States of America that I have read 6 in its entirety and understand the Stipulated Protective Order that was issued by the 7 United States District Court for the Central District of California on [date] in the 8 case of Luis Enrique Aguilera Angeles et al v. County of Los Angeles, et al Case 9 No.: 2:23-cv-00875-FMO-MAR. I agree to comply with and to be bound by all the 10 terms of this Stipulated Protective Order and I understand and acknowledge that 11 failure to so comply could expose me to sanctions and punishment in the nature of 12 contempt. I solemnly promise that I will not disclose in any manner any information 13 or item that is subject to this Stipulated Protective Order to any person or entity 14 except in strict compliance with the provisions of this Order. I further agree to 15 submit to the jurisdiction of the United States District Court for the Central District 16 of California for the purpose of enforcing the terms of this Stipulated Protective 17 Order, even if such enforcement proceedings occur after termination of this action. 18 I hereby appoint ________________________ [print or type full name] of 19 _________ [print or type full address and telephone number] as my California 20 agent for service of process in connection with this action or any proceedings 21 related to enforcement of this Stipulated Protective Order. 22 Date: __________________________ 23 City and State where sworn and signed: _____________________________ 24 Printed name: ____________________________________ 25 Signature: ________________________________ 26

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