PATRICK E. STOCKALPER, SBN 156954

1 MOLSHREE GUPTA, SBN 275101

CHAENA DADE, SBN 310365

2 KJAR, MCKENNA & STOCKALPER, LLP 841 Apollo Street, Suite 100 3 El Segundo, California 90245 Telephone (424) 217-3026 4 Facsimile (424) 367-0400 pstockalper@kmslegal.com 5 mgupta@kmslegal.com cdade@kmslegal.com 6

7 Attorneys for Defendants,

RIVERSIDE COUNTY CHILD SERVICES DPSS, PETER BRICARELLO,

8

GUADALOUPE IBANEZ DE MOLLETI, ANTHONY RADER

9 10 UNITED STATES DISTRICT COURT 11 CENTRAL DISTRICT OF THE STATE OF CALIFORNIA 12

13 NABIL MIHOUBI, Case No.: 5:24-cv-02472-AH (MAAx) 14 Plaintiff, AMENDED STIPULATED 15

PROTECTIVE ORDER

16 v.

17 RIVERSIDE COUNTY CHILD Action Filed: November 19, 2024 18 SERVICES DPSS; PETER Pretrial Conference: *** BRICARELLO, an individual; Trial Date: *** 19

GUADALOUPE IBANEZ DE

20 MOLLETI, an individual; Assigned to: 21 ANTHONY RADER, an individual; Hon. Anne Hwang, District Judge Courtroom 7D 22 Defendants. 23 24 25 1. PURPOSES AND LIMITATIONS 26 Discovery in this action is likely to involve production of confidential, proprietary, 27 or private information for which special protection from public disclosure and from use 28 for any purpose other than prosecuting this litigation may be warranted. Accordingly, the 1 parties hereby stipulate to and petition the Court to enter the following Stipulated 2 Protective Order. The parties acknowledge that this Stipulated Protective Order does not 3 confer blanket protections on all disclosures or responses to discovery and that the 4 protection it affords from public disclosure and use extends only to the limited 5 information or items that are entitled to confidential treatment under the applicable legal 6 principles. The parties further acknowledge, as set forth in Section 13.3 below, that this 7 Stipulated Protective Order does not entitle them to file confidential information under 8 seal; Local Rule 79-5 sets forth the procedures that must be followed and the standards 9 that will be applied when a party seeks permission from the Court to file material under 10 seal. 11 12 2. GOOD CAUSE STATEMENT 13 In connection with this action, Plaintiff and the Defendants may produce certain 14 documents, things, materials, or other information derived therefrom that contain 15 personal medical, employment or financial information not available to the public; 16 and/or personnel files, information, Department of Public Social Services records and 17 County Department of Human Resources records; and any confidential information 18 contained therein or in any summary, copy, abstract, or other documents derived in 19 whole or part therefrom. Such information may implicate the privacy interests of the 20 party and are properly protected through a Fed. R. Civ. P. 26(c) protective order. Seattle 21 Times Co. v. Rhinehart, 467 U.S. 20, 35 n.21 (1984) (“Rule 26(c) includes among its 22 express purposes the protection of a ‘party or person from annoyance, embarrassment, 23 oppression or undue burden or expense.’ Although the Rule contains no specific 24 reference to privacy or to other rights or interests that may be implicated, such matters 25 are implicit in the broad purpose and language of the Rule.”); Soto v. City of Concord, 26 162 F.R.D. 603, 617 (N.D. Cal. 1995) (a party’s privacy rights are to be protected 27 through a “carefully crafted protective order.”). 28 California law fiercely protects the confidentiality of juvenile records. See, e.g., 1 Cal. Welf. & Inst. Code section 827 (providing that “the Legislature reaffirms its belief 2 that juvenile court records, in general, should be confidential”). Federal courts have 3 likewise adhered to this confidentiality. See Meyer v. County of San Diego, 2022 WL 4 395967, *7 (S.D. Cal., Feb. 8, 2022) and T.T. v. Cty. of San Diego, 2020 WL 6118781, at 5 *1 (S.D. Cal. Oct. 16, 2020) (granting a motion to seal juvenile records because “given 6 the confidential status of plaintiff’s juvenile records pursuant to section 827 of the 7 Welfare and Institutional Code, the Court finds that defendants have articulated 8 compelling reasons in support of their motion to seal”). 9 In light of the nature of the claims and allegations in this case and the parties’ 10 representations that discovery in this case will involve the production of confidential 11 records, including but not limited to sensitive operational documents (including 12 investigative records) and/or confidential employment/personnel records and 13 information of employees of the County, as well as Plaintiff’s medical and mental health 14 information, and confidential juvenile dependency court records containing private and 15 sensitive information pertaining to Plaintiff and/or Plaintiff’s minor child as it relates to 16 their underlying juvenile dependency case which is the subject of this action. The 17 disclosure of the foregoing information to non-parties or others would be harmful to the 18 parties' interests, including Plaintiff. Therefore, this information must be protected. The 19 parties shall not designate any information/documents as confidential without a good 20 faith belief that such information/documents have been maintained in a confidential, 21 non-public manner, and that there is good cause or a compelling reason why it should 22 not be part of the public record of this case. 23 24 3. DEFINITIONS 25 3.1. Action: This pending federal lawsuit, Nabil Mihoubi v. Riverside County 26 Child Services DPSS, et al., Case No. 5:24-cv-02472-AH (MAAx). 27 3.2. Challenging Party: A Party or Nonparty that challenges the designation of 28 information or items under this Stipulated Protective Order. 1 3.3. “CONFIDENTIAL” Information or Items: Information (regardless of how 2 it is generated, stored or maintained) or tangible things that qualify for 3 protection under Federal Rule of Civil Procedure 26(c), and as specified 4 above in the Good Cause Statement. 5 3.4. Counsel: Outside Counsel of Record and In-House Counsel (as well as their 6 support staff). 7 3.5. Designating Party: A Party or Nonparty that designates information or items 8 that it produces in disclosures or in responses to discovery as 9 “CONFIDENTIAL.” 10 3.6. Disclosure or Discovery Material: All items or information, regardless of 11 the medium or manner in which it is generated, stored, or maintained 12 (including, among other things, testimony, transcripts, and tangible things), 13 that is produced or generated in disclosures or responses to discovery in this 14 matter. 15 3.7. Expert: A person with specialized knowledge or experience in a matter 16 pertinent to the litigation who has been retained by a Party or its counsel to 17 serve as an expert witness or as a consultant in this Action. 18 3.8. In-House Counsel: Attorneys who are employees of a party to this Action. 19 In-House Counsel does not include Outside Counsel of Record or any other 20 outside counsel. 21 3.9. Nonparty: Any natural person, partnership, corporation, association, or 22 other legal entity not named as a Party to this action. 23 3.10. Outside Counsel of Record: Attorneys who are not employees of a party to 24 this Action but are retained to represent or advise a party to this Action and 25 have appeared in this Action on behalf of that party or are affiliated with a 26 law firm which has appeared on behalf of that party, and includes support 27 staff. 28 3.11. Party: Any party to this Action, including all of its officers, directors, 1 employees, consultants, retained experts, In-House Counsel, and Outside 2 Counsel of Record (and their support staffs). 3 3.12. Producing Party: A Party or Nonparty that produces Disclosure or 4 Discovery Material in this Action. 5 3.13. Professional Vendors: Persons or entities that provide litigation support 6 services (e.g., photocopying, videotaping, translating, preparing exhibits or 7 demonstrations, and organizing, storing, or retrieving data in any form or 8 medium) and their employees and subcontractors. 9 3.14. Protected Material: Any Disclosure or Discovery Material that is designated 10 as “CONFIDENTIAL.” 11 3.15. Receiving Party: A Party that receives Disclosure or Discovery Material 12 from a Producing Party. 13 14 4. SCOPE 15 The protections conferred by this Stipulated Protective Order cover not only 16 Protected Material, but also (1) any information copied or extracted from Protected 17 Material; (2) all copies, excerpts, summaries, or compilations of Protected Material; and 18 (3) any testimony, conversations, or presentations by Parties or their Counsel that might 19 reveal Protected Material. 20 Any use of Protected Material at trial shall be governed by the orders of the trial 21 judge. This Stipulated Protective Order does not govern the use of Protected Material at 22 trial. 23 24 5. DURATION 25 Even after final disposition of this litigation, the confidentiality obligations 26 imposed by this Stipulated Protective Order shall remain in effect until a Designating 27 Party agrees otherwise in writing or a court order otherwise directs. Final disposition 28 shall be deemed to be the later of (1) dismissal of all claims and defenses in this Action, 1 with or without prejudice; and (2) final judgment herein 2 3 after the completion and exhaustion of all appeals, rehearings, remands, trials, or reviews 4 of this Action, including the time limits for filing any motions or applications for 5 extension of time pursuant to applicable law. 6 7 6. DESIGNATING PROTECTED MATERIAL 8 6.1. Exercise of Restraint and Care in Designating Material for Protection. 9 Each Party or Nonparty that designates information or items for protection 10 under this Stipulated Protective Order must take care to limit any such designation 11 to specific material that qualifies under the appropriate standards. The Designating 12 Party must designate for protection only those parts of material, documents, items, 13 or oral or written communications that qualify so that other portions of the 14 material, documents, items, or communications for which protection is not 15 warranted are not swept unjustifiably within the ambit of this Stipulated Protective 16 Order. 17 Mass, indiscriminate, or routinized designations are prohibited. 18 Designations that are shown to be clearly unjustified or that have been made for an 19 improper purpose (e.g., to unnecessarily encumber the case development process 20 or to impose unnecessary expenses and burdens on other parties) may expose the 21 Designating Party to sanctions. 22 6.2. Manner and Timing of Designations. 23 Except as otherwise provided in this Stipulated Protective Order (see, e.g., 24 Section 6.2(a)), or as otherwise stipulated or ordered, Disclosure or Discovery 25 Material that qualifies for protection under this Stipulated Protective Order must 26 be clearly so designated before the material is disclosed or produced. 27 Designation in conformity with this Stipulated Protective Order requires the 28 following: 1 (a) For information in documentary form (e.g., paper or electronic documents, 2 but excluding transcripts of depositions or other pretrial or trial 3 proceedings), that the Producing Party affix at a minimum, the legend 4 “CONFIDENTIAL” to each page that contains protected material. If only a 5 portion or portions of the material on a page qualifies for protection, the 6 Producing Party also must clearly identify the protected portion(s) (e.g., by 7 making appropriate markings in the margins). 8 A Party or Nonparty that makes original documents available for 9 inspection need not designate them for protection until after the inspecting 10 Party has indicated which documents it would like copied and produced. 11 During the inspection and before the designation, all of the material made 12 available for inspection shall be deemed “CONFIDENTIAL.” After the 13 inspecting Party has identified the documents it wants copied and produced, 14 the Producing Party must determine which documents, or portions thereof, 15 qualify for protection under this Stipulated Protective Order. Then, before 16 producing the specified documents, the Producing Party must affix the 17 legend “CONFIDENTIAL” to each page that contains Protected Material. If 18 only a portion or portions of the material on a page qualifies for protection, 19 the Producing Party also must clearly identify the protected portion(s) (e.g., 20 by making appropriate markings in the margins). 21 (b) For testimony given in depositions, that the Designating Party identify the 22 Disclosure or Discovery Material on the record, before the close of the 23 deposition, all protected testimony. 24 (c) For information produced in nondocumentary form, and for any other 25 tangible items, that the Producing Party affix in a prominent place on the 26 exterior of the container or containers in which the information is stored the 27 legend “CONFIDENTIAL.” If only a portion or portions of the information 28 warrants protection, the Producing Party, to the extent practicable, shall 1 identify the protected portion(s). 2 3 6.3. Inadvertent Failure to Designate. 4 If timely corrected, an inadvertent failure to designate qualified 5 information or items does not, standing alone, waive the Designating 6 Party’s right to secure protection under this Stipulated Protective Order for 7 such material. Upon timely correction of a designation, the Receiving Party 8 must make reasonable efforts to assure that the material is treated in 9 accordance with the provisions of this Stipulated Protective Order. 10 11 7. CHALLENGING CONFIDENTIALITY DESIGNATIONS 12 7.1. Timing of Challenges. 13 Any Party or Nonparty may challenge a designation of confidentiality 14 at any time that is consistent with the Court’s Scheduling Order. 15 7.2. Meet and Confer. 16 The Challenging Party shall initiate the dispute resolution process, 17 which shall comply with Local Rule 37.1 et seq., and with Section 4 of 18 Judge Audero’s Procedures (“Mandatory Telephonic Conference for 19 Discovery Disputes”).1 20 7.3. Burden of Persuasion. 21 The burden of persuasion in any such challenge proceeding shall be 22 on the Designating Party. Frivolous challenges, and those made for an 23 improper purpose (e.g., to harass or impose unnecessary expenses and 24 burdens on other parties) may expose the Challenging Party to sanctions. 25 Unless the Designating Party has waived or withdrawn the confidentiality 26 designation, all parties shall continue to afford the material in question the 27

28 1 Judge Audero’s Procedures are available at https://www.cacd.uscourts.gov/honorable-maria-audero. 1 level of protection to which it is entitled under the Producing Party’s 2 designation until the Court rules on the challenge. 3 8. ACCESS TO AND USE OF PROTECTED MATERIALS 4 8.1. Basic Principles. 5 A Receiving Party may use Protected Material that is disclosed or 6 produced by another Party or by a Nonparty in connection with this Action 7 only for prosecuting, defending, or attempting to settle this Action. Such 8 Protected Material may be disclosed only to the categories of persons and 9 under the conditions described in this Stipulated Protective Order. When the 10 Action reaches a final disposition, a Receiving Party must comply with the 11 provisions of Section 14 below. 12 Protected Material must be stored and maintained by a Receiving 13 Party at a location and in a secure manner that ensures that access is limited 14 to the persons authorized under this Stipulated Protective Order. 15 8.2. Disclosure of “CONFIDENTIAL” Information or Items. 16 Unless otherwise ordered by the Court or permitted in writing by the 17 Designating Party, a Receiving Party may disclose any information or item 18 designated “CONFIDENTIAL” only to: 19 (a) The Receiving Party’s Outside Counsel of Record, as well as 20 employees of said Outside Counsel of Record to whom it is 21 reasonably necessary to disclose the information for this Action; 22 (b) The officers, directors, and employees (including In-House Counsel) 23 of the Receiving Party to whom disclosure is reasonably necessary 24 for this Action; 25 (c) Experts of the Receiving Party to whom disclosure is reasonably 26 necessary for this Action and who have signed the “Acknowledgment 27 and Agreement to Be Bound” (Exhibit A); 28 (d) The Court and its personnel; 1 (e) Court reporters and their staff; 2 (f) Professional jury or trial consultants, mock jurors, and Professional 3 Vendors to whom disclosure is reasonably necessary or this Action 4 and who have signed the “Acknowledgment and Agreement to be 5 Bound” (Exhibit A); 6 (g) The author or recipient of a document containing the information or a 7 custodian or other person who otherwise possessed or knew the 8 information; 9 (h) During their depositions, witnesses, and attorneys for 10 witnesses, in the Action to whom disclosure is reasonably necessary 11 provided: (i) the deposing party requests that the witness sign the 12 “Acknowledgment and Agreement to Be Bound” (Exhibit A); and (ii) 13 the witness will not be permitted to keep any confidential information 14 unless they sign the “Acknowledgment and Agreement to Be 15 Bound,” unless otherwise agreed by the Designating Party or ordered 16 by the Court. Pages of transcribed deposition testimony or exhibits to 17 depositions that reveal Protected Material may be separately bound 18 by the court reporter and may not be disclosed to anyone except as 19 permitted under this Stipulated Protective Order; and 20 (i) Any mediator or settlement officer, and their supporting personnel, 21 mutually agreed upon by any of the parties engaged in settlement 22 discussions. 23 24 9. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 25 IN OTHER LITIGATION 26 If a Party is served with a subpoena or a court order issued in other litigation that 27 compels disclosure of any information or items designated in this Action as 28 “CONFIDENTIAL,” that Party must: 1 (a) Promptly notify in writing the Designating Party. Such notification shall 2 include a copy of the subpoena or court order; 3 (b) Promptly notify in writing the party who caused the subpoena or order to 4 issue in the other litigation that some or all of the material covered by the 5 subpoena or order is subject to this Stipulated Protective Order. Such 6 notification shall include a copy of this Stipulated Protective Order; and 7 (c) Cooperate with respect to all reasonable procedures sought to be pursued by 8 the Designating Party whose Protected Material may be affected. 9 If the Designating Party timely seeks a protective order, the Party served with the 10 subpoena or court order shall not produce any information designated in this action as 11 “CONFIDENTIAL” before a determination by the Court from which the subpoena or 12 order issued, unless the Party has obtained the Designating Party’s permission. The 13 Designating Party shall bear the burden and expense of seeking protection in that court 14 of its confidential material and nothing in these provisions should be construed as 15 authorizing or encouraging a Receiving Party in this Action to disobey a lawful directive 16 from another court. 17 18 10. A NONPARTY’S PROTECTED MATERIAL SOUGHT TO BE 19 PRODUCED IN THIS LITIGATION 20 10.1. Application. 21 The terms of this Stipulated Protective Order are applicable to 22 information produced by a Nonparty in this Action and designated as 23 “CONFIDENTIAL.” Such information produced by Nonparties in 24 connection with this litigation is protected by the remedies and relief 25 provided by this Stipulated Protective Order. Nothing in these provisions 26 should be construed as prohibiting a Nonparty from seeking additional 27 protections. 28 10.2. Notification. 1 In the event that a Party is required, by a valid discovery request, to 2 produce a Nonparty’s confidential information in its possession, and the 3 Party is subject to an agreement with the Nonparty not to produce the 4 Nonparty’s confidential information, then the Party shall: 5 (a) Promptly notify in writing the Requesting Party and the Nonparty 6 that some or all of the information requested is subject to a 7 confidentiality agreement with a Nonparty; 8 (b) Promptly provide the Nonparty with a copy of the Stipulated 9 Protective Order in this Action, the relevant discovery request(s), and 10 a reasonably specific description of the information requested; and 11 (c) Make the information requested available for inspection by the 12 Nonparty, if requested. 13 10.3. Conditions of Production. 14 If the Nonparty fails to seek a protective order from this Court within 15 fourteen (14) days after receiving the notice and accompanying information, 16 the Receiving Party may produce the Nonparty’s confidential information 17 responsive to the discovery request. If the Nonparty timely seeks a 18 protective order, the Receiving Party shall not produce any information in 19 its possession or control that is subject to the confidentiality agreement with 20 the Nonparty before a determination by the Court. Absent a court order to 21 the contrary, the Nonparty shall bear the burden and expense of seeking 22 protection in this Court of its Protected Material. 23 24 11. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 25 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 26 Protected Material to any person or in any circumstance not authorized under this 27 Stipulated Protective Order, the Receiving Party immediately must (1) notify in writing 28 the Designating Party of the unauthorized disclosures, (2) use its best efforts to retrieve 1 all unauthorized copies of the Protected Material, (3) inform the person or persons to 2 whom unauthorized disclosures were made of all the terms of this Stipulated Protective 3 Order, and (4) request such person or persons to execute the “Acknowledgment and 4 Agreement to be Bound” (Exhibit A). 5 6 12. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 7 PROTECTED MATERIAL 8 When a Producing Party gives notice to Receiving Parties that certain 9 inadvertently produced material is subject to a claim of privilege or other protection, the 10 obligations of the Receiving Parties are those set forth in Federal Rule of Civil Procedure 11 26(b)(5)(B). This provision is not intended to modify whatever procedure may be 12 established in an e-discovery order that provides for production without prior privilege 13 review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the parties reach 14 an agreement on the effect of disclosure of a communication or information covered by 15 the attorney-client privilege or work product protection, the parties may incorporate their 16 agreement in the Stipulated Protective Order submitted to the Court. 17 18 13. MISCELLANEOUS 19 13.1. Right to Further Relief. 20 Nothing in this Stipulated Protective Order abridges the right of any 21 person to seek its modification by the Court in the future. 22 13.2. Right to Assert Other Objections. 23 By stipulating to the entry of this Stipulated Protective Order, no 24 Party waives any right it otherwise would have to object to disclosing or 25 producing any information or item on any ground not addressed in this 26 Stipulated Protective Order. Similarly, no Party waives any right to object 27 on any ground to use in evidence of any of the material covered by this 28 Stipulated Protective Order. 1 13.3. Filing Protected Material. 2 A Party that seeks to file under seal any Protected Material must 3 comply with Local Rule 79-5. Protected Material may only be filed under 4 seal pursuant to a court order authorizing the sealing of the specific 5 Protected Material at issue. If a Party's request to file Protected Material 6 under seal is denied by the Court, then the Receiving Party may file the 7 information in the public record unless otherwise instructed by the Court. 8 9 14. FINAL DISPOSITION 10 After the final disposition of this Action, within sixty (60) days of a written 11 request by the Designating Party, each Receiving Party must return all Protected 12 Material to the Producing Party or destroy such material. As used in this subdivision, “all 13 Protected Material” includes all copies, abstracts, compilations, summaries, and any 14 other format reproducing or capturing any of the Protected Material. Whether the 15 Protected Material is returned or destroyed, the Receiving Party must submit a written 16 certification to the Producing Party (and, if not the same person or entity, to the 17 Designating Party) by the 60-day deadline that (1) identifies (by category, where 18 appropriate) all the Protected Material that was returned or destroyed and (2) affirms that 19 the Receiving Party has not retained any copies, abstracts, compilations, summaries or 20 any other format reproducing or capturing any of the Protected Material. 21 Notwithstanding this provision, Counsel is entitled to retain an archival copy of all 22 pleadings; motion papers; trial, deposition, and hearing transcripts; legal memoranda; 23 correspondence; deposition and trial exhibits; expert reports; attorney work product; and 24 consultant and expert work product, even if such materials contain Protected Material. 25 Any such archival copies that contain or constitute Protected Material remain subject to 26 this Stipulated Protective Order as set forth in Section 5. 27 /// 28 /// 1 15. VIOLATION 2 Any violation of this Stipulated Order may be punished by any and all appropriate 3 measures including, without limitation, contempt proceedings and/or monetary 4 sanctions. 5 6 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 7 8 Dated:4/28/2025 /s/ Nabil Mihoubi 9 Plaintiff NABIL MIHOUBI 10 11 Dated:4/28/2025 /s/ Chaena B. Dade 12 PATRICK E. STOCKALPER 13 MOLSHREE GUPTA 14 CHAENA DADE 15 Attorneys for Defendants, 16 RIVERSIDE COUNTY CHILD 17 SERVICES DPSS, PETER BRICARELLO, 18 GUADALOUPE IBANEZ DE MOLLETI, 19 ANTHONY RADER 20 21 22 23 24 25 26 27 28 1 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 2 3 || Dated: 4/30/25 wet □□ 5 □ Maria A. Audero 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 16

AMENDED STIPULATED PROTECTIVE ORDER

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 I, _____________________________ [print or type full name], of 5 _________________ [print or type full address], declare under penalty of perjury that I 6 have read in its entirety and understand the Protective Order that was issued by the 7 United States District Court for the Central District of California on 8 _________________________ in the case of Mihoubi v. Riverside County Child 9 Services DPSS, et al., Case No. 5:24-cv-02472-AH (MAAx). 10 I agree to comply with and to be bound by all the terms of this Protective Order 11 and I understand and acknowledge that failure to so comply could expose me to 12 sanctions and punishment in the nature of contempt. I solemnly promise that I will not 13 disclose in any manner any information or item that is subject to this Protective Order to 14 any person or entity except in strict compliance with the provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District Court for 16 the Central District of California for the purpose of enforcing the terms of this Protective 17 Order, even if such enforcement proceedings occur after termination of this action. I 18 hereby appoint __________________________ [print or type full name] of 19 _______________________________________ [print or type full address and 20 telephone number] as my California agent for service of process in connection with this 21 action or any proceedings related to enforcement of this Protective Order. 22 Date: ______________________________________ 23 City and State where sworn and signed: _________________________________ 24 25 Printed name: _______________________________ 26 27 Signature: 28

CERTIFICATE OF SERVICE

1 2 I am employed in the County of Los Angeles, State of California; I am over the 3 age of eighteen years and not a party to the within action; my business address is 841 4 Apollo Street, Suite 100, El Segundo, California 90245.

5 On April 30, 2025, I served the foregoing document described as AMENDED 6 STIPULATED PROTECTIVE ORDER on all interested parties in this action by placing a true copy thereof in a sealed envelope addressed as follows: 7

8 SEE ATTACHED SERVICE LIST

9

10 XX By Mail I caused such envelope(s) to be deposited in the mail at El Segundo, 11 California. The envelope was mailed with postage thereon fully prepaid and addressed to the parties listed on the Service List. I am “readily familiar” with the 12 firm’s practice of collection and processing correspondence for mailing. It is 13 deposited with U.S. postal service on that same day in the ordinary course of business. I am aware that on motion of party served, service is presumed invalid 14 if postal cancellation date or postage meter date is more than 1 day after date of 15 deposit for mailing in affidavit.

16 XX By Email Based upon a court order or an agreement of the parties to accept 17 electronic service, I caused the documents to be sent to the persons at the 18 electronic service addresses listed in the Service List. My email address is mhoover@kmslegal.com. 19 20 XX State I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. 21

22 Executed on April 30, 2025, at El Segundo, California.

23 /s/ Magnus Hoover 24 Magnus Hoover 25 26 27 28

SERVICE LIST

1 540-14 2 Nabil Mihoubi v. Riverside County Child Services DPSS, et al. USDC Case No.: 5:24-cv-02472 3

4 Nabil Mihoubi Plaintiff In Pro Per 5 79140 Diane Drive La Quinta CA 92253 6 310/774-6711 7 nabilocean@hotmail.com

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