1 ROBERT R. POWELL, SBN: 159747 2 POWELL & ASSOCIATES 925 West Hedding Street 3 San Jose, California 95126 4 T: 408-553-0200 F: 408-553-0201 E: admin@rrpassociates.com 5 Attorney for Plaintiffs 6 7 8 9 UNITED STATES DISTRICT COURT 10 CENTRAL DISTRICT OF CALIFORNIA 11 12 JESSICA RAMOS, individually and as Case No.: 5:24-cv-01971-JGB-DTB Guardian ad Litem for A.R., a minor, and N.R., a minor, 13

14 Plaintiffs, STIPULATED PROTECTIVE v. ORDER 15

COUNTY OF SAN BERNARDINO,

16 EIMMY KAFKA, SHARON

GONZALEZ, RICHARD MEZA,

17 DOES1-5,

18 Defendants. 19 20 1. A. PURPOSES AND LIMITATIONS 21 Discovery in this action is likely to involve production of confidential, 22 proprietary, or private information for which special protection from public disclosure 23 and from use for any purpose other than prosecuting this litigation may be warranted. 24 Accordingly, the parties hereby stipulate to and petition the Court to enter the 25 following Stipulated Protective Order. The parties acknowledge that this Order does 26 not confer blanket protections on all disclosures or responses to discovery and that the 27 protection it affords from public disclosure and use extends only to the limited 28 1 1 information or items that are entitled to confidential treatment under the applicable 2 legal principles. The parties further acknowledge, as set forth in Section 12.3, below, 3 that this Stipulated Protective Order does not entitle them to file confidential 4 information under seal; Civil Local Rule 79-5 sets forth the procedures that must be 5 followed and the standards that will be applied when a party seeks permission from the 6 court to file material under seal. 7

B. GOOD CAUSE STATEMENT

8 This action is likely to involve juvenile dependency case file records (CRC 9 5.552 – defining “juvenile case file”), and communications of parties related to the 10 events and circumstances described in the Complaint on file in this action, as well 11 as an unknown number of documents / writings / evidence in possession of law 12 enforcement agencies, which are or may be otherwise generally unavailable to the 13 public, or which may be privileged or otherwise protected from disclosure under 14 state or federal statutes, court rules, case decisions, or common law. 15 Accordingly, to expedite the flow of information, to facilitate the prompt 16 resolution of disputes over confidentiality of discovery materials, to adequately 17 protect information the parties are entitled to keep confidential, to ensure that the 18 parties are permitted reasonable necessary uses of such material in preparation for 19 and in the conduct of trial, to address their handling at the end of the litigation, and 20 to serve the ends of justice, a protective order for such information is justified in 21 this matter. 22 It is the intent of the parties that information will not be designated as 23 confidential for tactical reasons and that nothing be so designated without a good 24 faith belief that it has been maintained in a confidential, non-public manner, and there 25 is good cause why it should not be part of the public record of this case. 26 // 27 28 2 1 2. DEFINITIONS 2 2.1 Action: Refers to this litigation / lawsuit. 3 2.2 “ATTORNEYS’ EYES ONLY” Information or Items: Information 4 (regardless of how it is generated, stored or maintained) or tangible things that qualify 5 for a higher protection under Federal Rule of Civil Procedure 26(c), and as specified 6 above in the Good Cause Statement. The designation of “ATTORNEYS’ EYES 7 ONLY” shall be limited to sensitive personal information, that if improperly disclosed 8 to another party in this litigation, could cause potential harm the Producing Party. 9 Because the designation of information as “ATTORNEYS’ EYES ONLY” is more 10 restrictive on disclosure and may interfere with the discovery process, designations 11 should be used infrequently and minimally. The “ATTORNEYS’ EYES ONLY” 12 designation shall be limited to the following information: private financial information 13 of the individual parties. Nothing in this definition, nor any provision of this Stipulated 14 Protective Order, is intended to constitute a waiver of any party’s right to challenge an 15 “ATTORNEY EYES ONLY” designation in the future and seek an Order of the Court 16 presiding over this action to have such designation removed. 17 Further, these provisions, like all others herein, are subject to the terms of 18 paragraph “4. DURATION.” 19 2.3 Challenging Party: A Party or Non-Party that challenges the designation of 20 information or items under this Order. 21 2.4 “CONFIDENTIAL” Information or Items: Information (regardless of how 22 it is generated, stored or maintained) or tangible things that qualify for protection 23 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 24 Statement. 25 2.5 Counsel: Outside Counsel of Record and House Counsel (as well as their 26 support staff). 27 2.6 Designating Party: A Party or Non-Party that designates information or items 28 3 1 that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 2 2.7 Disclosure or Discovery Material: All items or information, regardless of the 3 medium or manner in which it is generated, stored, or maintained (including, among 4 other things, testimony, transcripts, and tangible things), that are produced or generated 5 in disclosures or responses to discovery in this matter. 6 2.8 Expert: A person with specialized knowledge or experience in a matter 7 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 8 expert witness or as a consultant in this Action. 9 2.9 House Counsel: Attorneys who are employees of a party to this Action. House 10 Counsel does not include Outside Counsel of Record or any other outside counsel. 11 2.10 Non-Party: Any natural person, partnership, corporation, association, or 12 other legal entity not named as a Party to this action. 13 2.11 Outside Counsel of Record: Attorneys who are not employees of a party to 14 this Action but are retained to represent or advise a party to this Action and have 15 appeared in this Action on behalf of that party or are affiliated with a law firm which 16 has appeared on behalf of that party, and includes support staff. 17 2.12 Party: Any party to this Action, including all of its officers, directors, 18 employees, consultants, retained experts, and Outside Counsel of Record (and their 19 support staffs). 20 2.13 Producing Party: A Party or Non-Party that produces Disclosure or 21 Discovery Material in this Action. 22 2.14 Professional Vendors: Persons or entities that provide litigation support 23 services (e.g., photocopying, videotaping, translating, preparing exhibits or 24 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 25 their employees and subcontractors. 26 2.15 Protected Material: Any Disclosure or Discovery Material that is designated 27 as “CONFIDENTIAL” or “ATTORNEYS EYES ONLY.” 28 4 1 2.16 Receiving Party: A Party that receives Disclosure or Discovery Material 2 from a Producing Party. 3 3. SCOPE 4 The protections conferred by this Stipulation and Order cover not only Protected 5 Material (as defined above), but also (1) any information copied or extracted from 6 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 7 Material; and (3) any testimony, conversations, or presentations by Parties or their 8 Counsel that might reveal Protected Material. 9 Any use of Protected Material at trial shall be governed by the orders of the trial 10 judge. This Order does not govern the use of Protected Material at trial. 11 12 4. DURATION 13 Once a case proceeds to trial, all of the information that was designated as 14 confidential or maintained pursuant to this protective order becomes public and will be 15 presumptively available to all members of the public, including the press, unless 16 compelling reasons supported by specific factual findings to proceed otherwise are 17 made to the trial judge in advance of the trial. See Kamakana v. City and County of 18 Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing “good cause” 19 showing for sealing documents produced in discovery from “compelling reasons” 20 standard when merits-related documents are part of court record). Accordingly, the 21 terms of this protective order do not extend beyond the commencement of the trial. 22 5. DESIGNATING PROTECTED MATERIAL 23 5.1 Exercise of Restraint and Care in Designating Material for Protection. 24 Each Party or Non-Party that designates information or items for protection under 25 this Order must take care to limit any such designation to specific material that 26 qualifies under the appropriate standards. The Designating Party must designate for 27 28 5 1 protection only those parts of material, documents, items, or oral or written 2 communications that qualify so that other portions of the material, documents, items, 3 or communications for which protection is not warranted are not swept unjustifiably 4 within the ambit of this Order. The Party or Non-Party which designates information 5 or items under protection must specifically state which designation is being asserted, 6 “CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY.” 7 Mass, indiscriminate, or routinized designations are prohibited. Designations that 8 are shown to be clearly unjustified or that have been made for an improper purpose 9 (e.g., to unnecessarily encumber the case development process or to impose 10 unnecessary expenses and burdens on other parties) may expose the Designating Party 11 to sanctions. 12 If it comes to a Designating Party’s attention that information or items that it 13 designated for protection do not qualify for protection, that Designating Party must 14 promptly notify all other Parties that it is withdrawing the inapplicable designation. 15 5.2 Manner and Timing of Designations. Except as otherwise provided in this 16 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated 17 or ordered, Disclosure or Discovery Material that qualifies for protection under this 18 Order must be clearly so designated before the material is disclosed or produced. 19 Designation in conformity with this Order requires the following: 20 (a) For information in documentary form (e.g., paper or electronic documents, 21 but excluding transcripts of depositions or other pretrial or trial proceedings), that the 22 Producing Party affix at a minimum, the legend “CONFIDENTIAL” or 23 “ATTORNEYS’ EYES ONLY,” as coincides with the designation, (hereinafter 24 “LEGEND”), to each page that contains protected material. If only a portion or 25 portions of the material on a page qualifies for protection, the Producing Party also 26 must clearly identify the protected portion(s) (e.g., by making appropriate markings in 27 the margins). 28 6 1 A Party or Non-Party that makes original documents available for inspection 2 need not designate them for protection until after the inspecting Party has indicated 3 which documents it would like copied and produced. During the inspection and before 4 the designation, all of the material made available for inspection shall be deemed 5 “CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY,” as applies. After the 6 inspecting Party has identified the documents it wants copied and produced, the 7 Producing Party must determine which documents, or portions thereof, qualify for 8 protection under this Order. Then, before producing the specified documents, the 9 Producing Party must affix the “LEGEND” to each page that contains Protected 10 Material. If only a portion or portions of the material on a page qualifies for protection, 11 the Producing Party also must clearly identify the protected portion(s) (e.g., by making 12 appropriate markings in the margins). 13 (b) For testimony given in depositions that the Designating Party identifies 14 Disclosure or Discovery Material which Designating Party deems “CONFIDENTIAL” 15 or “ATTORNEYS’ EYES ONLY” on the record, before the close of the deposition all 16 protected testimony. 17 (c) For information produced in some form other than documentary and for any 18 other tangible items, that the Producing Party affix in a prominent place on the exterior 19 of the container or containers in which the information is stored the “LEGEND” 20 “CONFIDENTIAL” OR “ATTORNEYS’ EYES ONLY.” If only a portion or portions 21 of the information warrants protection, the Producing Party, to the extent practicable, 22 shall identify the protected portion(s). 23 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure 24 to designate qualified information or items does not, standing alone, waive the 25 Designating Party’s right to secure protection under this Order for such material. Upon 26 timely correction of a designation, the Receiving Party must make reasonable efforts to 27 assure that the material is treated in accordance with the provisions of this Order. 28 7 1 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 2 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation 3 of confidentiality at any time that is consistent with the Court’s Scheduling Order. 4 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution 5 process under Local Rule 37.1 et seq. 6 6.3 The burden of persuasion in any such challenge proceeding shall be on the 7 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., 8 to harass or impose unnecessary expenses and burdens on other parties) may expose 9 the Challenging Party to sanctions. If a Party of Non-Party prevails on a challenge, that 10 party shall be awarded reasonable attorney fees, and in the discretion of the Court, 11 monetary and/or evidence sanctions as well. Unless the Designating Party has waived 12 or withdrawn the confidentiality designation, all parties shall continue to afford the 13 material in question the level of protection to which it is entitled under the Producing 14 Party’s designation until the Court rules 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 17 disclosed or produced by another Party or by a Non-Party in connection with this 18 Action only for prosecuting, defending, or attempting to settle this Action. Such 19 Protected Material may be disclosed only to the categories of persons and under the 20 conditions described in this Order. When the Action has been terminated, a Receiving 21 Party must comply with the provisions of section 13 below (FINAL DISPOSITION). 22 Protected Material must be stored and maintained by a Receiving Party at a location 23 and in a secure manner that ensures that access is limited to the person’s authorized 24 under this Order. 25 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise 26 ordered by the court or permitted in writing by the Designating Party, a Receiving 27 28 8 1 Party may disclose any information or item designated “CONFIDENTIAL” only to: 2 (a) The Receiving Party’s Outside Counsel of Record in this Action, as well as 3 employees of said Outside Counsel of Record to whom it is reasonably necessary to 4 disclose the information for this Action; 5 (b) the officers, directors, and employees (including House Counsel) of the 6 Receiving Party to whom disclosure is reasonably necessary for this Action; 7 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure 8 is reasonably necessary for this Action and who have signed the “Acknowledgment 9 and Agreement to Be Bound” (Exhibit A); 10 (d) the court and its personnel; 11 (e) court reporters and their staff; 12 (f) professional jury or trial consultants, mock jurors, and Professional 13 Vendors to whom disclosure is reasonably necessary for this Action and who have 14 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 15 (g) the author or recipient of a document containing the information or a 16 custodian or other person who otherwise possessed or knew the information; 17 (h) during their depositions, witnesses, and attorneys for witnesses, in the Action 18 to whom disclosure is reasonably necessary provided: (1) The deposing party requests 19 that the witness sign the form attached as Exhibit 1 hereto; and (2) they will not be 20 permitted to keep any confidential information unless they sign the “Acknowledgment 21 and Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating 22 Party or ordered by the court. Pages of transcribed deposition testimony or exhibits to 23 depositions that reveal Protected Material may be separately bound by the court 24 reporter and may not be disclosed to anyone except as permitted under this Stipulated 25 Protective Order; and 26 (i) any mediator or settlement officer, and their supporting personnel, mutually 27 agreed upon by any of the parties engaged in settlement discussions. 28 9 1 7.3. Disclosure of “ATTORNEYS’ EYES ONLY” Information. 2 Unless otherwise ordered by the court or permitted in writing by the Designating 3 Party, the attorney of record for the Receiving Party may not disclose any information 4 or item designated “ATTORNEYS’ EYES ONLY” to anyone. 5 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 6

IN OTHER LITIGATION

7 If a Party is served with a subpoena or a court order issued in other litigation that 8 compels disclosure of any information or items designated in this Action as 9 “CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY” that Party must: 10 (a) Promptly notify in writing the Designating Party. Such notification shall 11 include a copy of the subpoena or court order; 12 (b) promptly notify in writing the party who caused the subpoena or order to 13 issue in the other litigation that some or all of the material covered by the subpoena or 14 order is subject to this Protective Order. Such notification shall include a copy of this 15 Stipulated Protective Order; and 16 (c) cooperate with respect to all reasonable procedures sought to be pursued by 17 the Designating Party whose Protected Material may be affected. If the Designating 18 Party timely seeks a protective order, the Party served with the subpoena or court order 19 shall not produce any information designated in this action as “CONFIDENTIAL” or 20 “ATTORNEYS’ EYES ONLY” before a determination by the court from which the 21 subpoena or order issued, unless the Party has obtained the Designating Party’s 22 permission. The Designating Party shall bear the burden and expense of seeking 23 protection in that court of its confidential material and nothing in these provisions 24 should be construed as authorizing or encouraging a Receiving Party in this Action to 25 disobey a lawful directive from another court. 26 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 27 28 10 1 PRODUCED IN THIS LITIGATION 2 (a) The terms of this Order are applicable to information produced by a Non- 3 Party in this Action and designated as “CONFIDENTIAL” or “ATTORNEYS’ EYES 4 ONLY.” Such information produced by Non-Parties in connection with this litigation 5 is protected by the remedies and relief provided by this Order. Nothing in these 6 provisions should be construed as prohibiting a Non-Party from seeking additional 7 protections. Nothing in these provisions limit any other party from challenging such 8 designations, and if prevailing on a challenge, the Court shall award reasonable 9 attorney fees. 10 (b) In the event that a Party is required, by a valid discovery request, to produce 11 a Non-Party’s confidential information in its possession, and the Party is subject to an 12 agreement with the Non-Party not to produce the Non-Party’s confidential information, 13 then the Party shall: 14 (1) Promptly notify in writing the Requesting Party and the Non-Party 15 that some or all of the information requested is subject to a confidentiality agreement 16 with a Non-Party; 17 (2) promptly provide the Non-Party with a copy of the Stipulated 18 Protective Order in this Action, the relevant discovery request(s), and a reasonably 19 specific description of the information requested; and 20 (3) make the information requested available for inspection by the Non- 21 Party, if requested. 22 (c) If the Non-Party fails to seek a protective order from this court within 14 23 days of receiving the notice and accompanying information, the Receiving Party may 24 produce the Non-Party’s confidential information responsive to the discovery request. 25 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce 26 any information in its possession or control that is subject to the confidentiality 27 agreement with the Non-Party before a determination by the court. Absent a court 28 11 1 order to the contrary, the Non-Party shall bear the burden and expense of seeking 2 protection in this court of its Protected Material. 3 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 4 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 5 Protected Material to any person or in any circumstance not authorized under this 6 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 7 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 8 all unauthorized copies of the Protected Material, (c) inform the person or persons to 9 whom unauthorized disclosures were made of all the terms of this Order, and (d) 10 request such person or persons to execute the “Acknowledgment and Agreement to Be 11 Bound” that is attached hereto as Exhibit A. 12 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 13

PROTECTED MATERIAL

14 When a Producing Party gives notice to Receiving Parties that certain inadvertently 15 produced material is subject to a claim of privilege or other protection, the obligations 16 of the Receiving Parties are those set forth in Federal Rule of Civil Procedure 17 26(b)(5)(B). This provision is not intended to modify whatever procedure may be 18 established in an e-discovery order that provides for production without prior privilege 19 review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the parties 20 reach an agreement on the effect of disclosure of a communication or information 21 covered by the attorney-client privilege or work product protection, the parties may 22 incorporate their agreement in the stipulated protective order submitted to the court. 23 24 12. MISCELLANEOUS 25 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 26 person to seek its modification by the Court in the future. 27 12.2 Right to Assert Other Objections. By stipulating to the entry of this 28 12 1 Protective Order no Party waives any right it otherwise would have to object to 2 disclosing or producing any information or item on any ground not addressed in this 3 Stipulated Protective Order. Similarly, no Party waives any right to object on any 4 ground to use in evidence of any of the material covered by this Protective Order. 5 12.3 Filing Protected Material. A Party that seeks to file under seal any Protected 6 Material must comply with Civil Local Rule 79-5. Protected Material may only be 7 filed under seal pursuant to a court order authorizing the sealing of the specific 8 Protected Material at issue. If a Party's request to file Protected Material under seal is 9 denied by the court, then the Receiving Party may file the information in the public 10 record unless otherwise instructed by the court. 11 13. FINAL DISPOSITION 12 After the final disposition of this Action, as defined in paragraph 4, within 60 days 13 of a written request by the Designating Party, each Receiving Party must return all 14 Protected Material to the Producing Party or destroy such material. As used in this 15 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 16 summaries, and any other format reproducing or capturing any of the Protected 17 Material. Whether the Protected Material is returned or destroyed, the Receiving Party 18 must submit a written certification to the Producing Party (and, if not the same person 19 or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by 20 category, where appropriate) all the Protected Material that was returned or destroyed 21 and (2) affirms that the Receiving Party has not retained any copies, abstracts, 22 compilations, summaries or any other format reproducing or capturing any of the 23 Protected Material. Notwithstanding this provision, Counsel are entitled to retain an 24 archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, 25 legal memoranda, correspondence, deposition and trial exhibits, expert reports, 26 attorney work product, and consultant and expert work product, even if such materials 27 contain Protected Material. Any such archival copies that contain or constitute 28 13 1 || Protected Material remain subject to this Protective Order as set forth in Section 4 (DURATION). 3 14, Any violation of this Order may be punished by any and all appropriate measures 4 including, without limitation, contempt proceedings and/or monetary sanctions. 5 15. Nothing in this Stipulated Protective Order is intended as a waiver of any party’s 6 right to request public use of any documents or other materials produced which are 7 covered within the terms of this Order by designation or otherwise. 8 9|| ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD. 10 11 || Date: 1/7/2026 /S/ Julian V. Lee DOUGLAS C. SMITH Attorneys for Defendants 13 Date: 1/7/2026 /S/ Robert R. Powell 15 ROBERT R. POWELL Attorney for Plaintiffs 16 17|| FOR GOOD CAUSE SHOWN, IT IS SO “7 Date: 01/07/2026 aif /- 19 JUDGE OF THE CENTRAL

DISTRICT COURT - CALIFORNIA

20 21 22 23 24 25 26 27 28 14 Stipulated Protective Order RPamne ptal w Cnimnty nt San Rornnadinn otal

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 penalty of perjury that I 5 have read in its entirety and understand the Stipulated Protective Order that was issued 6 by the United States District Court for the Central District of California on [date] in the 7 case of ___________ [insert formal name of the case and the number and initials 8 assigned to it by the court]. I agree to comply with and to be bound by all the terms of 9 this Stipulated Protective Order and I understand and acknowledge that failure to so 10 comply could expose me to sanctions and punishment in the nature of contempt. I 11 solemnly promise that I will not disclose in any manner any information or item that is 12 subject to this Stipulated Protective Order to any person or entity except in strict 13 compliance with the provisions of this Order. 14 I further agree to submit to the jurisdiction of the United States District Court for 15 the Central District of California for the purpose of enforcing the terms of this 16 Stipulated Protective Order, even if such enforcement proceedings occur after 17 termination of this action. I hereby appoint __________________________ [print or 18 type full name] of _______________________________________ [print or type full 19 address and telephone number] as my California agent for service of process in 20 connection with this action or any proceedings related to enforcement of this 21 Stipulated Protective Order. 22 Date: ______________________________________ 23 City and State where sworn and signed: _________________________________ 24 Printed name: _______________________________ 25 Signature: __________________________________ 26 27 28 15