Estate of Jess Flores et al v. County of Riverside et al

Filing 29

PROTECTIVE ORDER by Magistrate Judge Shashi H. Kewalramani re Stipulation for Protective Order 28 . (SEE DOCUMENT FOR DETAILS) (hr)

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Denisse O. Gastélum, SBN 282771
Selene Estrada-Villela, SBN 354994
GASTÉLUM LAW, APC
A PROFESSIONAL CORPORATION
3767 Worsham Ave.
Long Beach, California 90808
Tel: [phone]
Fax: [phone]
Email: [e-mail]

Christian Contreras, SBN 330269

LAW OFFICES OF CHRISTIAN CONTRERAS
PROFESSIONAL LAW CORPORATION

360 E. 2nd St., 8th Floor
Los Angeles, California 90012
Tel: [phone]
Fax: [phone]
Email: [e-mail]

Attorneys for Plaintiffs,
ESTATE OF JESS FLORES, by and through successors in interest, M.F., R.F., and
S.F.; M.F., a minor, by and through Guardian Ad Litem, Justine Flores; R.F., a minor,
by and through Guardian Ad Litem, Justine Flores; S.F., a minor, by and through
Guardian Ad Litem, Lydia Arzola; JESS R. FLORES, JR., individually; and
DEBORAH ANN JACOBS, individually
UNITED STATES DISTRICT COURT
THE CENTRAL DISTRICT OF CALIFORNIA
ESTATE OF JESS FLORES, by and ) CASE NO. 5:24?cv?01933?KK?SHK
through successors in interest, M.F., ) [Assigned to the Hon. Kenly Kiya Kato,
R.F., and S.F.; M.F., a minor, by and ) District Judge; Referred to the Hon. Shashi
through Guardian Ad Litem, Justine ) H. Kewalramani, Magistrate Judge]
Flores; R.F., a minor, by and through )
Guardian Ad Litem, Justine Flores;
)
S.F., a minor, by and through Guardian )
Ad Litem, Lydia Arzola; JESS R.
) STIPULATED PROTECTIVE ORDER
FLORES, JR., individually; and
)
DEBORAH ANN JACOBS,
)
individually,
)
Plaintiffs,
)
)
v.
)
)
COUNTY OF RIVERSIDE, a public )
entity; RIVERSIDE COUNTY
)
SHERIFF’S DEPARTMENT;
)
SHERIFF CHAD BIANCO, in his
)
individual and official capacities;
)
EDWARD DELGADO; JAMES
)
KRACHMER; DAVID HOLM; DOES )
1 through 10, individually, jointly and )
severally,
)
)
Defendants.
)
)
)
)

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STIPULATED PROTECTIVE ORDER

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A. PURPOSES AND LIMITATIONS

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Discovery in this action is likely to involve production of confidential,

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proprietary, or private information for which special protection from public

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disclosure and from use for any purpose other than prosecuting this litigation may be

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warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter

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the following Stipulated Protective Order. The parties acknowledge that this Order
does not confer blanket protections on all disclosures or responses to discovery and
that the protection it affords from public disclosure and use extends only to the limited
information or items that are entitled to confidential treatment under the applicable
legal principles. The parties further acknowledge, as set forth in Section 12.3, below,
that this Stipulated Protective Order does not entitle them to a file confidential
information under seal; Civil Local Rule 79-5 sets forth the procedures that must be
followed and the standards that will be applied when a party seeks permission from
the court to file material under seal.
B. GOOD CAUSE STATEMENT

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Plaintiffs and the individual Defendants may produce certain documents in this

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case that contain personal medical, employment or financial information. Such

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information may implicate the privacy interests of the party and are properly

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protected through a Fed. R. Civ. P. 26(c) protective order. Seattle Times Co. v.

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Rhinehart, 467 U.S. 20, 35 n.21 (1984) (“Rule 26(c) includes among its express

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purposes the protection of a ‘party or person from annoyance, embarrassment,

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oppression or undue burden or expense.’ Although the Rule contains no specific

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reference to privacy or to other rights or interests that may be implicated, such matters

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are implicit in the broad purpose and language of the Rule.”); Soto v. City of Concord,

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162 F.R.D. 603, 617 (N.D. Cal. 1995) (a party’s privacy rights are to be protected
through a “carefully crafted protective order.”).
In light of the nature of the claims and allegations in this case and the parties’
representations that discovery in this case will involve the production of confidential
records, including but not limited to sensitive operational documents (including
investigative records) and/or confidential employment/personnel records
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STIPULATED PROTECTIVE ORDER

and

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information of individually named Defendants and/or other employees of the County,

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as well as Mr. Jess Flores’ medical and mental health information, pre-incident

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treatment records containing private and sensitive information pertaining to Mr.

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Flores, and private and sensitive documents referencing past criminal history as it

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relates to the claims and defenses in this action. The disclosure of the foregoing
information to non-parties or others would be harmful to the parties' interests,
including Plaintiffs. Therefore, this information must be protected. The parties shall
not designate any information/documents as confidential without a good faith belief
that such information/documents have been maintained in a confidential, non-public
manner, and that there is good cause or a compelling reason why it should not be part
of the public record of this case.
2.

DEFINITIONS
2.1

Action: This pending federal law suit, Estate of Jess Flores, et al. v.

County of Riverside, et al.; Case No. 5:24?cv?01933?KK?SHK.
2.2

Challenging Party: a Party or Non-Party that challenges the designation

of information or items under this Order.
2.3

“CONFIDENTIAL” Information or Items: information (regardless of

how it is generated, stored, or maintained) or tangible things that qualify for
protection under Federal Rule of Civil Procedure 26(c), and as specified above in the
Good Cause Statement.
2.4

Counsel: Outside Counsel of Record and House Counsel (as well as

their support staff).
2.5

Designating Party: a Party or Non-Party that designates information or

items that it produces in disclosures or in responses to discovery as
“CONFIDENTIAL.”
2.6

Disclosure or Discovery Material: all items or information, regardless

of the medium or manner in which it is generated, stored, or maintained (including,
among other things, testimony, transcripts, and tangible things), that are produced or
generated in disclosures or responses to discovery in this matter.
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STIPULATED PROTECTIVE ORDER

2.7

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Expert: a person with specialized knowledge or experience in a matter

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pertinent to the litigation who has been retained by a Party or its counsel to serve as

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an expert witness or as a consultant in this Action.
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House Counsel: attorneys who are employees of a party to this Action.

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House Counsel does not include Outside Counsel of Record or any other outside

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counsel.

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2.9

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Non-Party: any natural person, partnership, corporation, association, or

other legal entity not named as a Party to this action.

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2.10 Outside Counsel of Record: attorneys who are not employees of a party

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to this Action but are retained to represent or advise a party to this Action and have

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appeared in this Action on behalf of that party or are affiliated with a law firm which

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has appeared on behalf of that party, including support staff.

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2.11 Party: any party to this Action, including all of its officers, directors,

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employees, consultants, retained experts, and Outside Counsel of Record (and their

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support staffs).
2.12 Producing Party: a Party or Non-Party that produces Disclosure or

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Discovery Material in this Action.

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2.13 Professional Vendors: persons or entities that provide litigation support

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services (e.g., photocopying, videotaping, translating, preparing exhibits or

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demonstrations, and organizing, storing, or retrieving data in any form or medium)

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and their employees and subcontractors.

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2.14 Protected Material:

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any Disclosure or Discovery Material that is

designated as “CONFIDENTIAL.”
2.15 Receiving Party: a Party that receives Disclosure or Discovery Material

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from a Producing Party.

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3.

SCOPE

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The protections conferred by this Stipulation and Order cover not only

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Protected Material (as defined above), but also (1) any information copied or
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STIPULATED PROTECTIVE ORDER

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extracted from Protected Material; (2) all copies, excerpts, summaries, or

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compilations of Protected Material; and (3) any testimony, conversations, or

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presentations by Parties or their Counsel that might reveal Protected Material.

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Any use of Protected Material at trial shall be governed by the orders of the
trial judge. This Order does not govern the use of Protected Material at trial.
4.

DURATION
Once a case proceeds to trial, all of the information that was designated as

confidential or maintained pursuant to this protective order becomes public and will
be presumptively available to all members of the public, including the press, unless
compelling reasons supported by specific factual findings to proceed otherwise are
made to the trial judge in advance of the trial. See Kamakana v. City and County of
Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing “good cause”
showing for sealing documents produced in discovery from “compelling reasons”
standard when merits-related documents are part of court record). Accordingly, the
terms of this protective order do not extend beyond the commencement of the trial.
5.

DESIGNATING PROTECTED MATERIAL
5.1

Exercise of Restraint and Care in Designating Material for Protection.

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Each Party or Non-Party that designates information or items for protection under

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this Order must take care to limit any such designation to specific material that

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qualifies under the appropriate standards. The Designating Party must designate for

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protection only those parts of material, documents, items, or oral or written

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communications that qualify so that other portions of the material, documents, items,

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or communications for which protection is not warranted are not swept unjustifiably

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within the ambit of this Order.

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Mass, indiscriminate, or routinized designations are prohibited. Designations

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that are shown to be clearly unjustified or that have been made for an improper

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purpose (e.g., to unnecessarily encumber the case development process or to impose
unnecessary expenses and burdens on other parties) may expose the Designating
Party to sanctions.
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STIPULATED PROTECTIVE ORDER

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If it comes to a Designating Party’s attention that information or items that it

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designated for protection do not qualify for protection, that Designating Party must

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promptly notify all other Parties that it is withdrawing the inapplicable designation.

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5.2

Manner and Timing of Designations. Except as otherwise provided in

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this Order (see, e.g., second paragraph of Section 5.2(a) below), or as otherwise

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stipulated or ordered, Disclosure or Discovery Material that qualifies for protection

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under this Order must be clearly so designated before the material is disclosed or

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produced.

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Designation in conformity with this Order requires:
(a) for information in documentary form (e.g., paper or electronic
documents, but excluding transcripts of depositions or other pretrial or trial
proceedings), that the Producing Party affix at a minimum, the legend
“CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
contains protected material. If only a portion or portions of the material on a page
qualifies for protection, the Producing Party also must clearly identify the protected
portion(s) (e.g., by making appropriate markings in the margins).
A Party or Non-Party that makes original documents available for
inspection need not designate them for protection until after the inspecting Party has
indicated which documents it would like copied and produced. During the inspection

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and before the designation, all of the material made available for inspection shall be

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deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents

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it wants copied and produced, the Producing Party must determine which documents,

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or portions thereof, qualify for protection under this Order. Then, before producing

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the specified documents, the Producing Party must affix the “CONFIDENTIAL

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legend” to each page that contains Protected Material. If only a portion or portions of

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the material on a page qualifies for protection, the Producing Party also must clearly

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identify the protected portion(s) (e.g., by making appropriate markings in the

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margins). Markings added to documents pursuant to this paragraph shall not obscure

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the content or text of the documents produced.
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STIPULATED PROTECTIVE ORDER

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(b) for testimony given in depositions that the Designating Party identify

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the Disclosure or Discovery Material on the record, before the close of the deposition

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all protected testimony. The court reporter must affix to each such transcript page

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containing Protected Material the “CONFIDENTIAL legend”, as instructed by the

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Designating Party.
(c) for information produced in some form other than documentary and
for any other tangible items, that the Producing Party affix in a prominent place on
the exterior of the container or containers in which the information is stored the
legend “CONFIDENTIAL.” If only a portion or portions of the information warrants
protection, the Producing Party, to the extent practicable, shall identify the protected
portion(s).
5.3

Inadvertent Failures to Designate. If timely corrected, an inadvertent

failure to designate qualified information or items does not, standing alone, waive the
Designating Party’s right to secure protection under this Order for such material.
Upon timely correction of a designation, the Receiving Party must make reasonable
efforts to assure that the material is treated in accordance with the provisions of this
Order.
5.4 Privilege Log
If a party withholds information that is responsive to a discovery request by
claiming that it is privileged or otherwise protected from discovery, that party shall
promptly prepare and provide a privilege log that is sufficiently detailed and
informative for the opposing party to assess whether a document's designation as
privileged is justified. See Fed. R. Civ. P. 26(b)(5). The privilege log shall set forth
the privilege relied upon and specify separately for each document or for each category
of similarly situated documents:
(a)

the title and description of the document, including number of pages
or Bates- number range;

(b)

the subject matter addressed in the document;

(c)

the identity and position of its author(s);
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STIPULATED PROTECTIVE ORDER

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(d)

the identity and position of all addressees and recipients;

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(e)

the date the document was prepared and, if different, the date(s) on
which it was sent to or shared with persons other than its author(s); and

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(f)

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protected.

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Communications involving counsel that post-date the filing of the complaint

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the specific basis for the claim that the document is privileged and

need not be placed on a privilege log.
6.

CHALLENGING CONFIDENTIALITY DESIGNATIONS
6.1

Timing of Challenges.

Any Party or Non-Party may challenge a

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designation of confidentiality at any time that is consistent with the Court’s

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Scheduling Order.

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6.2

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Meet and Confer. The Challenging Party Shall initiate the dispute

resolution process under Civil Local Rule 37-1 et seq.
6.3 Failing to Meet and Confer
Failing informal resolution between parties, the Designating Party may file and

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serve a Motion for a Protective Order with the Court strictly pursuant to Local Rule

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37, including the Joint Stipulation Procedure. The parties agree that if the Motion for

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Protective Order is filed within 21 days of the written challenge (subject to extension

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upon agreement of the Parties), the Material will retain its original designation until

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the Court rules on the Motion for a Protective Order. If the Designating Party does

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not file a motion within the 21-day period following a challenge, the material is no

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longer designated as CONFIDENTIAL INFORMATION for purposes of this

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Stipulation, but that change in designation does not bar the Producing Party from

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subsequently filing a motion for a protective order.

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6.4 Burden of Persuasion

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The burden of persuasion in any such challenge proceeding shall be on the

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Designating Party. Frivolous challenges, and those made for an improper purpose

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(e.g., to harass or impose unnecessary expenses and burdens on other parties), may
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STIPULATED PROTECTIVE ORDER

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expose the Challenging Party to sanctions. Unless the Designating Party has waived

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or withdrawn the confidentiality designation, all parties shall continue to afford the

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material in question the level of protection to which it is entitled under the

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Producing Party’s designation until the Court rules on the challenge.

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6.5 Withdrawal of “CONFIDENTIAL” Designation.

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At its discretion, a Designating Party may remove Protected Material from some or

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all of the protections and provisions of this Stipulated Protective Order at any time by

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any of the following methods:

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(a)

Express Written Withdrawal. A Designating Party may withdraw a

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“CONFIDENTIAL” designation made to any specified Protected Material from some

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or all of the protections of this Stipulated Protective Order by an express withdrawal in

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writing signed by the Designating Party or Designating Party’s counsel (but not

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including staff of such counsel) that specifies and itemizes the Disclosure or Discovery

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Material previously designated as Protected Material that shall not longer be subject to

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some or all of the provisions of this Stipulated Protective Order. Such express

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withdrawal shall be effective when transmitted or served upon the Receiving Party. If

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a Designating Party is withdrawing Protected Material from only some of the

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provisions/protections of this Stipulated Protective Order, the Designating Party must

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state which specific provisions are no longer to be enforced as to the specified material

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for which confidentiality protection hereunder is withdrawn: otherwise, such

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withdrawal shall be construed as a withdrawal of such material from all of the

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protections/provisions of this Stipulated Protective Order;

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(b)

Express Withdrawal on the Record. A Designating Party may withdraw

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a “CONFIDENTIAL” designation made to any specified Protected Material from all

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of the provisions/protections of this Stipulated Protective Order by verbally consenting

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in court proceedings on the record to such withdrawal – provided that such withdrawal

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specifies the Disclosure or Discovery Material previously designated as Protected

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STIPULATED PROTECTIVE ORDER

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Material shall no longer be subject to any of the provisions of this Stipulation and

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Order;
(c)

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Implicit Withdrawal by Publication or Failure to Oppose Challenge. A

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Designating Party shall be construed to have withdrawn a “CONFIDENTIAL”

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designation made to any specified Protected Material from all of the

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provisions/protections of this Stipulated Protective Order by either (1) making such

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Protected Material part of the public record – including but not limited to attaching

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such as exhibits to any filing with the court without moving, prior to such filing, for

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the court to seal such records; or (2) failing to timely oppose a Challenging Party’s

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motion to remove a “CONFIDENTIAL” designation to specified Protected Material.

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7.

ACCESS TO AND USE OF PROTECTED MATERIAL
7.1

Basic Principles. A Receiving Party may use Protected Material that is

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disclosed or produced by another Party or by a Non-Party in connection with this

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Action only for prosecuting, defending, or attempting to settle this Action. Such

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Protected Material may be disclosed only to the categories of persons and under the

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conditions described in this Order.

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Receiving Party must comply with the provisions of Section 13 below (FINAL

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DISPOSITION).

When the Action has been terminated, a

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Protected Material must be stored and maintained by a Receiving Party at a

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location and in a secure manner that ensures that access is limited to the persons

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authorized under this Order.

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7.2

Disclosure of “CONFIDENTIAL” Information or Items.

Unless

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otherwise ordered by the Court or permitted in writing by the Designating Party, a

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Receiving

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“CONFIDENTIAL” only to:

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Party

may

disclose

any

information

or

item

designated

(a) the Receiving Party’s Outside Counsel of Record in this Action, as
well as employees of said Outside Counsel of Record to whom it is reasonably
necessary to disclose the information for this Action;
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STIPULATED PROTECTIVE ORDER

(b) the officers, directors, and employees (including House Counsel) of

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the Receiving Party to whom disclosure is reasonably necessary for this Action;

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(c) Experts (as defined in this Order) of the Receiving Party to whom

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disclosure is reasonably necessary for this Action and who have signed the

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“Acknowledgment and Agreement to Be Bound” (Exhibit A);
(d) the Court and its personnel;

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(e) court reporters and their staff;

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(f) professional jury or trial consultants, mock jurors, and Professional
Vendors to whom disclosure is reasonably necessary for this Action and who have
signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
(g) the author or recipient of a document containing the information or a
custodian or other person who otherwise possessed or knew the information;
(h) during their depositions, witnesses, and attorneys for witnesses, in the

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Action to whom disclosure is reasonably necessary provided: (1) the deposing party

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requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will

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not be permitted to keep any confidential information unless they sign the

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“Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise

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agreed by the Designating Party or ordered by the Court. Pages of transcribed

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deposition testimony or exhibits to depositions that reveal Protected Material may be

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separately bound by the court reporter and may not be disclosed to anyone except as

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permitted under this Stipulated Protective Order; and
(i) any mediator or settlement officer, and their supporting personnel,

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mutually agreed upon by any of the parties engaged in settlement discussions.

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8.

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PRODUCED IN OTHER LITIGATION

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PROTECTED

MATERIAL

SUBPOENAED

OR

ORDERED

If a Party is served with a subpoena or a court order issued in other litigation
that compels disclosure of any information or items designated in this Action as
“CONFIDENTIAL,” that Party must:
(a) promptly notify in writing the Designating Party. Such notification
shall include a copy of the subpoena or court order;
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STIPULATED PROTECTIVE ORDER

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(b) promptly notify in writing the party who caused the subpoena or order

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to issue in the other litigation that some or all of the material covered by the subpoena

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or order is subject to this Protective Order. Such notification shall include a copy of

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this Stipulated Protective Order; and

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(c) cooperate with respect to all reasonable procedures sought to be
pursued by the Designating Party whose Protected Material may be affected.
If the Designating Party timely seeks a protective order, the Party served with
the subpoena or court order shall not produce any information designated in this
action as “CONFIDENTIAL” before a determination by the court from which the
subpoena or order issued, unless the Party has obtained the Designating Party’s
permission. The Designating Party shall bear the burden and expense of seeking
protection in that court of its confidential material, and nothing in these provisions
should be construed as authorizing or encouraging a Receiving Party in this Action
to disobey a lawful directive from another court.

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9.

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PRODUCED IN THIS LITIGATION

A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

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(a) The terms of this Order are applicable to information produced by a

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Non-Party in this Action and designated as “CONFIDENTIAL.” Such information

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produced by Non-Parties in connection with this litigation is protected by the

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remedies and relief provided by this Order. Nothing in these provisions should be

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construed as prohibiting a Non-Party from seeking additional protections.

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(b) In the event that a Party is required, by a valid discovery request, to

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produce a Non-Party’s confidential information in its possession, and the Party is

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subject to an agreement with the Non-Party not to produce the Non-Party’s

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confidential information, then the Party shall:

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(1) promptly notify in writing the Requesting Party and the Non-Party
that some or all of the information requested is subject to a confidentiality agreement
with a Non-Party;

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STIPULATED PROTECTIVE ORDER

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(2) promptly provide the Non-Party with a copy of the Stipulated

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Protective Order in this Action, the relevant discovery request(s), and a reasonably

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specific description of the information requested; and

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(3) make the information requested available for inspection by the NonParty, if requested.
(c) If the Non-Party fails to seek a protective order from this Court within
14 days of receiving the notice and accompanying information, the Receiving Party
may produce the Non-Party’s confidential information responsive to the discovery
request. If the Non-Party timely seeks a protective order, the Receiving Party shall
not produce any information in its possession or control that is subject to the
confidentiality agreement with the Non-Party before a determination by the Court.
Absent a court order to the contrary, the Non-Party shall bear the burden and expense
of seeking protection in this Court of its Protected Material.

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///

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///

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10.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed

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Protected Material to any person or in any circumstance not authorized under this

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Stipulated Protective Order, the Receiving Party must immediately (a) notify in

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writing the Designating Party of the unauthorized disclosures, (b) use its best efforts

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to retrieve all unauthorized copies of the Protected Material, (c) inform the person or

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persons to whom unauthorized disclosures were made of all the terms of this Order,

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and (d) request such person or persons to execute the “Acknowledgment and

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Agreement to Be Bound” that is attached hereto as Exhibit A.

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11.

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INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
PROTECTED MATERIAL
When a Producing Party gives notice to Receiving Parties that certain

inadvertently produced material is subject to a claim of privilege or other protection,
the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
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STIPULATED PROTECTIVE ORDER

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Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure

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may be established in an e-discovery order that provides for production without prior

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privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the

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parties reach an agreement on the effect of disclosure of a communication or

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information covered by the attorney-client privilege or work product protection, the
parties may incorporate their agreement in the stipulated protective order submitted
to the Court.
12.

MISCELLANEOUS
12.1 Right to Relief. Nothing in this Order abridges the right of any person

to seek its modification by the Court in the future.
12.2 Right to Assert Other Objections. By stipulating to the entry of this
Protective Order, no Party waives any right it otherwise would have to object to
disclosing or producing any information or item on any ground not addressed in this
Stipulated Protective Order. Similarly, no Party waives any right to object on any
ground to use in evidence of any of the material covered by this Protective Order.
12.3 Filing Protected Material. A Party that seeks to file under seal any
Protected Material must comply with Civil Local Rule 79-5. Protected Material may
only be filed under seal pursuant to a court order authorizing the sealing of the specific
Protected Material at issue. If a Party’s request to file Protected Material under seal
is denied by the court, then the Receiving Party may file the information in the public
record unless otherwise instructed by the court.
13.

FINAL DISPOSITION
After the final disposition of this Action, as defined in paragraph 4, within 60

days of a written request by the Designating Party, each Receiving Party must return
all Protected Material to the Producing Party or destroy such material. As used in
this subdivision, “all Protected Material” includes all copies, abstracts, compilations,
summaries, and any other format reproducing or capturing any of the Protected
Material. Whether the Protected Material is returned or destroyed, the Receiving
Party must submit a written certification to the Producing Party (and, if not the same
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person or entity, to the Designating Party) by the 60 day deadline that (1) identifies

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(by category, where appropriate) all the Protected Material that was returned or

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destroyed; and (2) affirms that the Receiving Party has not retained any copies,

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abstracts, compilations, summaries, or any other format reproducing or capturing any

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of the Protected Material. Notwithstanding this provision, Counsel are entitled to
retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing
transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
reports, attorney work product, and consultant and expert work product, even if such
materials contain Protected Material. Any such archival copies that contain or
constitute Protected Material remain subject to this Protective Order as set forth in
Section 4 (DURATION).
14.

Any violation of this Order may be punished by any and all appropriate
measures including, without limitation, contempt proceedings and/or monetary
sanctions.

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
Dated: March 10, 2025

GASTÉLUM LAW, APC
By: /s/Denisse O. Gastélum
Denisse O. Gastélum, Esq.
Selene Estrada-Villela, Esq.
Attorneys for Plaintiffs,
ESTATE OF JESS FLORES, by and through
successors in interest, M.F., R.F., and S.F.; M.F., a
minor, by and through Guardian Ad Litem, Justine
Flores; R.F., a minor, by and through Guardian Ad
Litem, Justine Flores; S.F., a minor, by and through
Guardian Ad Litem, Lydia Arzola; JESS R.
FLORES, JR., individually; and DEBORAH ANN
JACOBS, individually

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Dated: March 10, 2025

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LAW OFFICES OF CHRISTIAN CONTRERAS
A Professional Law Corporation

By: /s/ Christian Contreras
Christian Contreras, Esq.
Attorneys for Plaintiffs,
ESTATE OF JESS FLORES, by and through
successors in interest, M.F., R.F., and S.F.; M.F., a
minor, by and through Guardian Ad Litem, Justine
Flores; R.F., a minor, by and through Guardian Ad
Litem, Justine Flores; S.F., a minor, by and through
Guardian Ad Litem, Lydia Arzola; JESS R.
FLORES, JR., individually; and DEBORAH ANN
JACOBS, individually

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Dated: March 10, 2025

KJAR, MCKENNA & STOCKALPER, LLP

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By: /s/ Chaena Dade
Patrick E. Stockalper
Molshree Gupta
Chaena Dade
Attorneys for Defendants,
COUNTY OF RIVERSIDE, RIVERSIDE COUNTY
SHERIFF’S DEPARTMENT,
SHERIFF CHAD BIANCO, EDWARD DELGADO,
JAMES KRACHMER,
DAVID HOLM

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FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
03/11/2025
DATED:________________________
____________________________________
Honorable Shashi H. Kewalramani
United States Magistrate Judge

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STIPULATED PROTECTIVE ORDER

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EXHIBIT A

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ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

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I, _____________________________

[print

or

type

full

name], of

_________________ [print or type full address], declare under penalty of perjury that
I have read in its entirety and understand the Stipulated Protective Order that was
issued by the United States District Court for the Central District of California on
[date] in the case of Estate of Jess Flores, et al. v. County of Riverside, et al.; Case
No. 5:24?cv?01933?KK?SHK. I agree to comply with and to be bound by all the
terms of this Stipulated Protective Order, and I understand and acknowledge that
failure to so comply could expose me to sanctions and punishment in the nature of
contempt. I solemnly promise that I will not disclose in any manner any information
or item that is subject to this Stipulated Protective Order to any person or entity except
in strict compliance with the provisions of this Order.

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I further agree to submit to the jurisdiction of the United States District Court

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for the Central District of California for the purpose of enforcing the terms of this

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Stipulated Protective Order, even if such enforcement proceedings occur after

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termination of this action. I hereby appoint __________________________ [print or

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type full name] of _______________________________________ [print or type full

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address and telephone number] as my California agent for service of process in

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connection with this action or any proceedings related to enforcement of this

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Stipulated Protective Order.

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Date: ______________________________________

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City and State where sworn and signed: _________________________________
Printed name: _______________________________
Signature: __________________________________

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STIPULATED PROTECTIVE ORDER