# Cityscape Rentals, LLC v. Travelers Casualty Insurance Company of America

> District Court, C.D. California · December 23, 2019

URL: https://www.frixlaw.com/law-library/cases/10036496

## Case

- **Court:** District Court, C.D. California
- **Decided:** December 23, 2019
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

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## Opinion text

NE SLI II IPR IDOE EI ELEM AD EGS AME RM TAGE NTE □□□
3
5
7 UNITED STATES DISTRICT COURT □
8 CENTRAL DISTRICT OF CALIFORNIA
° CITYSCAPE RENTALS, LLC, a Case No. 2:19-cv-01886-DSF-E
10 || California limited liability company, Assigned to Hon. Dale S. Fischer
11 Plaintiffs, STIPULATED PROTECTIVE
vs. ORDER
13 || TRAVELERS CASUALTY
14 AMERICA: YOUNG & OF Complaint Filed: February 6, 2019
15 ASSOCIATES: PARRY through 30, Action Removed: March 14, 2019
16 inclusive, Defendants, Trial Date: None Set
17
18
19
20

22
23 || 1. A. PURPOSES AND LIMITATIONS
24 Discovery in this action is likely to involve production of confidential,
25 || proprietary or private information for which special protection from public
26 || disclosure and from use for any purpose other than prosecuting this litigation may
27 || be warranted. Accordingly, the parties hereby stipulate to and petition the Court to
28 || enter the following Stipulated Protective Order. The parties acknowledge that this

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1 || Order does not confer blanket protections on all disclosures or responses to
2 || discovery and that the protection it affords from public disclosure and use extends
3 || only to the limited information or items that are entitled to confidential treatment
4 || under the applicable legal principles.
5 B. GOOD CAUSE STATEMENT
6 This action is likely to involve commercial, financial, technical and/or __

7 || proprietary information for which special protection from public disclosure and
8 || from use for any purpose other than prosecution of this action is warranted. Such
9 || confidential and proprietary materials and information consist of, among other
10 || things, confidential business or financial information, information regarding
11 || confidential business practices, or other confidential commercial information
12 || (including information implicating privacy rights of third parties), information
13 || otherwise generally unavailable to the public, or which may be privileged or
14 || otherwise protected from disclosure under state or federal statutes, court rules, case
15 || decisions, or common law.. Accordingly, to expedite the flow of information, to
16 || facilitate the prompt resolution of disputes over confidentiality of discovery
17 || materials, to adequately protect information the parties are entitled to keep
18 || confidential, to ensure that the parties are permitted reasonable necessary uses of
19 || such material in preparation for and in the conduct of trial, to address their handling
20 || at the end of the litigation, and serve the ends of justice, a protective order for such
21 || information is justified in this matter. It is the intent of the parties that information
22 || will not be designated as confidential for tactical reasons and that nothing be so
23 || designated without a good faith belief that it has been maintained in a confidential,
24 || non-public manner, and there is good cause why it should not be part of the public
25 || record of this case. .
26 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL
27 The parties further acknowledge, as set forth in Section 12.3, below, that this
28 || Stipulated Protective Order does not entitle them to file confidential information

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1 || under seal; Local Civil Rule 79-5 seis forth the procedures that must be followed
2 | and the standards that will be applied when a party seeks permission from the court
3 |! to file material under seal.
4 There is a strong presumption that the public has a right of access to judicial
5 || proceedings and records in civil cases. In connection with non-dispositive motions,
6 || good cause must be shown to support a filing under seal. See Kamakana vy. City and
7 || County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors
8 || Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics,
9 || Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders
10 || require good cause showing), and a specific showing of good cause or compelling
11 || reasons with proper evidentiary support and legal justification, must be made with
12 || respect to Protected Material that a party seeks to file under seal. The parties’ mere
13 || designation of Disclosure or Discovery Material as CONFIDENTIAL does not—
14 || without the submission of competent evidence by declaration, establishing that the
15 |} material sought to be filed under seal qualifies as confidential, privileged, or
16 |} otherwise protectable—constitute good cause.
17 Further, if a party requests sealing related to a dispositive motion or trial, then
18 || compelling reasons, not only good cause, for the sealing must be shown, and the
19 |! relief sought shall be narrowly tailored to serve the specific interest to be protected.
20 || See Pintos v, Pacific Creditors Ass'n, 605 F.3d 665, 677-79 (9th Cir. 2010). For
21 || each item or type of information, document, or thing sought to be filed or introduced
22 || under seal in connection with a dispositive motion or trial, the party seeking
23 || protection must articulate compelling reasons, supported by specific facts and legal
24 || justification, for the requested sealing order. Again, competent evidence supporting
25 || the application to file documents under seal must be provided by declaration.
26 Any document that is not confidential, privileged, or otherwise protectable in
27 |j its entirety will not be filed under seal if the confidential portions can be redacted.
|) Ifdocuments can be redacted, then a redacted version for public viewing, omitting

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1 || only the confidential, privileged, or otherwise protectable portions of the document,
2 || shall be filed. Any application that seeks to file documents under seal in their
3 || entirety should include an explanation of why redaction is not feasible.
4 ||2. DEFINITIONS
5 2.1 Action: Cityscape Rentals, LLC v. Travelers Casualty Insurance
6 || Company of America, et al., United States District Court for the Central District of
7 || California, Case No. 2:19-cv-01886-DSE-E. .
8 2.2 Challenging Party: a Party that challenges the designation of
9 || information or items under this Order.
10 2.3 “CONFIDENTIAL” Information or Items: information (regardless of
11 || how it is generated, stored or maintained) or tangible things that qualify for
12 || protection under Federal Rule of Civil Procedure 26(c), and as specified above in
13 || the Good Cause Statement.
14 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as
15 || their support staff).
16 2.5 Designating Party: a Party or Non-Party that designates information or
17 || items that it produces in disclosures or in responses to discovery as
18 || “CONFIDENTIAL.”
19 2.6 Disclosure or Discovery Material: all items or information, regardless
20 || of the medium or manner in which it is generated, stored, or maintained (including,
21 || among other things, testimony, transcripts, and tangible things), that are produced or
22 || generated in disclosures or responses to discovery in this matter.
23 2.7 Expert: a person with specialized knowledge or experience in a matter
24 || pertinent to the litigation who has been retained by a Party or its counsel to serve as
25 || an expert witness or as a consultant in this Action.
26 2.8 House Counsel: attorneys who are employees of a party to this Action.
27 || House Counsel does not include Outside Counsel of Record or any other outside
28 |; counsel.

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1 2.9 Non-Party: any natural person, partnership, corporation, association or _
2 || other legal entity not named as a Party to this action.
3 2.10 Outside Counsel of Record: attorneys who are not employees of a
4 || party to this Action but are retained to represent or advise a party to this Action and
5 || have appeared in this Action on behalf of that party or are affiliated with a law firm
6 || that has appeared on behalf of that party, and includes support staff.
7 2.11 Party: any party to this Action, including all of its officers, directors,
8 employees, consultants, retained experts, and Outside Counsel of Record (and their
9 || support staffs). —
10 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
11 || Discovery Material in this Action.
12 2.13 Professional Vendors: persons or entities that provide litigation
13 || support services (e.g., photocopying, videotaping, translating, preparing exhibits or
14 || demonstrations, and organizing, storing, or retrieving data in any form or medium)
15 || and their employees and subcontractors.
16 2.14 Protected Material: any Disclosure or Discovery Material that is
17 || designated as “CONFIDENTIAL.” □

18 2.15 Receiving Party: a Party that receives Disclosure or Discovery
19 || Material from a Producing Party. .
20 13. SCOPE
21 The protections conferred by this Stipulation and Order cover not only
22 || Protected Material (as defined above), but also (1) any information copied or
23 || extracted from Protected Material; (2) all copies, excerpts, summaries, or
24 compilations of Protected Material; and (3) any testimony, conversations, or
25 || presentations by Parties or their Counsel that might reveal Protected Material.
26 Any use of Protected Material at trial shall be governed by the orders of the
27 || trial judge. This Order does not govern the use of Protected Material at trial.
28 | /// .
a

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1||4. DURATION =

2 Once a case proceeds to trial, information that was designated as
3. || CONFIDENTIAL or maintained pursuant to this protective order used or introduced
4 || as an exhibit at trial becomes public and will be presumptively available to all

5 |] members of the public, including the press, unless compelling reasons supported by
6 || specific factual findings to proceed otherwise are made to the trial judge in advance
7 ll of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “(good cause”
8 || showing for sealing documents produced in discovery from “compelling reasons”
9 || standard when merits-related documents are part of court record). Accordingly, the
10 || terms of this protective order do not extend beyond the commencement of the trial.
11 || 5. DESIGNATING PROTECTED MATERIAL
12 5.1 Exercise of Restraint and Care in Designating Protected Material,
13 Each Party or Non-Party that designates information or items for protection
14 |] under this Order must take care to limit any such designation to specific material
15 || that qualifies under the appropriate standards. The Designating Party must
16 || designate for protection only those parts of material, documents, items or oral or
17 {| written communications that qualify so that other portions of the material,
18 || documents, items or communications for which protection is not warranted are not
19 || swept unjustifiably within the ambit of this Order.
20 If it comes to a Designating Party’s attention that information or items that it
21 || designated for protection do not qualify for protection, that Designating Party must
22 || promptly notify all other Parties that it is withdrawing the inapplicable designation.
23 5.2. Manner and Timing of Designations. Except as otherwise provided in
24 || this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
25 || stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
26 || under this Order must be clearly so designated before the material is disclosed or
27 || produced. —
28 Designation in conformity with this Order requires:

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1 (a) for information in documentary form (e.g., paper or electronic
2 || documents, but excluding transcripts of depositions or other pretrial or trial
3 || proceedings), that the Producing Party affix at a minimum, the legend
4 || “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
5 || contains protected material. If only a portion of the material on a page qualifies for
6 || protection, the Producing Party also must clearly identify the protected portion(s)
7 || (e.g., by making appropriate markings in the margins).
8 A Party or Non-Party that makes original documents available for inspection
9 || need not designate them for protection until after the inspecting Party has indicated
|| which documents it would like copied and produced, During the inspection and
11 || before the designation, all of the material made available for inspection shall be
12 || deemed “CONFIDENTIAL.” After the inspecting Party has identified the

13 || documents it wants copied and produced, the Producing Party must determine which
14 || documents, or portions thereof, qualify for protection under this Order. Then,
15 || before producing the specified documents, the Producing Party must affix the
16 || “CONFIDENTIAL legend” to each page that contains Protected Material. If only a
17 || portion of the material on a page qualifies for protection, the Producing Party also
18 || must clearly identify the protected portion(s) (e.g., by making appropriate markings
19 || in the margins).
20 (b) for testimony given in depositions that the Designating Party identifies
21 || the Disclosure or Discovery Material on the record, before the close of the
22 || deposition all protected testimony.
23 (c) for information produced in some form other than documentary and
24 || for any other tangible items, that the Producing Party affix in a prominent place on
25 || the exterior of the container or containers in which the information is stored the
26 || legend “CONFIDENTIAL.” If only a portion or portions of the information
27 || warrants protection, the Producing Party, to the extent practicable, shall identify the
28 . || protected portion(s).

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1 5.3 Inadvertent Failures to Design ate. If timely corrected, an inadvertent
2 || failure to designate qualified information or items does not, standing alone, waive
3 || the Designating Party’s right to secure protection under this Order for such material.
4 || Upon timely correction of a designation, the Receiving Party must make reasonable
5 || efforts to assure that the material is treated in accordance with the provisions of this
6 || Order.
7 □□ □□ CHALLENGING CONFIDENTIALITY DESIGNATIONS
8 6.1 Timing of Challenges, Any Party may challenge a designation of
9 || confidentiality at any time that is consistent with the Court’s Scheduling Order.
10 6.2 Meetand Confer. The Challenging Party shall initiate the dispute
11 || resolution process under Local Rule 37.1 et seq.
12 6.3. The burden of persuasion in any such challenge proceeding shall be on
13 || the Designating Party. Frivolous challenges, and those made for an improper
14 || purpose (e.g., to harass or impose unnecessary expenses and burdens on other
15 |] parties) may expose the Challenging Party to sanctions. Unless the Designating
16 || Party has waived or withdrawn the confidentiality designation, all parties shall
17 || continue to afford the material in question the level of protection to which it is
18 || entitled under the Producing Party’s designation until the Court rules on the
19 || challenge. .
20 || 7. ACCESS TO AND USE OF PROTECTED MATERIAL
21 7.1 Basic Principles. A Receiving Party may use Protected Material that is
22 || disclosed or produced by another Party or by a Non-Party in connection with this
23 |) Action only for prosecuting, defending or attempting to settle this Action. Such
24 || Protected Material may be disclosed only to the categories of persons and under the
25 || conditions described in this Order.. When the Action has been terminated, a
26 |} Receiving Party must comply. with the provisions of section 13 below (FINAL
27 || DISPOSITION). .. .
28 ‘ Protected Material must be stored and maintained by a Receiving Party at a

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

Case|P:19-cv-01886-DSF-E Document 21 Filed 12/23/19 Page LQ ofils Page ID #295

1 || be separately bound by the court reporter and may not be disclosed to anyone except
2 || as permitted under this Stipulated Protective Order; and
3 (i) any mediator or settlement officer, and their supporting personnel,
4 || mutually agreed upon by any of the parties engaged in settlement discussions.
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
8 || that compels disclosure of any information or items designated in this Action as
9 || “CONFIDENTIAL,” that Party must:
10 (a) promptly notify in writing the Designating Party. Such notification
11 || shall include a copy of the subpoena or court order;
12 (b) promptly notify in writing the party who caused the subpoena or order
13 || to issue in the other. litigation, that some or all of the material covered by the
14 || subpoena or order is subject to this Protective Order. Such notification shall include
15 || acopy of this Stipulated Protective Order; and
16 (c) cooperate with respect to all reasonable procedures sought to be
17 || pursued by the Designating Party whose Protected Material may be affected.
18 If the Designating Party timely seeks a protective order, the Party served with
19 || the subpoena or court order shall not produce any information designated in this
20 || action as “CONFIDENTIAL” 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
25 || to disobey a lawful directive from another court.
26 11/9. ANON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
27 PRODUCED IN THIS LITIGATION
28 (a) The terms of this Order are applicable to information produced by a
10

Case :19-cv-01886-DSF-E Document Filed le/2si/ly Page lloflo Page ID #294

1 || Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
2 || produced by Non-Parties in connection with this litigation is protected by the
3 || remedies and relief provided by this Order. Nothing in these provisions should be
4 || construed as prohibiting a Non-Party from seeking additional protections.
5 (b) In the event that a Party is required, by a valid discovery request, to
6 || produce a Non-Party’s confidential information in its possession, and the Party is
7 || subject to an agreement with the Non-Party not to produce the Non-Party’s
8 || confidential information, then the Party shall:
9 (1) promptly notify in writing the Requesting Party and the Non-Party
10 || that some or all of the information requested is subject to a confidentiality
11 || agreement with a Non-Party;
12 (2) promptly provide the Non-Party with a copy of the Stipulated
13 || Protective Order in this Action, the relevant discovery request(s), and a reasonably
14 || specific description of the information requested; and
15 (3) make the information requested available for inspection by the
16 || Non-Party, if requested.
17 (c) If the Non-Party fails to seek a protective order from this court within
18 || 14 days of receiving the notice and accompanying information, the Receiving Party
19 || may produce the Non-Party’s confidential information responsive to the discovery
20 || request. Ifthe Non-Party timely seeks a protective order, the Receiving Party shall
21 || not produce any information in its possession or control that is subject to the
22 || confidentiality agreement with the Non-Party before a determination by the court.
23 || Absent a court order to the contrary, the Non-Party shall bear the burden and
24 || expense of seeking protection in this court of its Protected Material.
25 || 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
26 . If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
27 || Protected Material to any person or in any circumstance not authorized under this
28 || Stipulated Protective Order, the Receiving Party must immediately (a) notify in
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1 || writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
2 || to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
3 || persons to whom unauthorized disclosures were made of all the terms of this Order,
4 || and (d) request such person or persons to execute the “Acknowledgment and □
5 || Agreement to Be Bound” that is attached hereto as Exhibit A.
6 || 11. 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,
10 || the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
11 || Procedure 26(b)(5)(B).
12 || 12. “MISCELLANEOUS
13 12.1 Right to Further Relief, Nothing in this Order abridges the right of any
14 || person to seek its modification by the Court in the future.
15 12.2 Right to Assert Other Objections. By stipulating to the entry of this
16 || Protective Order, no Party waives any right it otherwise would have to object to
17 || disclosing or producing any information or item on any ground not addressed in this
18 || Stipulated Protective Order. Similarly, no Party waives any right to object on any
19 || ground to use in evidence of any of the material covered by this Protective Order.
20 12.3 Filing Protected Material. A Party that seeks to file under seal any
21 || Protected Material must comply with Local Civil Rule 79-5. Protected Material
22 |) may only be filed under seal pursuant to a court order authorizing the sealing of the
23 || specific Protected Material at issue. If a Party’s request to file Protected Material
24 || under seal is denied by the court, then the Receiving Party may file the information
25 || in the public record unless otherwise instructed by the court.
26 || 13. FINAL DISPOSITION
27 After the final disposition of this Action, as defined in paragraph 4, within 60
28 || days of a written request, by the Designating Party, each Receiving Party must return
12

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1 || all Protected Material to the Producing Party or destroy such material. As used in
2 || this subdivision, “all Protected Material” includes all copies, abstracts, compilations,
3 || summaries, and any other format reproducing or capturing any of the Protected
4 || Material. Whether the Protected Material is returned or destroyed, the Receiving
5 || Party must submit a written certification to the Producing Party (and, if not the same
6 || person or entity, to the Designating Party) by the 60 day deadline that (1) identifies
7 || (by category, where appropriate) all the Protected Material that was returned or
8 || destroyed and (2) affirms that the Receiving Party has not retained any copies,
9 || abstracts, compilations, summaries or any other format reproducing or capturing any
10 || of the Protected Material. Notwithstanding this provision, Counsel are entitled to
11 || retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing
12 || transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
13 || reports, attorney work product, and consultant and expert work product, even if such
14 || materials contain Protected Material. Any such archival copies that contain or
15 || constitute Protected Material remain subject to this Protective Order as set forth in
16 || Section 4 (DURATION). .
17 || 14. VIOLATION
18 || Any violation of this Order may be punished by appropriate measures including,
19 || without limitation, contempt proceedings and/or monetary sanctions.
20 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD.
21 .
22 || DATED October 19, 2019
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35 Atto for Plaintiff Cityscape Rentals, LLC
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1 || DATED: Gcteber 13 , 2019
3 | Dad Me“
Attorneys for Defendant Travelers Casualty
4 || Insurance Company of America
5 .
FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

DATED: _/2/23//2
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11 ON. CHARLES F. EICK
United States Magistrate Judge
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Case/?:19-cv-01886-DSF-E Document Filed leiéa/lY Page io Fage ID #:2¥6

1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
4 iI, [print or type full name], of
5 || [print or type full address], declare under penalty of perjury that I have read in its
6 || entirety and understand the Stipulated Protective Order that was issued by the
7 || United States District Court for the Central District of California on [date] in the
8 || case of Cityscape Rentals, LLC v. Travelers Casualty Insurance Company of
9 || America, et al., United States District Court for the Central District of California,
10 |} Case No. 2:19-cv-01886-DSF-E. I agree to comply with and to be bound by all the
11 |} terms of this Stipulated Protective Order and I understand and acknowledge that
12 || failure to so comply could expose me to sanctions and punishment in the nature of
13 || contempt. I solemnly promise that I will not disclose in any manner any
14 || information or item that is subject to this Stipulated Protective Order to any person
15 || or entity except in strict compliance with the provisions of this Order.
16 || I further agree to submit to the jurisdiction of the United States District Court for the
17 |} Central District of California for enforcing the terms of this Stipulated Protective
18 || Order, even if such enforcement proceedings occur after termination of this action.
19 || [hereby appoint [print or type full name] of
20 [print or type full address and
21 || telephone number] as my California agent for service of process in connection with
22 || this action or any proceedings related to enforcement of this Stipulated Protective
23 |} Order.
24 || Date: . __
25 || City and State where sworm and signed:
26 || Printed name: _
27
28 || Signature:
15

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/10036496. Public record. Not legal advice.