Michael Thai v. Team Industrial Services, Inc.

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8 UNITED STATES DISTRICT COURT

9 CENTRAL DISTRICT OF CALIFORNIA

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MICHAEL THAI, an individual, on

11 behalf of himself and on behalf of all Case No. 2:21-cv-03319-FLA-GJS

others similarly situated,

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Plaintiff, [PROPOSED] STIPULATED

13 PROTECTIVE ORDER1

v.

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TEAM INDUSTRIAL SERVICES,

15 INC., a Corporation; and Does 1

through 50 Inclusive,

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Defendants.

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19 1. A. PURPOSES AND LIMITATIONS

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

21 proprietary or private information for which special protection from public

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

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

24 enter the following Stipulated Protective Order. The parties acknowledge that this

25 Order does not confer blanket protections on all disclosures or responses to

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27 1 This Stipulated Protective Order is substantially based on the model protective

order provided under Magistrate Judge Gail J. Standish’s Procedures.

1 discovery and that the protection it affords from public disclosure and use extends

2 only to the limited information or items that are entitled to confidential treatment

3 under the applicable legal principles.

4 B. GOOD CAUSE STATEMENT

5 This action is likely to involve third party private information, private

6 personnel information, trade secret, proprietary business and/or financial

7 information, and/or other commercial, financial, technical and/or proprietary

8 information for which special protection from public disclosure and from use for

9 any purpose other than prosecution of this action is warranted. Such confidential

10 and proprietary materials and information consist of, among other things,

11 confidential business or financial information, information regarding confidential

12 business practices, or other confidential commercial information (including

13 information implicating privacy rights of third parties, including Defendant’s current

14 and former employees), information otherwise generally unavailable to the public,

15 or which may be privileged or otherwise protected from disclosure under state or

16 federal statutes, court rules, case decisions, or common law. Accordingly, to

17 expedite the flow of information, to facilitate the prompt resolution of disputes over

18 confidentiality of discovery materials, to adequately protect information the parties

19 are entitled to keep confidential, to ensure that the parties are permitted reasonable

20 necessary uses of such material in preparation for and in the conduct of trial, to

21 address their handling at the end of the litigation, and serve the ends of justice, a

22 protective order for such information is justified in this matter. It is the intent of the

23 parties that information will not be designated as confidential for tactical reasons

24 and that nothing be so designated without a good faith belief that it has been

25 maintained in a confidential, non-public manner, and there is good cause why it

26 should not be part of the public record of this case.

27 / / /

1 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL

2 The parties further acknowledge, as set forth in Section 12.3, below, that this

3 Stipulated Protective Order does not entitle them to file confidential information

4 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed

5 and the standards that will be applied when a party seeks permission from the court

6 to file material under seal.

7 There is a strong presumption that the public has a right of access to judicial

8 proceedings and records in civil cases. In connection with non-dispositive motions,

9 good cause must be shown to support a filing under seal. See Kamakana v. City and

10 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors

11 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics,

12 Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders

13 require good cause showing), and a specific showing of good cause or compelling

14 reasons with proper evidentiary support and legal justification, must be made with

15 respect to Protected Material that a party seeks to file under seal. The parties’ mere

16 designation of Disclosure or Discovery Material as CONFIDENTIAL does not—

17 without the submission of competent evidence by declaration, establishing that the

18 material sought to be filed under seal qualifies as confidential, privileged, or

19 otherwise protectable—constitute good cause.

20 Further, if a party requests sealing related to a dispositive motion or trial, then

21 compelling reasons, not only good cause, for the sealing must be shown, and the

22 relief sought shall be narrowly tailored to serve the specific interest to be protected.

23 See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For

24 each item or type of information, document, or thing sought to be filed or introduced

25 under seal in connection with a dispositive motion or trial, the party seeking

26 protection must articulate compelling reasons, supported by specific facts and legal

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1 justification, for the requested sealing order. Again, competent evidence supporting

2 the application to file documents under seal must be provided by declaration.

3 Any document that is not confidential, privileged, or otherwise protectable in

4 its entirety will not be filed under seal if the confidential portions can be redacted.

5 If documents can be redacted, then a redacted version for public viewing, omitting

6 only the confidential, privileged, or otherwise protectable portions of the document,

7 shall be filed. Any application that seeks to file documents under seal in their

8 entirety should include an explanation of why redaction is not feasible.

9 2. DEFINITIONS

10 2.1 Action: the above-captioned lawsuit and all actions now or later

11 consolidated with that lawsuit, and any appeal from that lawsuit, and from any other

12 action consolidated at any time under the above-captioned lawsuit, through final

13 judgment.

14 2.2 Challenging Party: a Party or Non-Party that challenges the

15 designation of information or items under this Order.

16 2.3 “CONFIDENTIAL” Information or Items: information (regardless of

17 how it is generated, stored or maintained) or tangible things that qualify for

18 protection under Federal Rule of Civil Procedure 26(c), and as specified above in

19 the Good Cause Statement.

20 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as

21 their support staff).

22 2.5 Designating Party: a Party or Non-Party that designates information or

23 items that it produces in disclosures or in responses to discovery as

24 “CONFIDENTIAL.”

25 2.6 Disclosure or Discovery Material: all items or information, regardless

26 of the medium or manner in which it is generated, stored, or maintained (including,

27 among other things, testimony, transcripts, and tangible things), that are produced or

1 generated in disclosures or responses to discovery in this matter.

2 2.7 Expert: a person with specialized knowledge or experience in a matter

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

4 an expert witness or as a consultant in this Action.

5 2.8 House Counsel: attorneys who are employees of a party to this Action.

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

7 counsel.

8 2.9 Non-Party: any natural person, partnership, corporation, association or

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

10 2.10 Outside Counsel of Record: attorneys who are not employees of a

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

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

13 that has appeared on behalf of that party, and includes support staff.

14 2.11 Party: any party to this Action, including all of its officers, directors,

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

16 support staffs).

17 2.12 Producing Party: a Party or Non-Party that produces Disclosure or

18 Discovery Material in this Action.

19 2.13 Professional Vendors: persons or entities that provide litigation

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

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

22 and their employees and subcontractors.

23 2.14 Protected Material: any Disclosure or Discovery Material that is

24 designated as “CONFIDENTIAL.”

25 2.15 Receiving Party: a Party that receives Disclosure or Discovery

26 Material from a Producing Party.

27 / / /

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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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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

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trial judge. This Order does not govern the use of Protected Material at trial.

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4. DURATION

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FINAL DISPOSITION of the action is defined as the conclusion of any

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appellate proceedings, or, if no appeal is taken, when the time for filing of an appeal

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has run. Except as set forth below, the terms of this protective order apply through

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FINAL DISPOSITION of the action. The parties may stipulate that the they will be

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contractually bound by the terms of this agreement beyond FINAL DISPOSITION,

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but will have to file a separate action for enforcement of the agreement once all

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proceedings in this case are complete.

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Once a case proceeds to trial, information that was designated as

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CONFIDENTIAL or maintained pursuant to this protective order used or introduced

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as an exhibit at trial becomes public and will be presumptively available to all

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members of the public, including the press, unless compelling reasons supported by

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specific factual findings to proceed otherwise are made to the trial judge in advance

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of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause”

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showing for sealing documents produced in discovery from “compelling reasons”

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standard when merits-related documents are part of court record). Accordingly, for

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such materials, the terms of this protective order do not extend beyond the

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commencement of the trial.

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2 5. DESIGNATING PROTECTED MATERIAL

3 5.1 Exercise of Restraint and Care in Designating Material for Protection.

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

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

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

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

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

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

10 within the ambit of this Order.

11 Mass, indiscriminate or routinized designations are prohibited. Designations

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

13 purpose (e.g., to unnecessarily encumber the case development process or to impose

14 unnecessary expenses and burdens on other parties) may expose the Designating

15 Party to sanctions.

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

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

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

19 5.2 Manner and Timing of Designations. Except as otherwise provided in

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

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

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

23 produced.

24 Designation in conformity with this Order requires:

25 (a) for information in documentary form (e.g., paper or electronic

26 documents, but excluding transcripts of depositions or other pretrial or trial

27 proceedings), that the Producing Party affix at a minimum, the legend

1 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that

2 contains protected material. If only a portion of the material on a page qualifies for

3 protection, the Producing Party also must clearly identify the protected portion(s)

4 (e.g., by making appropriate markings in the margins).

5 A Party or Non-Party that makes original documents available for inspection

6 need not designate them for protection until after the inspecting Party has indicated

7 which documents it would like copied and produced. During the inspection and

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

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

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

11 documents, or portions thereof, qualify for protection under this Order. Then,

12 before producing the specified documents, the Producing Party must affix the

13 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a

14 portion of the material on a page qualifies for protection, the Producing Party also

15 must clearly identify the protected portion(s) (e.g., by making appropriate markings

16 in the margins).

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

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

19 deposition all protected testimony.

20 (c) for information produced in some form other than documentary and

21 for any other tangible items, that the Producing Party affix in a prominent place on

22 the exterior of the container or containers in which the information is stored the

23 legend “CONFIDENTIAL.” If only a portion or portions of the information

24 warrants protection, the Producing Party, to the extent practicable, shall identify the

25 protected portion(s).

26 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent

27 failure to designate qualified information or items does not, standing alone, waive

1 the Designating Party’s right to secure protection under this Order for such material.

2 Upon timely correction of a designation, the Receiving Party must make reasonable

3 efforts to assure that the material is treated in accordance with the provisions of this

4 Order.

5 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

6 6.1 Timing of Challenges. Any Party or Non-Party may challenge a

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

8 Scheduling Order.

9 6.2 Meet and Confer. The Challenging Party shall initiate the dispute

10 resolution process under Local Rule 37.1 et seq.

11 6.3 The burden of persuasion in any such challenge proceeding shall be on

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

13 purpose (e.g., to harass or impose unnecessary expenses and burdens on other

14 parties) may expose the Challenging Party to sanctions. Unless the Designating

15 Party has waived or withdrawn the confidentiality designation, all parties shall

16 continue to afford the material in question the level of protection to which it is

17 entitled under the Producing Party’s designation until the Court rules on the

18 challenge.

19 7. ACCESS TO AND USE OF PROTECTED MATERIAL

20 7.1 Basic Principles. A Receiving Party may use Protected Material that is

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

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

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

24 conditions described in this Order. When the Action has been terminated, a

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

26 DISPOSITION).

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

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 “CONFIDENTIAL” 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 personnel;

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

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

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

3 as permitted under this Stipulated Protective Order; and

4 (i) any mediator or settlement officer, and their supporting personnel,

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

6 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED

7 IN OTHER LITIGATION

8 If a Party is served with a subpoena or a court order issued in other litigation

9 that compels disclosure of any information or items designated in this Action as

10 “CONFIDENTIAL,” that Party must:

11 (a) promptly notify in writing the Designating Party. Such notification

12 shall include a copy of the subpoena or court order;

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

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

15 subpoena or order is subject to this Protective Order. Such notification shall include

16 a copy of this Stipulated Protective Order; and

17 (c) cooperate with respect to all reasonable procedures sought to be

18 pursued by the Designating Party whose Protected Material may be affected.

19 If the Designating Party timely seeks a protective order, the Party served with

20 the subpoena or court order shall not produce any information designated in this

21 action as “CONFIDENTIAL” before a determination by the court from which the

22 subpoena or order issued, unless the Party has obtained the Designating Party’s

23 permission. The Designating Party shall bear the burden and expense of seeking

24 protection in that court of its confidential material and nothing in these provisions

25 should be construed as authorizing or encouraging a Receiving Party in this Action

26 to disobey a lawful directive from another court.

27 / / /

1 / / /

2 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

3 PRODUCED IN THIS LITIGATION

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

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

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

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

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

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

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

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

12 confidential information, then the Party shall:

13 (1) promptly notify in writing the Requesting Party and the Non-Party

14 that some or all of the information requested is subject to a confidentiality

15 agreement with a Non-Party;

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

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

18 specific description of the information requested; and

19 (3) make the information requested available for inspection by the

20 Non-Party, if requested.

21 (c) If the Non-Party fails to seek a protective order from this court within

22 14 days of receiving the notice and accompanying information, the Receiving Party

23 may produce the Non-Party’s confidential information responsive to the discovery

24 request. If the Non-Party timely seeks a protective order, the Receiving Party shall

25 not produce any information in its possession or control that is subject to the

26 confidentiality agreement with the Non-Party before a determination by the court.

27 Absent a court order to the contrary, the Non-Party shall bear the burden and

1 expense of seeking protection in this court of its Protected Material.

2 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

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

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

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

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

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

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

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

11 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

12 PROTECTED MATERIAL

13 When a Producing Party gives notice to Receiving Parties that certain

14 inadvertently produced material is subject to a claim of privilege or other protection,

15 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil

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

17 procedure may be established in an e-discovery order that provides for production

18 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and

19 (e), insofar as the parties reach an agreement on the effect of disclosure of a

20 communication or information covered by the attorney-client privilege or work

21 product protection, the parties may incorporate their agreement in the stipulated

22 protective order submitted to the court.

23 12. MISCELLANEOUS

24 12.1 Right to Further Relief. Nothing in this Order abridges the right of any

25 person to seek its modification by the Court in the future.

26 12.2 Right to Assert Other Objections. By stipulating to the entry of this

27 Protective Order, no Party waives any right it otherwise would have to object to

1 disclosing or producing any information or item on any ground not addressed in this

2 Stipulated Protective Order. Similarly, no Party waives any right to object on any

3 ground to use in evidence of any of the material covered by this Protective Order.

4 12.3 Filing Protected Material. A Party that seeks to file under seal any

5 Protected Material must comply with Local Civil Rule 79-5. Protected Material

6 may only be filed under seal pursuant to a court order authorizing the sealing of the

7 specific Protected Material at issue. If a Party’s request to file Protected Material

8 under seal is denied by the court, then the Receiving Party may file the information

9 in the public record unless otherwise instructed by the court.

10 13. FINAL DISPOSITION

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

12 days of a written request by the Designating Party, each Receiving Party must return

13 all Protected Material to the Producing Party or destroy such material. As used in

14 this subdivision, “all Protected Material” includes all copies, abstracts, compilations,

15 summaries, and any other format reproducing or capturing any of the Protected

16 Material. Whether the Protected Material is returned or destroyed, the Receiving

17 Party must submit a written certification to the Producing Party (and, if not the same

18 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies

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

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

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

22 of the Protected Material. Notwithstanding this provision, Counsel are entitled to

23 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing

24 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert

25 reports, attorney work product, and consultant and expert work product, even if such

26 materials contain Protected Material. Any such archival copies that contain or

27 constitute Protected Material remain subject to this Protective Order as set forth in

1 Section 4 (DURATION).

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1 || 14. VIOLATION

2 || Any violation of this Order may be punished by appropriate measures including,

3 || without limitation, contempt proceedings and/or monetary sanctions.

4 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD.

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Dated: September 15, 2021 BLUMENTHAL NORDREHAUG

6 BHOWMIK DE BLOUW LLP

7 By: /s/ Christine T. LeVu

APARAJIT BHOWMIK

8 CHRISTINE T. LEVU

9 Attorneys for Plaintiff Michael Thai

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Dated: September 16, 2021 BOUTIN JONES INC.

By: /s/ James D. McNairy

12 JAMES D. MCNAIRY

13 Attorneys for Defendant Team Industrial Services,

14 Inc.

15 FILER’S ATTESTATION

16 Pursuant to Local Civil Rule 5-4.3.4(a)(2)(1), I attest under penalty of perjury

17 || that all other signatories listed, and on whose behalf the filing is submitted, concur in

18 || the filing’s content and have authorized this filing.

19

20 /s/ James D. McNai

James D. McNairy

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22 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

23 || DATED: _September 22, 2021

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HON. GAIL J. STANDISH

27 || United States Magistrate Judge

28 16

1 EXHIBIT A

2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

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4 I, _____________________________ [print or type full name], of

5 _________________ [print or type full address], declare under penalty of perjury

6 that I have read in its entirety and understand the Stipulated Protective Order that

7 was issued by the United States District Court for the Central District of California

8 on [date] in the case of Michael Thai v. Team Industrial Services, Inc., Case No.

9 2:21-cv-03319-FLA-GJS. I agree to comply with and to be bound by all the terms

10 of this Stipulated Protective Order and I understand and acknowledge that failure to

11 so comply could expose me to sanctions and punishment in the nature of contempt.

12 I solemnly promise that I will not disclose in any manner any information or item

13 that is subject to this Stipulated Protective Order to any person or entity except in

14 strict compliance with the provisions of this Order.

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

16 Central District of California for enforcing the terms of this Stipulated Protective

17 Order, even if such enforcement proceedings occur after termination of this action.

18 I hereby appoint __________________________ [print or type full name] of

19 _______________________________________ [print or type full address and

20 telephone number] as my California agent for service of process in connection with

21 this action or any proceedings related to enforcement of this Stipulated Protective

22 Order.

23 Date: ______________________________________

24 City and State where sworn and signed: _________________________________

25

26 Printed name: _______________________________

27 Signature: __________________________________