The opinion
1 JASON E. MURTAGH (SBN 294830)
jason.murtagh@bipc.com
2 KOMAL JAIN (309827)
komal.jain@bipc.com
3 BUCHANAN INGERSOLL & ROONEY LLP
One America Plaza
4 600 West Broadway, Suite 1100
San Diego, CA 92101
5 Telephone: 619 239 8700
Fax: 619 702 3898
6
7 Attorneys for Defendants
8 UNITED STATES DISTRICT COURT
9 FOR THE EASTERN DISTRICT OF CALIFORNIA
10 MARGARITA ARROYO, an individual, Case No.: 1:22-cv-00579-JLT-BAM
11 Plaintiff,
[PROPOSED] STIPULATED
12 vs. PROTECTIVE ORDER
13
14 GRAHAM PACKAGING COMPANY,
L.P., a Pennsylvania Limited Partnership;
15 and DOES 1 through 20, inclusive,
Complaint Filed: April 15, 2022
16 Defendant. Removed: May 13, 2022
17
18
19 The parties to this action have stipulated to the terms of this Protective Order;
20 accordingly, it is ORDERED:
21 1. Pursuant to Local Rule 141.1(c)(1) and (2), the parties anticipate that due
22 to the nature of Plaintiff’s claims and Defendants’ defenses, discovery will by
23 definition include including personnel documents, medical records, confidential
24 company documents, which include proprietary information and potential trade secrets,
25 in addition to and third-party personnel information and other personnel information
26 relating to Plaintiff’s claims and Defendant’s defenses. This information is not
27 otherwise available to the public, and the parties recognize and acknowledge that this
1 Defendants’ competitors. The parties also anticipate discovery on topics concerning
2 Plaintiff’s background, much of which shares the same confidential characteristics,
3 including detailed credit information, Plaintiff’s generalized background, Plaintiff’s
4 income taxes, and other information concerning Plaintiff relating to Plaintiff’s claims
5 and Defendants’ defenses. The parties state that the above descriptions are not intended
6 to be an exhaustive list of all classes of information subject to this Stipulated Protective
7 Order. However, this statement is made in compliance with the requirements set forth
8 in Local Rule 141.1(c)(1) and (2).
9 2. Pursuant to Local Rule 141.1(c)(3), the parties agree the details set forth
10 below should be entered by court order, rather than as an agreement by and between
11 the parties, because these terms will apply only to the immediate litigation. A protective
12 order entered by the Court will outline procedures for the parties to follow to
13 expeditiously resolve confidentiality and/or privilege disputes – ideally with minimal
14 court involvement. A court order will govern potential discovery from third parties who
15 are non-parties to the immediate litigation and may not otherwise be subject to a private
16 agreement between the parties.
17
1. PURPOSES AND LIMITATIONS
18
Disclosure and discovery activity in this action are likely to involve production
19
of confidential, proprietary, or private information for which special protection from
20
public disclosure and from use for any purpose other than prosecuting this litigation
21
may be warranted. Accordingly, the parties hereby stipulate to and petition the court to
22
enter the following Stipulated Protective Order. The parties acknowledge that this
23
Order does not confer blanket protections on all disclosures or responses to discovery
24
and that the protection it affords from public disclosure and use extends only to the
25
limited information or items that are entitled to confidential treatment under the
26
applicable legal principles. The parties further acknowledge, as set forth in Section
27
12.3, below, that this Stipulated Protective Order does not entitle them to file
1 confidential information under seal; Civil Local Rule 141 sets forth the procedures that
2 must be followed and the standards that will be applied when a party seeks permission
3 from the court to file material under seal.
4
2. DEFINITIONS
5
2.1 Challenging Party: a Party or Non-Party that challenges the designation of
6
information or items under this Order.
7
2.2 "CONFIDENTIAL" Information or Items: information (regardless of how
8
it is generated, stored or maintained) or tangible things that qualify for protection under
9
Federal Rule of Civil Procedure 26(c).
10
2.3 Counsel (without qualifier): Outside Counsel of Record and House
11
Counsel (as well as their support staff).
12
2.4 Designating Party: a Party or Non-Party that designates information or
13
items that it produces in disclosures or in responses to discovery as
14
"CONFIDENTIAL."
15
2.5 Disclosure or Discovery Material: all items or information, regardless of
16
the medium or manner in which it is generated, stored, or maintained (including, among
17
other things, testimony, transcripts, and tangible things), that are produced or generated
18
in disclosures or responses to discovery in this matter.
19
2.6 Expert: a person with specialized knowledge or experience in a matter
20
pertinent to the litigation who has been retained by a Party or its counsel to serve as an
21
expert witness or as a consultant in this action.
22
2.7 House Counsel: attorneys who are employees of a party to this action.
23
House Counsel does not include Outside Counsel of Record or any other outside
24
counsel.
25
2.8 Non-Party: any natural person, partnership, corporation, association, or
26
other legal entity not named as a Party to this action.
27
1 2.9 Outside Counsel of Record: attorneys who are not employees of a party to
2 this action but are retained to represent or advise a party to this action and have
3 appeared in this action on behalf of that party or are affiliated with a law firm which
4 has appeared on behalf of that party.
5 2.10 Party: any party to this action, including all of its officers, directors,
6 employees, consultants, retained experts, and Outside Counsel of Record (and their
7 support staffs).
8 2.11 Producing Party: a Party or Non-Party that produces Disclosure or
9 Discovery Material in this action.
10 2.12 Professional Vendors: persons or entities that provide litigation support
11 services (e.g., photocopying, videotaping, translating, preparing exhibits or
12 demonstrations, and organizing, storing, or retrieving data in any form or medium) and
13 their employees and subcontractors.
14 2.13 Protected Material: any Disclosure or Discovery Material that is
15 designated as "CONFIDENTIAL."
16 2.14 Receiving Party: a Party that receives Disclosure or Discovery Material
17 from a Producing Party.
18
3. SCOPE
19
The protections conferred by this Stipulation and Order cover not only Protected
20
Material (as defined above), but also (1) any information copied or extracted from
21
Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected
22
Material; and (3) any testimony, conversations, or presentations by Parties or their
23
Counsel that might reveal Protected Material.
24
However, the protections conferred by this Stipulation and Order do not cover
25
the following information: (a) any information that is in the public domain at the time
26
of disclosure to a Receiving Party or becomes part of the public domain after its
27
disclosure to a Receiving Party as a result of publication not involving a violation of
1 this Order, including becoming part of the public record through trial or otherwise; and
2 (b) any information known to the Receiving Party prior to the disclosure or obtained
3 by the Receiving Party after the disclosure from a source who obtained the information
4 lawfully and under no obligation of confidentiality to the Designating Party. Any use
5 of Protected Material at trial shall be governed by a separate agreement or order.
6
4. DURATION
7
Even after final disposition of this litigation, the confidentiality obligations
8
imposed by this Order shall remain in effect until a Designating Party agrees otherwise
9
in writing or a court order otherwise directs. Final disposition shall be deemed to be
10
the later of (1) dismissal of all claims and defenses in this action, with or without
11
prejudice; and (2) final judgment herein after the completion and exhaustion of all
12
appeals, rehearings, remands, trials, or reviews of this action, including the time limits
13
for filing any motions or applications for extension of time pursuant to applicable law.
14
15 5. DESIGNATING PROTECTED MATERIAL
16
5.1 Exercise of Restraint and Care in Designating Material for Protection.
17
Each Party or Non-Party that designates information or items for protection under this
18
Order must take care to limit any such designation to specific material that qualifies
19
under the appropriate standards. The Designating Party must designate for protection
20
only those parts of material, documents, items, or oral or written communications that
21
qualify – so that other portions of the material, documents, items, or communications
22
for which protection is not warranted are not swept unjustifiably within the ambit of
23
this Order.
24
Mass, indiscriminate, or routinized designations are prohibited. Designations
25
that are shown to be clearly unjustified or that have been made for an improper purpose
26
(e.g., to unnecessarily encumber or retard the case development process or to impose
27
unnecessary expenses and burdens on other parties) may expose the Designating Party
1 If it comes to a Designating Party's attention that information or items that it
2 designated for protection do not qualify for protection, that Designating Party must
3 promptly notify all other Parties that it is withdrawing the mistaken designation.
4 5.2 Manner and Timing of Designations. Except as otherwise provided in this
5 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated
6 or ordered, Disclosure or Discovery Material that qualifies for protection under this
7 Order must be clearly so designated before the material is disclosed or produced.
8 Designation in conformity with this Order requires:
9 (a) For information in documentary form (e.g., paper or electronic
10 documents, but excluding transcripts of depositions or other pretrial or trial
11 proceedings), that the Producing Party affix the legend "CONFIDENTIAL" to each
12 page that contains protected material. If only a portion or portions of the material on a
13 page qualifies for protection, the Producing Party also must clearly identify the
14 protected portion(s) (e.g., by making appropriate markings in the margins). A Party or
15 Non-Party that makes original documents or materials available for inspection need not
16 designate them for protection until after the inspecting Party has indicated which
17 material it would like copied and produced. During the inspection and before the
18 designation, all of the material made available for inspection shall be deemed
19 "CONFIDENTIAL." After the inspecting Party has identified the documents it wants
20 copied and produced, the Producing Party must determine which documents, or
21 portions thereof, qualify for protection under this Order. Then, before producing the
22 specified documents, the Producing Party must affix the "CONFIDENTIAL" legend to
23 each page that contains Protected Material. If only a portion or portions of the material
24 on a page qualifies for protection, the Producing Party also must clearly identify the
25 protected portion(s) (e.g., by making appropriate markings in the margins).
26 (b) for testimony given in deposition or in other pretrial or trial
27 proceedings, that the Designating Party identify on the record, before the close of the
1 (c) for information produced in some form other than documentary and
2 for any other tangible items, that the Producing Party affix in a prominent place on the
3 exterior of the container or containers in which the information or item is stored the
4 legend "CONFIDENTIAL." If only a portion or portions of the information or item
5 warrant protection, the Producing Party, to the extent practicable, shall identify the
6 protected portion(s).
7 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
8 failure to designate qualified information or items does not, standing alone, waive the
9 Designating Party's right to secure protection under this Order for such material. Upon
10 timely correction of a designation, the Receiving Party must make reasonable efforts
11 to assure that the material is treated in accordance with the provisions of this Order.
12
6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
13
6.1 Timing of Challenges. Any Party or Non-Party may challenge a
14
designation of confidentiality at any time. Unless a prompt challenge to a Designating
15
Party's confidentiality designation is necessary to avoid foreseeable, substantial
16
unfairness, unnecessary economic burdens, or a significant disruption or delay of the
17
litigation, a Party does not waive its right to challenge a confidentiality designation by
18
electing not to mount a challenge promptly after the original designation is disclosed.
19
6.2 Meet and Confer. The Challenging Party shall initiate the dispute
20
resolution process by providing written notice of each designation it is challenging and
21
describing the basis for each challenge. To avoid ambiguity as to whether a challenge
22
has been made, the written notice must recite that the challenge to confidentiality is
23
being made in accordance with this specific paragraph of the Protective Order. The
24
parties shall attempt to resolve each challenge in good faith and must begin the process
25
by conferring directly (in voice to voice dialogue; other forms of communication are
26
not sufficient) within 14 days of the date of service of notice. In conferring, the
27
Challenging Party must explain the basis for its belief that the confidentiality
1 designation was not proper and must give the Designating Party an opportunity to
2 review the designated material, to reconsider the circumstances, and, if no change in
3 designation is offered, to explain the basis for the chosen designation. A Challenging
4 Party may proceed to the next stage of the challenge process only if it has engaged in
5 this meet and confer process first or establishes that the Designating Party is unwilling
6 to participate in the meet and confer process in a timely manner.
7 6.3 Judicial Intervention. If the Parties cannot resolve a challenge without
8 court intervention, the Designating Party shall file and serve a motion to retain
9 confidentiality (in compliance with Civil Local Rule 141, if applicable) within 21 days
10 of the initial notice of challenge or within 14 days of the parties agreeing that the meet
11 and confer process will not resolve their dispute, whichever is earlier. Each such motion
12 must be accompanied by a competent declaration affirming that the movant has
13 complied with the meet and confer requirements imposed in the preceding paragraph.
14 Failure by the Designating Party to make such a motion including the required
15 declaration within 21 days (or 14 days, if applicable) shall automatically waive the
16 confidentiality designation for each challenged designation. In addition, the
17 Challenging Party may file a motion challenging a confidentiality designation at any
18 time if there is good cause for doing so, including a challenge to the designation of a
19 deposition transcript or any portions thereof. Any motion brought pursuant to this
20 provision must be accompanied by a competent declaration affirming that the movant
21 has complied with the meet and confer requirements imposed by the preceding
22 paragraph.
23 The burden of persuasion in any such challenge proceeding shall be on the
24 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g.,
25 to harass or impose unnecessary expenses and burdens on other parties) may expose
26 the Challenging Party to sanctions Unless the Designating Party has waived the
27 confidentiality designation by failing to file a motion to retain confidentiality as
1 protection to which it is entitled under the Producing Party's designation until the court
2 rules on the challenge.
3
7. ACCESS TO AND USE OF PROTECTED MATERIAL
4
7.1 Basic Principles. A Receiving Party may use Protected Material that is
5
disclosed or produced by another Party or by a Non-Party in connection with this case
6
only for prosecuting, defending, or attempting to settle this litigation. Such Protected
7
Material may be disclosed only to the categories of persons and under the conditions
8
described in this Order. When the litigation has been terminated, a Receiving Party
9
must comply with the provisions of section 13 below (FINAL DISPOSITION).
10
Protected Material must be stored and maintained by a Receiving Party at a
11
location and in a secure manner that ensures that access is limited to the persons
12
authorized under this Order.
13
7.2 Disclosure of "CONFIDENTIAL" Information or Items. Unless otherwise
14
ordered by the court or permitted in writing by the Designating Party, a Receiving Party
15
may disclose any information or item designated "CONFIDENTIAL" only to:
16
(a) the Receiving Party's Outside Counsel of Record in this action, as
17
well as employees of said Outside Counsel of Record to whom it is reasonably
18
necessary to disclose the information for this litigation and who have signed the
19
"Acknowledgment and Agreement to Be Bound" that is attached hereto as Exhibit A;
20
(b) the officers, directors, and employees (including House Counsel) of
21
the Receiving Party to whom disclosure is reasonably necessary for this litigation and
22
who have signed the "Acknowledgment and Agreement to Be Bound" (Exhibit A);
23
(c) Experts (as defined in this Order) of the Receiving Party to whom
24
disclosure is reasonably necessary for this litigation and who have signed the
25
"Acknowledgment and Agreement to Be Bound" (Exhibit A);
26
(d) the court and its personnel;
27
1 (e) court reporters and their staff, professional jury or trial consultants,
2 mock jurors, and Professional Vendors to whom disclosure is reasonably necessary for
3 this litigation and who have signed the "Acknowledgment and Agreement to Be
4 Bound" (Exhibit A);
5 (f) during their depositions, witnesses in the action to whom disclosure
6 is reasonably necessary and who have signed the "Acknowledgment and Agreement to
7 Be Bound" (Exhibit A), unless otherwise agreed by the Designating Party or ordered
8 by the court. Pages of transcribed deposition testimony or exhibits to depositions that
9 reveal Protected Material must be separately bound by the court reporter and may not
10 be disclosed to anyone except as permitted under this Stipulated Protective Order.
11 (g) the author or recipient of a document containing the information or
12 a custodian or other person who otherwise possessed or knew the information.
13
8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN
14 OTHER LITIGATION
15
If a Party is served with a subpoena or a court order issued in other litigation that
16
compels disclosure of any information or items designated in this action as
17
"CONFIDENTIAL," that Party must:
18
(a) promptly notify in writing the Designating Party. Such notification
19
shall include a copy of the subpoena or court order;
20
(b) promptly notify in writing the party who caused the subpoena or
21
order to issue in the other litigation that some or all of the material covered by the
22
subpoena or order is subject to this Protective Order. Such notification shall include a
23
copy of this Stipulated Protective Order; and
24
(c) cooperate with respect to all reasonable procedures sought to be
25
pursued by the Designating Party whose Protected Material may be affected.
26
If the Designating Party timely seeks a protective order, the Party served with
27
the subpoena or court order shall not produce any information designated in this action
1 or order issued, unless the Party has obtained the Designating Party's permission. The
2 Designating Party shall bear the burden and expense of seeking protection in that court
3 of its confidential material – and nothing in these provisions should be construed as
4 authorizing or encouraging a Receiving Party in this action to disobey a lawful directive
5 from another court.
6
9. A NON-PARTY'S PROTECTED MATERIAL SOUGHT TO BE PRODUCED
7 IN THIS LITIGATION
8
(a) The terms of this Order are applicable to information produced by
9
a Non-Party in this action and designated as "CONFIDENTIAL." Such information
10
produced by Non-Parties in connection with this litigation is protected by the remedies
11
and relief provided by this Order. Nothing in these provisions should be construed as
12
prohibiting a Non-Party from seeking additional protections.
13
(b) In the event that a Party is required, by a valid discovery request, to
14
produce a Non- Party's confidential information in its possession, and the Party is
15
subject to an agreement with the Non-Party not to produce the Non-Party's confidential
16
information, then the Party shall:
17
(i) promptly notify in writing the Requesting Party and the Non-
18
Party that some or all of the information requested is subject to a confidentiality
19
agreement with a Non-Party;
20
(ii) promptly provide the Non-Party with a copy of the Stipulated
21
Protective Order in this litigation, the relevant discovery request(s), and a reasonably
22
specific description of the information requested; and
23
(iii) make the information requested available for inspection by
24
the Non-Party.
25
(c) If the Non-Party fails to object or seek a protective order from this
26
court within 14 days of receiving the notice and accompanying information, the
27
Receiving Party may produce the Non-Party's confidential information responsive to
1 Party shall not produce any information in its possession or control that is subject to
2 the confidentiality agreement with the Non-Party before a determination by the court.
3 Absent a court order to the contrary, the Non-Party shall bear the burden and expense
4 of seeking protection in this court of its Protected Material.
5
10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
6
If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
7
Protected Material to any person or in any circumstance not authorized under this
8
Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing
9
the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve
10
all unauthorized copies of the Protected Material, (c) inform the person or persons to
11
whom unauthorized disclosures were made of all the terms of this Order, and (d)
12
request such person or persons to execute the "Acknowledgment and Agreement to Be
13
Bound" that is attached hereto as Exhibit A.
14
15 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
16 PROTECTED MATERIAL
17 When a Producing Party gives notice to Receiving Parties that certain
18 inadvertently produced material is subject to a claim of privilege or other protection,
19 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
20 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
21 may be established in an e-discovery order that provides for production without prior
22 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
23 parties reach an agreement on the effect of disclosure of a communication or
24 information covered by the attorney-client privilege or work product protection, the
25 parties may incorporate their agreement in the stipulated protective order submitted to
26 the court.
27
1 12. MISCELLANEOUS
2 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
3 person to seek its modification by the court in the future.
4 12.2 Right to Assert Other Objections. By stipulating to the entry of this
5 Protective Order no Party waives any right it otherwise would have to object to
6 disclosing or producing any information or item on any ground not addressed in this
7 Stipulated Protective Order. Similarly, no Party waives any right to object on any
8 ground to use in evidence of any of the material covered by this Protective Order.
9 12.3 Filing Protected Material. Without written permission from the
10 Designating Party or a court order secured after appropriate notice to all interested
11 persons, a Party may not file in the public record in this action any Protected Material.
12 A Party that seeks to file under seal any Protected Material must comply with Civil
13 Local Rule 141. Protected Material may only be filed under seal pursuant to a court
14 order authorizing the sealing of the specific Protected Material at issue. Pursuant to
15 Civil Local Rule 141, a sealing order will issue only upon a request establishing that
16 the Protected Material at issue is privileged, protectable as a trade secret, or otherwise
17 entitled to protection under the law. If a Receiving Party's request to file Protected
18 Material under seal pursuant to Civil Local Rule 141 is denied by the court, then the
19 Receiving Party may file the information in the public record pursuant to Civil Local
20 Rule 141 unless otherwise instructed by the court.
21
13. FINAL DISPOSITION
22
23 Within 60 days after the final disposition of this action, as defined in paragraph
24 4, each Receiving Party must return all Protected Material to the Producing Party or
25 destroy such material. As used in this subdivision, "all Protected Material" includes all
26 copies, abstracts, compilations, summaries, and any other format reproducing or
27 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
1 Party (and, if not the same person or entity, to the Designating Party) by the 60 day
2 deadline that (1) identifies (by category, where appropriate) all the Protected Material
3 that was returned or destroyed and (2) affirms that the Receiving Party has not retained
4 any copies, abstracts, compilations, summaries or any other format reproducing or
5 capturing any of the Protected Material. Notwithstanding this provision, Counsel are
6 entitled to retain an archival copy of all pleadings, motion papers, trial, deposition, and
7 hearing transcripts, legal memoranda, correspondence, deposition and trial exhibits,
8 expert reports, attorney work product, and consultant and expert work product, even if
9 such materials contain Protected Material. Any such archival copies that contain or
10 constitute Protected Material remain subject to this Protective Order as set forth in
11 Section 4 (DURATION).
12
13
IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD:
14
15
DATED: May 16, 2023 BY: /s/ Joshua Falakassa___________________
16 COUNSEL FOR PLAINTIFF
17
18
DATED: May 16, 2023 BY: /s/ Komal Jain_______________________
19
COUNSEL FOR DEFENDANTS
20
21
22
23
24
25
26
27
1 EXHIBIT A
2 CERTIFICATION RE CONFIDENTIAL DISCOVERY MATERIALS
3 I hereby acknowledge that I, ______________________________ [NAME],
4 _________________________________ [POSITION AND EMPLOYER], am about
5 to receive Protected Material(s) supplied in connection with the Proceeding, 1:22-CV-
6 00579-JLT-BAM (“Proceeding”) I certify that I understand that the Protected
7 Material(s) are provided to me subject to the terms and restrictions of the Stipulation
8 and Protective Order filed in this Proceeding. I have been given a copy of the
9 Stipulation and Protective Order; I have read it, and I agree to be bound by its terms.
10 I understand that the Protected Material(s), as defined in the Stipulation and
11 Protective Order, including any notes or other records that may be made regarding any
12 such materials, shall not be Disclosed to anyone except as expressly permitted by the
13 Stipulation and Protective Order. I will not copy or use, except solely for the purposes
14 of this Proceeding, any Protected Material(s), except as provided therein or otherwise
15 ordered by the Court in the Proceeding.
16 I further understand that I am to retain all copies of all Protected Material(s) in
17 a secure manner, and that all copies of such materials are to remain in my personal
18 custody until termination of my participation in this Proceeding, whereupon the copies
19 of such materials will be returned to counsel who provided me with such materials.
20 I declare under penalty of perjury that the foregoing is true and correct.
21
22
23 DATED: _________________________ BY: _______________________________
Signature
24
25 _______________________________
Name and Title
26
27
________________________________
Phone Number/Email
1 ORDER
2 Having considered the Stipulated Protective Order, and finding good cause,
3 the Court adopts the stipulated protective order. (Doc. 16.)
4 The parties are advised that pursuant to the Local Rules of the United States
5 District Court, Eastern District of California, any documents subject to the protective
6 order to be filed under seal must be accompanied by a written request which
7 complies with Local Rule 141 prior to sealing. The party making a request to file
8 documents under seal shall be required to show good cause for documents attached
9 to a non-dispositive motion or compelling reasons for documents attached to a
10 dispositive motion. Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-78 (9th Cir.
11 2009). Within five (5) days of any approved document filed under seal, the party
12 shall file a redacted copy of the sealed document. The redactions shall be narrowly
13 tailored to protect only the information that is confidential or was deemed
14 confidential.
15 Additionally, the parties shall consider resolving any dispute arising under the
16 stipulated protective order according to the Court’s informal discovery dispute
17 procedure.
18
19 IT IS SO ORDERED.
20 Dated: May 22, 2023 /s/ Barbara A. McAuliffe _
21 UNITED STATES MAGISTRATE JUDGE
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