even 25 stipulated protective orders require good cause showing
How later courts described this case
- even 25 stipulated protective orders require good cause showing
Written by the judges who cited it.
The opinion
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UNITED STATES DISTRICT COURT
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FOR THE CENTRAL DISTRICT OF CALIFORNIA
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JON ANTHONY CLARK, individually Case No.
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and on behalf of all others similarly 5:24−cv−01903−SSS−DTB
12 situated,
STIPULATED
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Plaintiff, PROTECTIVE ORDER
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v.
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16 FREEDOM FOREVER LLC,
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Defendant.
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1 This Stipulated Protective Order is entered into between (1) Plaintiff, Jon
2 Anthony Clark (“Plaintiff”); and (2) Defendant, Freedom Forever LLC
3 (“Defendant” or “Freedom Forever”) in this case, styled Clark v. Freedom Forever
4 LLC, Case No. 5:24-cv-01903-SSS-DTB (hereinafter, the “Action”). Plaintiff and
5 Defendant will collectively be referred to hereinafter as the “Parties.”
6
1. INTRODUCTION
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1.1 Purposes and Limitations. Discovery in this Lawsuit is likely to
8
involve production of confidential, proprietary, or private information for which
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special protection from public disclosure and from use for any purpose other than
10
prosecuting this litigation may be warranted. Accordingly, the Parties hereby
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stipulate to and petition the Court to enter the following Stipulated Protective
12
Order. The Parties acknowledge that this Order does not confer blanket protections
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on all disclosures or responses to discovery and that the protection it affords from
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public disclosure and use extends only to the limited information or items that are
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entitled to confidential treatment under the applicable legal principles.
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1.2 Good Cause Statement. This Action is likely to involve trade secrets,
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customer and pricing lists and other valuable research, development, commercial,
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financial, technical and/or proprietary information for which special protection
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20 from public disclosure and from use for any purpose other than prosecution of this
21 action is warranted. Such confidential and proprietary materials and information
22 consist of, among other things, confidential business or financial information,
23 information regarding confidential business practices, or other confidential
24 research, development, or commercial information (including information
25 implicating privacy rights of third parties), information otherwise generally
26 unavailable to the public, or which may be privileged or otherwise protected from
27 disclosure under state or federal statutes, court rules, case decisions, or common
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1 law, such as Freedom Forever’s business practices and technological procedures
2 and policies. Accordingly, to expedite the flow of information, to facilitate the
3 prompt resolution of disputes over confidentiality of discovery materials, to
4 adequately protect information the parties are entitled to keep confidential, to
5 ensure that the Parties are permitted reasonable necessary uses of such material in
6
preparation for and in the conduct of trial, to address their handling at the end of
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the litigation, and serve the ends of justice, a protective order for such information
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is justified in this matter. It is the intent of the Parties that information will not be
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designated as confidential for tactical reasons and that nothing be so designated
10
without a good faith belief that it has been maintained in a confidential, non-public
11
manner, and there is good cause why it should not be part of the public record of
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this case.
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1.3 Acknowledgment of Procedure for Filing Under Seal. The Parties
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further acknowledge, as set forth in Section 12.3 below, that this Stipulated
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Protective Order does not entitle them to file confidential information under seal;
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Local Rule 79-5 sets forth the procedures that must be followed and the standards
17
that will be applied when a party seeks permission from the court to file material
18
under seal. There is a strong presumption that the public has a right of access to
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20 judicial proceedings and records in civil cases. In connection with non-dispositive
21 motions, good cause must be shown to support a filing under seal. See Kamakana
22 v. City and Cnty. of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips ex rel.
23 Ests. of Byrd v. Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002),
24 Makar-Welbon v. Sony Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even
25 stipulated protective orders require good cause showing), and a specific showing of
26 good cause or compelling reasons with proper evidentiary support and legal
27 justification, must be made with respect to Protected Material that a party seeks to
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1 file under seal. The parties’ mere designation of Disclosure or Discovery Material
2 as CONFIDENTIAL does not— without the submission of competent evidence by
3 declaration, establishing that the material sought to be filed under seal qualifies as
4 confidential, privileged, or otherwise protectable—constitute good cause.
5 Further, if a party requests sealing related to a dispositive motion or trial,
6
then compelling reasons, not only good cause, for the sealing must be shown, and
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the relief sought shall be narrowly tailored to serve the specific interest to be
8
protected. See Pintos v. Pac. Creditors Ass’n, 605 F.3d 665, 677–79 (9th Cir.
9
2010). For each item or type of information, document, or thing sought to be filed
10
or introduced under seal in connection with a dispositive motion or trial, the party
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seeking protection must articulate compelling reasons, supported by specific facts
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and legal justification, for the requested sealing order. Again, competent evidence
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supporting the application to file documents under seal must be provided by
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declaration. Any document that is not confidential, privileged, or otherwise
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protectable in its entirety will not be filed under seal if the confidential portions
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can be redacted. If documents can be redacted, then a redacted version for public
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viewing, omitting only the confidential, privileged, or otherwise protectable
18
portions of the document, shall be filed. Any application that seeks to file
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20 documents under seal in their entirety should include an explanation of why
21 redaction is not feasible.
22 2. DEFINITIONS
23 2.1 Action: this lawsuit, styled Clark v. Freedom Forever LLC, Case No.
24 5:24-cv-01903-SSS-DTB.
25 2.2 Challenging Party: a Party or Non-Party that challenges the designation
26 of information or items under this Order.
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1 2.3 “CONFIDENTIAL” Information or Items: information (regardless of
2 how it is generated, stored or maintained) or tangible things that qualify for
3 protection under Rule 26(c) of the Federal Rules of Civil Procedure, and as
4 specified above in the Good Cause Statement.
5 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as
6
their support staff).
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2.5 Designating Party: a Party or Non-Party that designates information or
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items that it produces in disclosures or in responses to discovery as
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“CONFIDENTIAL.”
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2.6 Disclosure or Discovery Material: all items or information, regardless
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of the medium or manner in which it is generated, stored, or maintained (including,
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among other things, testimony, transcripts, and tangible things), that are produced
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or generated in disclosures or responses to discovery in this matter.
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2.7 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
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as an expert witness or as a consultant in this Action.
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2.8 Final Disposition: the later of (1) dismissal of all claims and defenses in
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this Action, with or without prejudice; and (2) final judgment herein after the
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20 completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of
21 this Action, including the time limits for filing any motions or applications for
22 extension of time pursuant to applicable law.
23 2.9 In-House Counsel: attorneys who are employees of a party to this
24 Action. In-House Counsel does not include Outside Counsel of Record or any
25 other outside counsel.
26 2.10 Non-Party: any natural person, partnership, corporation, association, or
27 other legal entity not named as a Party to this action.
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1 2.11 Outside Counsel of Record: attorneys who are not employees of a
2 party to this Action but are retained to represent or advise a party to this Action
3 and have appeared in this Action on behalf of that party or are affiliated with a law
4 firm which has appeared on behalf of that party, and includes support staff.
5 2.12 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).
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2.13 Producing Party: a Party or Non-Party that produces Disclosure or
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Discovery Material in this Action.
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2.14 Professional Vendors: persons or entities that provide litigation-
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support 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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2.15 Protected Material: any Disclosure or Discovery Material that is
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designated as “CONFIDENTIAL.”
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2.16 Receiving Party: a Party that receives Disclosure or Discovery
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Material from a Producing Party.
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3. SCOPE
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20 The protections conferred by this Stipulation and Order cover not only
21 Protected Material (as defined above), but also (1) any information copied or
22 extracted from Protected Material; (2) all copies, excerpts, summaries, or
23 compilations of Protected Material; and (3) any testimony, conversations, or
24 presentations by Parties or their Counsel that might reveal Protected Material. Any
25 use of Protected Material at trial shall be governed by the orders of the trial judge.
26 This Stipulated Protective Order does not govern the use of Protected Material at
27 trial.
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1 4. TRIAL AND DURATION
2 The terms of this Stipulated Protective Order apply through Final
3 Disposition of the Action. Once a case proceeds to trial, information that was
4 designated as CONFIDENTIAL or maintained pursuant to this Stipulated
5 Protective Order and used or introduced as an exhibit at trial becomes public and
6
will be presumptively available to all members of the public, including the press,
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unless compelling reasons supported by specific factual findings to proceed
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otherwise are made to the trial judge in advance of the trial. See Kamakana, 447
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F.3d at 1180–81 (distinguishing “good cause” showing for sealing documents
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produced in discovery from “compelling reasons” standard when merits-related
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documents are part of court record). Accordingly, for such materials, the terms of
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this Stipulated Protective Order do not extend beyond the commencement of the
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trial. Even after Final Disposition of this litigation, the confidentiality obligations
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imposed by this Stipulated Protective Order shall remain in effect until a
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Designating Party agrees otherwise in writing or a court order otherwise directs.
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5. DESIGNATING PROTECTED MATERIAL
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5.1 Exercise of Restraint and Care in Designating Material for
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Protection. Each Party or Non-Party that designates information or items for
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20 protection under this Order must take care to limit any such designation to specific
21 material that qualifies under the appropriate standards. The Designating Party must
22 designate for protection only those parts of material, documents, items, or oral or
23 written communications that qualify so that other portions of the material,
24 documents, items, or communications for which protection is not warranted are not
25 swept unjustifiably within the ambit of this Order. Mass, indiscriminate, or
26 routinized designations are prohibited. Designations that are shown to be clearly
27 unjustified or that have been made for an improper purpose (e.g., to unnecessarily
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1 encumber the case development process or to impose unnecessary expenses and
2 burdens on other parties) may expose the Designating Party to sanctions. If it
3 comes to a Designating Party’s attention that information or items that it
4 designated for protection do not qualify for protection, that Designating Party must
5 promptly notify all other Parties that it is withdrawing the inapplicable designation.
6
5.2 Manner and Timing of Designations. Except as otherwise provided in
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this Stipulated Protective Order (see, e.g., second paragraph of section 5.2(a)
8
below), or as otherwise stipulated or ordered, Disclosure or Discovery Material
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that qualifies for protection under this Stipulated Protective Order must be clearly
10
so designated before the material is disclosed or produced. Designation in
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conformity with this Stipulated Protective Order requires:
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(a) for information in documentary form (e.g., paper or electronic
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documents, but excluding transcripts of depositions or other pretrial or trial
14
proceedings), that the Producing Party affix at a minimum, the legend
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“CONFIDENTIAL” to each page that contains protected material. If only a
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portion or portions of the material on a page qualifies for protection, the
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Producing Party also must clearly identify the protected portion(s) (e.g., by
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making appropriate markings in the margins). A Party or Non-Party that
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20 makes original documents available for inspection need not designate them
21 for protection until after the inspecting Party has indicated which documents
22 it would like copied and produced. During the inspection and before the
23 designation, all of the material made available for inspection shall be
24 deemed CONFIDENTIAL. After the inspecting Party has identified the
25 documents it wants copied and produced, the Producing Party must
26 determine which documents, or portions thereof, qualify for protection under
27 this Stipulated Protective Order. Then, before producing the specified
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1 documents, the Producing Party must affix the “CONFIDENTIAL” legend
2 to each page that contains Protected Material. If only a portion or portions of
3 the material on a page qualifies for protection, the Producing Party also must
4 clearly identify the protected portion(s) (e.g., by making appropriate
5 markings in the margins).
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(b) for testimony given in depositions that the Designating Party
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identify the Disclosure or Discovery Material on the record, before the close
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of the deposition all protected testimony.
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(c) for information produced in some form other than documentary
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and for any other tangible items, that the Producing Party affix in a
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prominent place on the exterior of the container or containers in which the
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information is stored the “CONFIDENTIAL” legend. If only a portion or
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portions of the information warrants protection, the Producing Party, to the
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extent practicable, shall identify the protected portion(s).
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5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
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failure to designate qualified information or items does not, standing alone, waive
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the Designating Party’s right to secure protection under this Order for such
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material. Upon timely correction of a designation, the Receiving Party must make
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20 reasonable efforts to assure that the material is treated in accordance with the
21 provisions of this Stipulated Protective Order.
22 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
23 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
24 designation of confidentiality at any time that is consistent with the court’s
25 Scheduling Order.
26 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
27 resolution process under Local Rule 37.1.
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1 6.3 Burden of Persuasion. The burden of persuasion in any such challenge
2 proceeding shall be on the Designating Party. Frivolous challenges, and those
3 made for an improper purpose (e.g., to harass or impose unnecessary expenses and
4 burdens on other parties) may expose the Challenging Party to sanctions. Unless
5 the Designating Party has waived or withdrawn the confidentiality designation, all
6
parties shall continue to afford the material in question the level of protection to
7
which it is entitled under the Producing Party’s designation until the court rules on
8
the challenge.
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7. ACCESS TO AND USE OF PROTECTED MATERIAL
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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
12
Action only for prosecuting, defending, or attempting to settle this Action. Such
13
Protected Material may be disclosed only to the categories of persons and under
14
the conditions described in this Order. When the Action reaches a Final
15
Disposition, a Receiving Party must comply with the provisions of section 13
16
below. Protected Material must be stored and maintained by a Receiving Party at a
17
location and in a secure manner that ensures that access is limited to the persons
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authorized under this Stipulated Protective Order.
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20 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
21 otherwise ordered by the court or permitted in writing by the Designating Party, a
22 Receiving Party may disclose any information or item designated
23 “CONFIDENTIAL” only:
24 (a) to the Receiving Party’s Outside Counsel of Record in this Action,
25 as well as employees of said Outside Counsel of Record to whom it is
26 reasonably necessary to disclose the information for this Action;
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1 (b) to the officers, directors, and employees (including House
2 Counsel) of the Receiving Party to whom disclosure is reasonably necessary
3 for this Action;
4 (c) to Experts (as defined in this Order) of the Receiving Party to
5 whom disclosure is reasonably necessary for this Action and who have
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signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
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(d) to the court and its personnel;
8
(e) to court reporters and their staff;
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(f) to professional jury or trial consultants, mock jurors, and
10
Professional Vendors to whom disclosure is reasonably necessary for this
11
Action and who have signed the “Acknowledgment and Agreement to Be
12
Bound” (Exhibit A);
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(g) to the author or recipient of a document containing the information
14
or a custodian or other person who otherwise possessed or knew the
15
information;
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(h) during their depositions, to witnesses, and attorneys for witnesses,
17
in the Action to whom disclosure is reasonably necessary, provided: (1) the
18
deposing party requests that the witness sign the “Acknowledgment and
19
20 Agreement to Be Bound” (Exhibit A); and (2) the witness will not be
21 permitted to keep any confidential information unless they sign the
22 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless
23 otherwise agreed by the Designating Party or ordered by the court. Pages of
24 transcribed deposition testimony or exhibits to depositions that reveal
25 Protected Material may be separately bound by the court reporter and may
26 not be disclosed to anyone except as permitted under this Stipulated
27 Protective Order; and (i) to any mediator or settlement officer, and their
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1 supporting personnel, mutually agreed upon by any of the parties engaged in
2 settlement discussions.
3 7.3 Use of “CONFIDENTIAL” Information at Trial or Hearing.
4 Nothing in this Order will be construed to affect the use of any document, material,
5 or information at any trial or hearing. A Party that intends to present, or that
6
anticipates that another Party may present, Confidential Information at a hearing or
7
trial must bring that issue to the attention of the Court and the other Parties without
8
disclosing the Confidential Information. The Court may thereafter make such
9
orders as are necessary to govern the use of such documents or information at the
10
hearing or trial.
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8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
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IN OTHER LITIGATION
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If a Party is served with a subpoena or a court order issued in other litigation
14
that compels disclosure of any information or items designated in this Action as
15
“CONFIDENTIAL,” that Party must: (a) promptly notify in writing the
16
Designating Party. Such notification shall include a copy of the subpoena or court
17
order; (b) promptly notify in writing the party who caused the subpoena or order to
18
issue in the other litigation that some or all of the material covered by the subpoena
19
20 or order is subject to this Protective Order. Such notification shall include a copy
21 of this Stipulated Protective Order; and (c) cooperate with respect to all reasonable
22 procedures sought to be pursued by the Designating Party whose Protected
23 Material may be affected. If the Designating Party timely seeks a protective order,
24 the Party served with the subpoena or court order shall not produce any
25 information designated in this action as “CONFIDENTIAL” before a
26 determination by the court from which the subpoena or order issued, unless the
27 Party has obtained the Designating Party’s permission. The Designating Party shall
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1 bear the burden and expense of seeking protection in that court of its confidential
2 material and nothing in these provisions should be construed as authorizing or
3 encouraging a Receiving Party in this Action to disobey a lawful directive from
4 another court.
5 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
6
PRODUCED IN THIS LITIGATION
7
9.1 Application. The terms of this Stipulated Protective Order are applicable
8
to information produced by a Non-Party in this Action and designated as
9
“CONFIDENTIAL.” Such information produced by Non-Parties in connection
10
with this litigation is protected by the remedies and relief provided by this Order.
11
Nothing in these provisions should be construed as prohibiting a Non-Party from
12
seeking additional protections.
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9.2 Notification. In the event that a Party is required, by a valid discovery
14
request, to produce a Non-Party’s confidential information in its possession, and
15
the Party is subject to an agreement with the Non-Party not to produce the Non-
16
Party’s confidential information, then the Party shall:
17
(a) promptly notify in writing the Requesting Party and the Non-Party
18
that some or all of the information requested is subject to a confidentiality
19
20 agreement with a Non-Party;
21 (b) make the information requested available for inspection by the
22 Non-Party, if requested.
23 9.3 Conditions of Production. If the Non-Party fails to seek a protective
24 order from this court within 14 days of receiving the notice and accompanying
25 information, the Receiving Party may produce the Non-Party’s confidential
26 information responsive to the discovery request. If the Non-Party timely seeks a
27 protective order, the Receiving Party shall not produce any information in its
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1 possession or control that is subject to the confidentiality agreement with the Non-
2 Party before a determination by the court. Absent a court order to the contrary, the
3 Non-Party shall bear the burden and expense of seeking protection in this court of
4 its Protected Material.
5 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
6
If a Receiving Party learns that, by inadvertence or otherwise, it has
7
disclosed Protected Material to any person or in any circumstance not authorized
8
under this Stipulated Protective Order, the Receiving Party must immediately (a)
9
notify in writing the Designating Party of the unauthorized disclosures, (b) use its
10
best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform
11
the person or persons to whom unauthorized disclosures were made of all the terms
12
of this Order, and (d) request such person or persons to execute the
13
“Acknowledgment and Agreement to Be Bound” (Exhibit A).
14
11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
15
PROTECTED MATERIAL
16
When a Producing Party gives notice to Receiving Parties that certain
17
inadvertently produced material is subject to a claim of privilege or other
18
protection, the obligations of the Receiving Parties are those set forth in Rule
19
20 26(b)(5)(B) of the Federal Rules of Civil Procedure. This provision is not intended
21 to modify whatever procedure may be established in an e-discovery order that
22 provides for production without prior privilege review. Pursuant to Rules 502(d)
23 and (e) of the Federal Rules of Evidence, insofar as the parties reach an agreement
24 on the effect of disclosure of a communication or information covered by the
25 attorney-client privilege or work product protection, the parties may incorporate
26 their agreement in the stipulated protective order submitted to the court.
27
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1 12. MISCELLANEOUS
2 12.1 Right to Further Relief. Nothing in this Stipulated Protective Order
3 abridges the right of any 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 Stipulated Protective Order no Party waives any right it otherwise would have to
6
object to disclosing or producing any information or item on any ground not
7
addressed in this Stipulated Protective Order. Similarly, no Party waives any right
8
to object on any ground to use in evidence of any of the material covered by this
9
Stipulated Protective Order.
10
12.3 Filing Protected Material. A Party that seeks to file under seal any
11
Protected Material must comply with Local Rule 79-5. Protected Material may
12
only be filed under seal pursuant to a court order authorizing the sealing of the
13
specific Protected Material at issue. If a Party's request to file Protected Material
14
under seal is denied by the court, then the Receiving Party may file the information
15
in the public record unless otherwise instructed by the court.
16
13. FINAL DISPOSITION
17
After the Final Disposition of this Action, as defined in paragraph 4, within
18
19
60 days of a written request by the Designating Party, each Receiving Party must
20 return all Protected Material to the Producing Party or destroy such material. As
21 used in this subdivision, “all Protected Material” includes all copies, abstracts,
22 compilations, summaries, and any other format reproducing or capturing any of the
23 Protected Material. Whether the Protected Material is returned or destroyed, the
24 Receiving Party must submit a written certification to the Producing Party (and, if
25 not the same person or entity, to the Designating Party) by the 60 day deadline that
26 (1) identifies (by category, where appropriate) all the Protected Material that was
27 returned or destroyed and (2) affirms that the Receiving Party has not retained any
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1 | copies, abstracts, compilations, summaries or any other format reproducing or
2 | capturing any of the Protected Material. Notwithstanding this provision, Counsel is
3 | entitled to retain an archival copy of all pleadings, motion papers, trial, deposition,
4 | and hearing transcripts, legal memoranda, correspondence, deposition and trial
5 exhibits, expert reports, attorney work product, and consultant and expert work
6 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.
° 14. VIOLATION
" Any violation of this Stipulated Protective Order may be punished by any
and all appropriate measures including, without limitation, contempt proceedings
3 and/or monetary sanctions.
'* IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
15
16
17 | DATED: May 16, 2025
/s/ Dana Oliver /s/ Anthony I Paronich
19 Attorney(s) for Plaintiff Attorney(s) for Plaintiff
DATED: May 16, 2025
| /s/ Barry Goheen /s/ Brandon T. Willenberg
93 | Attorney(s) for Defendant Attorney(s) for Defendant
24 | FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
25
26 | paTEp: May 20, 2025 i j / Yih
27 David T. Bristow
3g United States Magistrate Judge
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STIPULATED PROTECTIVE ORDER
EXHIBIT A
1
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND BY
3 PROTECTIVE ORDER
4
The undersigned acknowledges that he/she has read the Protective Order attached
5
hereto, understands the terms thereof, and agrees to be bound by its terms. The
6
undersigned understands that the terms of the Protective Order obligate him/her to
7
use documents designated CONFIDENTIAL in accordance with the Order, and not
8
to disclose any such documents or information derived directly therefrom to any
9
other person, firm or concern. The undersigned acknowledges that violation of the
10
Protective Order may result in penalties for contempt of court.
11
12
13
_________________________________
14
Printed Name
15
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17 Date: _____________________
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