The opinion
1 MITCHELL SILBERBERG & KNUPP LLP
ELAINE K. KIM (SBN 242066)
2 ekk@msk.com
DEBRA URTEAGA (SBN 278744)
3 dxu@msk.com
2049 Century Park East, 18th Floor
4 Los Angeles, CA 90067-3120
Telephone: (310) 312-2000
5 Facsimile: (310) 312-3100
6 Attorneys for Defendant
NBCUNIVERSAL MEDIA, LLC
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UNITED STATES DISTRICT COURT
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CENTRAL DISTRICT OF CALIFORNIA – WESTERN DIVISION
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PABLO CANALES, CASE NO. 2:26-cv-04055-SVW-DMK
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Plaintiff, Magistrate Judge Diana M. Kwok
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v. [PROPOSED] STIPULATED
14 PROTECTIVE ORDER1
NBCUNIVERSAL MEDIA, LLC and
15 DOES 1 through 100, Inclusive,
16 Defendants.
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1 This Stipulated Protective Order is substantially based on the model protective
order provided under Magistrate Judge Diana M. Kwok’s Procedures as of March
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1 1. INTRODUCTION
2 1.1 Purposes and Limitations. Discovery in this action is likely to involve
3 production of confidential, proprietary, or private information for which special
4 protection from public disclosure and from use for any purpose other than
5 prosecuting this litigation may be warranted. Accordingly, the parties hereby
6 stipulate to and petition the court to enter the following Stipulated Protective Order.
7 The parties acknowledge that this Order does not confer blanket protections on all
8 disclosures or responses to discovery and that the protection it affords from public
9 disclosure and use extends only to the limited information or items that are entitled
10 to confidential treatment under the applicable legal principles.
11 1.2 Good Cause Statement. This action is likely to involve trade secrets,
12 customer and pricing lists and other valuable research, development, commercial,
13 financial, technical and/or proprietary information for which special protection from
14 public disclosure and from use for any purpose other than prosecution of this action
15 is warranted. Such confidential and proprietary materials and information consist
16 of, among other things, confidential business or financial information, information
17 regarding confidential business practices, or other confidential research,
18 development, or commercial information (including information implicating privacy
19 rights of third parties), information otherwise generally unavailable to the public, or
20 which may be privileged or otherwise protected from disclosure under state or
21 federal statutes, court rules, case decisions, or common law. Accordingly, to
22 expedite the flow of information, to facilitate the prompt resolution of disputes over
23 confidentiality of discovery materials, to adequately protect information the parties
24 are entitled to keep confidential, to ensure that the parties are permitted reasonable
25 necessary uses of such material in preparation for and in the conduct of trial, to
26 address their handling at the end of the litigation, and serve the ends of justice, a
27 protective order for such information is justified in this matter. It is the intent of the
28 parties that information will not be designated as confidential for tactical reasons
1 and that nothing be so designated without a good faith belief that it has been
2 maintained in a confidential, non-public manner, and there is good cause why it
3 should not be part of the public record of this case.
4 1.3 Acknowledgment of Procedure for Filing Under Seal. The parties
5 further acknowledge, as set forth in Section 12.3, below, that this Stipulated
6 Protective Order does not entitle them to file confidential information under seal;
7 Local Rule 79-5 sets forth the procedures that must be followed and the standards
8 that will be applied when a party seeks permission from the court to file material
9 under seal.
10 There is a strong presumption that the public has a right of access to judicial
11 proceedings and records in civil cases. In connection with non-dispositive motions,
12 good cause must be shown to support a filing under seal. See Kamakana v. City
13 and Cnty. of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of
14 Byrd v. Gen. Motors Corp., 307 F.3d 1206, 1210–11 (9th Cir. 2002), Makar-
15 Welbon v. Sony Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated
16 protective orders require good cause showing), and a specific showing of good
17 cause or compelling reasons with proper evidentiary support and legal justification,
18 must be made with respect to Protected Material that a party seeks to file under
19 seal. The parties’ mere designation of Disclosure or Discovery Material as
20 CONFIDENTIAL does not—without the submission of competent evidence by
21 declaration, establishing that the material sought to be filed under seal qualifies as
22 confidential, privileged, or otherwise protectable—constitute good cause.
23 Further, if a party requests sealing related to a dispositive motion or trial,
24 then compelling reasons, not only good cause, for the sealing must be shown, and
25 the relief sought shall be narrowly tailored to serve the specific interest to be
26 protected. See Pintos v. Pac. Creditors Ass’n, 605 F.3d 665, 677–79 (9th Cir.
27 2010). For each item or type of information, document, or thing sought to be filed
28 or introduced under seal in connection with a dispositive motion or trial, the party
1 seeking protection must articulate compelling reasons, supported by specific facts
2 and legal justification, for the requested sealing order. Again, competent evidence
3 supporting the application to file documents under seal must be provided by
4 declaration.
5 Any document that is not confidential, privileged, or otherwise protectable in
6 its entirety will not be filed under seal if the confidential portions can be redacted.
7 If documents can be redacted, then a redacted version for public viewing, omitting
8 only the confidential, privileged, or otherwise protectable portions of the document,
9 shall be filed. Any application that seeks to file documents under seal in their
10 entirety should include an explanation of why redaction is not feasible.
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12 2. DEFINITIONS
13 2.1 Action: This pending federal lawsuit.
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
17 (regardless of how it is generated, stored or maintained) or tangible things
18 that qualify for protection under Rule 26(c) of the Federal Rules of Civil
19 Procedure, and as specified above in the Good Cause Statement.
20 2.4 Counsel: Outside Counsel of Record and House Counsel (as well
21 as their support staff).
22 2.5 Designating Party: a Party or Non-Party that designates
23 information or items that it produces in disclosures or in responses to
24 discovery as “CONFIDENTIAL.”
25 2.6 Disclosure or Discovery Material: all items or information,
26 regardless of the medium or manner in which it is generated, stored, or
27 maintained (including, among other things, testimony, transcripts, and
28 tangible things), that are produced or generated in disclosures or responses to
1 discovery in this matter.
2 2.7 Expert: a person with specialized knowledge or experience in a
3 matter pertinent to the litigation who has been retained by a Party or its
4 counsel to serve as an expert witness or as a consultant in this Action.
5 2.8 Final Disposition: the later of (1) dismissal of all claims and
6 defenses in this Action, with or without prejudice; and (2) final judgment
7 herein after the completion and exhaustion of all appeals, rehearings,
8 remands, trials, or reviews of this Action, including the time limits for filing
9 any motions or applications for extension of time pursuant to applicable law.
10 2.9 In-House Counsel: attorneys who are employees of a party to this
11 Action. In-House Counsel does not include Outside Counsel of Record or
12 any other outside counsel.
13 2.10 Non-Party: any natural person, partnership, corporation,
14 association, or other legal entity not named as a Party to this action.
15 2.11 Outside Counsel of Record: attorneys who are not employees of
16 a party to this Action but are retained to represent or advise a party to this
17 Action and have appeared in this Action on behalf of that party or are
18 affiliated with a law firm which has appeared on behalf of that party, and
19 includes support staff.
20 2.12 Party: any party to this Action, including all of its officers,
21 directors, employees, consultants, retained experts, and Outside Counsel of
22 Record (and their support staffs).
23 2.13 Producing Party: a Party or Non-Party that produces Disclosure
24 or Discovery Material in this Action.
25 2.14 Professional Vendors: persons or entities that provide litigation-
26 support services (e.g., photocopying, videotaping, translating, preparing
27 exhibits or demonstrations, and organizing, storing, or retrieving data in any
28 form or medium) and their employees and subcontractors.
1 2.15 Protected Material: any Disclosure or Discovery Material that is
2 designated as “CONFIDENTIAL.”
3 2.16 Receiving Party: a Party that receives Disclosure or Discovery
4 Material from a Producing Party.
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6 3. SCOPE
7 The protections conferred by this Stipulation and Order cover not only
8 Protected Material (as defined above), but also (1) any information copied or
9 extracted from Protected Material; (2) all copies, excerpts, summaries, or
10 compilations of Protected Material; and (3) any testimony, conversations, or
11 presentations by Parties or their Counsel that might reveal Protected Material.
12 Any use of Protected Material at trial shall be governed by the orders of the
13 trial judge. This Stipulated Protective Order does not govern the use of Protected
14 Material at trial.
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16 4. TRIAL AND DURATION
17 The terms of this Stipulated Protective Order apply through Final Disposition
18 of the Action.
19 Once a case proceeds to trial, information that was designated as
20 CONFIDENTIAL or maintained pursuant to this Stipulated Protective Order and
21 used or introduced as an exhibit at trial becomes public and will be presumptively
22 available to all members of the public, including the press, unless compelling
23 reasons supported by specific factual findings to proceed otherwise are made to the
24 trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180–81
25 (distinguishing “good cause” showing for sealing documents produced in discovery
26 from “compelling reasons” standard when merits-related documents are part of
27 court record). Accordingly, for such materials, the terms of this Stipulated
28 Protective Order do not extend beyond the commencement of the trial.
1 Even after Final Disposition of this litigation, the confidentiality obligations
2 imposed by this Stipulated Protective Order shall remain in effect until a
3 Designating Party agrees otherwise in writing or a court order otherwise directs.
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5 5. DESIGNATING PROTECTED MATERIAL
6 5.1 Exercise of Restraint and Care in Designating Material for Protection.
7 Each Party or Non-Party that designates information or items for protection under
8 this Order must take care to limit any such designation to specific material that
9 qualifies under the appropriate standards. The Designating Party must designate for
10 protection only those parts of material, documents, items, or oral or written
11 communications that qualify so that other portions of the material, documents,
12 items, or communications for which protection is not warranted are not swept
13 unjustifiably within the ambit of this Order.
14 Mass, indiscriminate, or routinized designations are prohibited. Designations
15 that are shown to be clearly unjustified or that have been made for an improper
16 purpose (e.g., to unnecessarily encumber the case development process or to
17 impose unnecessary expenses and burdens on other parties) may expose the
18 Designating Party to sanctions.
19 If it comes to a Designating Party’s attention that information or items that it
20 designated for protection do not qualify for protection, that Designating Party must
21 promptly notify all other Parties that it is withdrawing the inapplicable designation.
22 5.2 Manner and Timing of Designations. Except as otherwise provided in
23 this Stipulated Protective Order (see, e.g., second paragraph of section 5.2(a)
24 below), or as otherwise stipulated or ordered, Disclosure or Discovery Material that
25 qualifies for protection under this Stipulated Protective Order must be clearly so
26 designated before the material is disclosed or produced.
27 Designation in conformity with this Stipulated Protective Order requires:
28 (a) for information in documentary form (e.g., paper or electronic
1 documents, but excluding transcripts of depositions or other pretrial or trial
2 proceedings), that the Producing Party affix at a minimum, the legend
3 “CONFIDENTIAL” to each page that contains protected material. If only a
4 portion or portions of the material on a page qualifies for protection, the Producing
5 Party also must clearly identify the protected portion(s) (e.g., by making
6 appropriate markings in the margins).
7 A Party or Non-Party that makes original documents available for inspection
8 need not designate them for protection until after the inspecting Party has indicated
9 which documents it would like copied and produced. During the inspection and
10 before the designation, all of the material made available for inspection shall be
11 deemed CONFIDENTIAL. After the inspecting Party has identified the documents
12 it wants copied and produced, the Producing Party must determine which
13 documents, or portions thereof, qualify for protection under this Stipulated
14 Protective Order. Then, before producing the specified documents, the Producing
15 Party must affix the “CONFIDENTIAL” legend to each page that contains
16 Protected Material. If only a portion or portions of the material on a page qualifies
17 for protection, the Producing Party also must clearly identify the protected
18 portion(s) (e.g., by making appropriate markings in the margins).
19 (b) for testimony given in depositions that the Designating Party identify
20 the Disclosure or Discovery Material on the record before the close of the
21 deposition or within 7 days of the Designating Party’s receipt of the final transcript.
22 (c) for information produced in some form other than documentary and
23 for any other tangible items, that the Producing Party affix in a prominent place on
24 the exterior of the container or containers in which the information is stored the
25 “CONFIDENTIAL” legend. If only a portion or portions of the information
26 warrants protection, the Producing Party, to the extent practicable, shall identify the
27 protected portion(s).
28 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
1 failure to designate qualified information or items does not, standing alone, waive
2 the Designating Party’s right to secure protection under this Order for such material.
3 Upon timely correction of a designation, the Receiving Party must make reasonable
4 efforts to assure that the material is treated in accordance with the provisions of this
5 Stipulated Protective Order.
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7 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
8 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
9 designation of confidentiality at any time that is consistent with the court’s
10 Scheduling Order.
11 6.2 Meet and Confer. The Challenging Party shall initiate the
12 dispute resolution process under Local Rule 37.1 et seq.
13 6.3 The burden of persuasion in any such challenge proceeding
14 shall be on the Designating Party. Frivolous challenges, and those made for
15 an improper purpose (e.g., to harass or impose unnecessary expenses and
16 burdens on other parties) may expose the Challenging Party to sanctions.
17 Unless the Designating Party has waived or withdrawn the confidentiality
18 designation, all parties shall continue to afford the material in question the
19 level of protection to which it is entitled under the Producing Party’s
20 designation until the court rules on the challenge.
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22 7. ACCESS TO AND USE OF PROTECTED MATERIAL
23 7.1 Basic Principles. A Receiving Party may use Protected
24 Material that is disclosed or produced by another Party or by a Non-Party in
25 connection with this Action only for prosecuting, defending, or attempting
26 to settle this Action. Such Protected Material may be disclosed only to the
27 categories of persons and under the conditions described in this Order.
28 When the Action reaches a Final Disposition, a Receiving Party must
1 comply with the provisions of section 13 below.
2 Protected Material must be stored and maintained by a Receiving Party at a
3 location and in a secure manner that ensures that access is limited to the persons
4 authorized under this Stipulated Protective Order.
5 7.2 Disclosure of “CONFIDENTIAL” Information or Items.
6 Unless otherwise ordered by the court or permitted in writing by the
7 Designating Party, a Receiving Party may disclose any information or item
8 designated “CONFIDENTIAL” only:
9 (a) to the Receiving Party’s Outside Counsel of Record in this Action, as
10 well as employees of said Outside Counsel of Record to whom it is reasonably
11 necessary to disclose the information for this Action;
12 (b) to the officers, directors, and employees (including House Counsel) of
13 the Receiving Party to whom disclosure is reasonably necessary for this Action;
14 (c) to Experts (as defined in this Order) of the Receiving Party to whom
15 disclosure is reasonably necessary for this Action and who have signed the
16 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
17 (d) to the court and its personnel;
18 (e) to court reporters and their staff;
19 (f) to professional jury or trial consultants, mock jurors, and Professional
20 Vendors to whom disclosure is reasonably necessary for this Action and who have
21 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
22 (g) to the author or recipient of a document containing the information or
23 a custodian or other person who otherwise possessed or knew the information;
24 (h) during their depositions, to witnesses, and attorneys for witnesses, in
25 the Action to whom disclosure is reasonably necessary, provided: (1) the deposing
26 party requests that the witness sign the “Acknowledgment and Agreement to Be
27 Bound” (Exhibit A); and (2) the witness will not be permitted to keep any
28 confidential information unless they sign the “Acknowledgment and Agreement to
1 Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party or
2 ordered by the court. Pages of transcribed deposition testimony or exhibits to
3 depositions that reveal Protected Material may be separately bound by the court
4 reporter and may not be disclosed to anyone except as permitted under this
5 Stipulated Protective Order; and
6 (i) to any mediator or settlement officer, and their supporting personnel,
7 mutually agreed upon by any of the parties engaged in settlement discussions.
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9 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
10 PRODUCED IN OTHER LITIGATION
11 If a Party is served with a subpoena or a court order issued in other litigation
12 that compels disclosure of any information or items designated in this Action as
13 “CONFIDENTIAL,” that Party must:
14 (a) promptly notify in writing the Designating Party. Such notification
15 shall include a copy of the subpoena or court order;
16 (b) promptly notify in writing the party who caused the subpoena or order
17 to issue in the other litigation that some or all of the material covered by the
18 subpoena or order is subject to this Protective Order. Such notification shall include
19 a copy of this Stipulated Protective Order; and
20 (c) cooperate with respect to all reasonable procedures sought to be
21 pursued by the Designating Party whose Protected Material may be affected.
22 If the Designating Party timely seeks a protective order, the Party served
23 with the subpoena or court order shall not produce any information designated in
24 this action as “CONFIDENTIAL” before a determination by the court from which
25 the subpoena or order issued, unless the Party has obtained the Designating Party’s
26 permission. The Designating Party shall bear the burden and expense of seeking
27 protection in that court of its confidential material and nothing in these provisions
28 should be construed as authorizing or encouraging a Receiving Party in this Action
1 to disobey a lawful directive from another court.
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3 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
4 PRODUCED IN THIS LITIGATION
5 9.1 Application. The terms of this Stipulated Protective Order are
6 applicable to information produced by a Non-Party in this Action and designated as
7 “CONFIDENTIAL.” Such information produced by Non-Parties in connection with
8 this litigation is protected by the remedies and relief provided by this Order.
9 Nothing in these provisions should be construed as prohibiting a Non-Party from
10 seeking additional protections.
11 9.2 Notification. In the event that a Party is required, by a valid discovery
12 request, to produce a Non-Party’s confidential information in its possession, and the
13 Party is subject to an agreement with the Non-Party not to produce the Non-
14 Party’s confidential information, then the Party shall:
15 (a) promptly notify in writing the Requesting Party and the Non-Party
16 that some or all of the information requested is subject to a confidentiality
17 agreement with a Non-Party;
18 (b) make the information requested available for inspection by the Non-
19 Party, if requested.
20 9.3 Conditions of Production. If the Non-Party fails to seek a protective
21 order from this court within 14 days of receiving the notice and accompanying
22 information, the Receiving Party may produce the Non-Party’s confidential
23 information responsive to the discovery request. If the Non-Party timely seeks a
24 protective order, the Receiving Party shall not produce any information in its
25 possession or control that is subject to the confidentiality agreement with the Non-
26 Party before a determination by the court. Absent a court order to the contrary, the
27 Non-Party shall bear the burden and expense of seeking protection in this court of its
28 Protected Material.
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2 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
3 If a Receiving Party learns that, by inadvertence or otherwise, it has
4 disclosed Protected Material to any person or in any circumstance not authorized
5 under this Stipulated Protective Order, the Receiving Party must immediately (a)
6 notify in writing the Designating Party of the unauthorized disclosures, (b) use its
7 best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform
8 the person or persons to whom unauthorized disclosures were made of all the terms
9 of this Order, and (d) request such person or persons to execute the
10 “Acknowledgment and Agreement to Be Bound” (Exhibit A).
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12 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
13 PROTECTED MATERIAL
14 When a Producing Party gives notice to Receiving Parties that certain
15 inadvertently produced material is subject to a claim of privilege or other
16 protection, the obligations of the Receiving Parties are those set forth in Rule
17 26(b)(5)(B) of the Federal Rules of Civil Procedure. This provision is not intended
18 to modify whatever procedure may be established in an e-discovery order that
19 provides for production without prior privilege review. Pursuant to Rules 502(d)
20 and (e) of the Federal Rules of Evidence, insofar as the parties reach an agreement
21 on the effect of disclosure of a communication or information covered by the
22 attorney-client privilege or work product protection, the parties may incorporate
23 their agreement in the stipulated protective order submitted to the court.
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25 12. MISCELLANEOUS
26 12.1 Right to Further Relief. Nothing in this Stipulated Protective
27 Order abridges the right of any person to seek its modification by the court
28 in the future.
1 12.2 Right to Assert Other Objections. By stipulating to the entry of
2 this Stipulated Protective Order no Party waives any right it otherwise
3 would have to object to disclosing or producing any information or item on
4 any ground not addressed in this Stipulated Protective Order. Similarly, no
5 Party waives any right to object on any ground to use in evidence of any of
6 the material covered by this Stipulated Protective Order.
7 12.3 Filing Protected Material. A Party that seeks to file under seal
8 any Protected Material must comply with Local Rule 79-5. Protected
9 Material may only be filed under seal pursuant to a court order authorizing
10 the sealing of the specific Protected Material at issue. If a Party's request to
11 file Protected Material under seal is denied by the court, then the Receiving
12 Party may file the information in the public record unless otherwise
13 instructed by the court.
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15 13. FINAL DISPOSITION
16 After the Final Disposition of this Action, as defined in paragraph 4, within
17 60 days of a written request by the Designating Party, each Receiving Party must
18 return all Protected Material to the Producing Party or destroy such material. As
19 used in this subdivision, “all Protected Material” includes all copies, abstracts,
20 compilations, summaries, and any other format reproducing or capturing any of the
21 Protected Material. Whether the Protected Material is returned or destroyed, the
22 Receiving Party must submit a written certification to the Producing Party (and, if
23 not the same person or entity, to the Designating Party) by the 60 day deadline that
24 (1) identifies (by category, where appropriate) all the Protected Material that was
25 returned or destroyed and (2) affirms that the Receiving Party has not retained any
26 copies, abstracts, compilations, summaries or any other format reproducing or
27 capturing any of the Protected Material. Notwithstanding this provision, Counsel is
28 entitled to retain an archival copy of all pleadings, motion papers, trial, deposition,
1 | and hearing transcripts, legal memoranda, correspondence, deposition and trial
2 | exhibits, expert reports, attorney work product, and consultant and expert work
3 | product, even if such materials contain Protected Material. Any such archival
4 | copies that contain or constitute Protected Material remain subject to this Protective
5 | Order as set forth in Section 4.
6/14. VIOLATION
7 Any violation of this Stipulated Protective Order may be punished by any
8 | and all appropriate measures including, without limitation, contempt proceedings
9 | and/or monetary sanctions.
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11 | ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD.
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B DATED: May 21, 2026 /s/ Alana Ostrowiecki
14 Attorneys for Plaintiff Pablo Canales
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16 | DATED: May 21, 2026 /s/ Elaine K. Kim
17 Attorneys for Defendant NBCUniversal
18 Media, LLC
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20 | FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
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DATED: 5/22/2026 ay
23 DIANA M. Kwok
24 United States Magistrate Judge
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1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
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I, _______________________________ [print or type full name], of
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___________________________________________________ [print or type
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full address], declare under penalty of perjury that I have read in its entirety and
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understand the Stipulated Protective Order that was issued by the United States
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District Court for the Central District of California on ___________________
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[date] in the case of Pablo Canales v. NBCUniversal Media, LLC, 2:26-cv-
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04055-SVW-DMK. I agree to comply with and to be bound by all the terms of
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this Stipulated Protective Order and I understand and acknowledge that failure to
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so comply could expose me to sanctions and punishment in the nature of
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contempt. I solemnly promise that I will not disclose in any manner any
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information or item that is subject to this Stipulated Protective Order to any
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person or entity except in strict compliance with the provisions of this Order.
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I further agree to submit to the jurisdiction of the United States District
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Court for the Central District of California for the purpose of enforcing the terms
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of this Stipulated Protective Order, even if such enforcement proceedings occur
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after termination of this action. I hereby appoint ________________________
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[print or type full name] of ________________________________________
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[print or type full address and telephone number] as my California agent for
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service of process in connection with this action or any proceedings related to
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enforcement of this Stipulated Protective Order.
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24 Date: ___________________________
25 City and State where sworn and signed: ___________________________
26 Printed name: ___________________________
27 Signature: ___________________________
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