The opinion
1 K&L GATES LLP
Ronie Schmelz (State Bar No. 130798)
2 ronie.schmelz@klgates.com
(310) 552-5002
3 Kevin S. Asfour (State Bar No. 228993)
kevin.asfour@klgates.com
4 (310) 552-5016
Lauren E. Elvick (State Bar No. 348619)
5 lauren.elvick@klgates.com
(310) 552-5049
6 10100 Santa Monica Blvd.
Floor 8
7 Los Angeles, CA 90067
8 Attorneys for Defendant and
Counterclaimant Kissler & Co. Inc.
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10 UNITED STATES DISTRICT COURT
11 CENTRAL DISTRICT OF CALIFORNIA
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SHLA GROUP INC., PARK 2580, INC., Case No. 2:23-cv-07567-TJH-BFM
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Plaintiffs, [Hon. Judge Terry J. Hatter, Jr.]
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v. STIPULATED PROTECTIVE
16 ORDER
KISSLER AND CO. INC.
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Defendant.
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KISSLER AND CO. INC.,
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Counterclaimant,
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v.
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SHLA GROUP INC., PARK 2580, INC.,
23 and GANG HE,
24 Counterclaim Defendants.
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1 I. PURPOSES AND LIMITATIONS
2 Discovery in this action is likely to involve production of confidential,
3 proprietary or private information for which special protection from public disclosure
4 and from use for any purpose other than pursuing this litigation may be warranted.
5 Accordingly, the parties hereby stipulate to and petition the Court to enter the
6 following Stipulated Protective Order. The parties acknowledge that this Order does
7 not confer blanket protections on all disclosures or responses to discovery and that the
8 protection it affords from public disclosure and use extends only to the limited
9 information or items that are entitled to confidential treatment under the applicable
10 legal principles.
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12 II. GOOD CAUSE STATEMENT
13 This action is likely to involve trade secrets, customer and pricing lists, and
14 other valuable research, development, commercial, financial, technical and/or
15 proprietary information for which special protection from public disclosure and from
16 use for any purpose other than prosecution of this action is warranted. Such
17 confidential and proprietary materials and information consist of, among other things,
18 confidential business or financial information, information regarding confidential
19 business practices, or other confidential research, development, or commercial
20 information (including information implicating privacy rights of third parties),
21 information otherwise generally unavailable to the public, or which may be privileged
22 or otherwise protected from disclosure under state or federal statutes, court rules, case
23 decisions, or common law.
24 Accordingly, to expedite the flow of information, to facilitate the prompt
25 resolution of disputes over confidentiality of discovery materials, to adequately protect
26 information the parties are entitled to keep confidential, to ensure that the parties are
27 permitted reasonable necessary uses of such material in preparation for and in the
28 conduct of trial, to address their handling at the end of the litigation, and serve the ends
1 of justice, a protective order for such information is justified in this matter. It is the
2 intent of the parties that information will not be designated as confidential for tactical
3 reasons and that nothing be so designated without a good faith belief that it has been
4 maintained in a confidential, non-public manner, and there is good cause why it should
5 not be part of the public record of this case.
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7 III. ACKNOWLEDGMENT OF UNDER SEAL FILING PROCEDURE
8 The parties further acknowledge, as set forth in Section 14.3, below, that this
9 Stipulated Protective Order does not entitle them to file confidential information under
10 seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the
11 standards that will be applied when a party seeks permission from the court to file
12 material under seal. There is a strong presumption that the public has a right of access
13 to judicial proceedings and records in civil cases. In connection with non-dispositive
14 motions, good cause must be shown to support a filing under seal. See Kamakana v.
15 City and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen.
16 Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony
17 Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective
18 orders require good cause showing), and a specific showing of good cause or
19 compelling reasons with proper evidentiary support and legal justification, must be
20 made with respect to Protected Material that a party seeks to file under seal. The
21 parties’ mere designation of Disclosure or Discovery Material as CONFIDENTIAL
22 does not— without the submission of competent evidence by declaration, establishing
23 that the material sought to be filed under seal qualifies as confidential, privileged, or
24 otherwise protectable—constitute good cause.
25 Further, if a party requests sealing related to a dispositive motion or trial, then
26 compelling reasons, not only good cause, for the sealing must be shown, and the relief
27 sought shall be narrowly tailored to serve the specific interest to be protected. See
28 Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir. 2010). For each item
1 or type of information, document, or thing sought to be filed or introduced under seal,
2 the party seeking protection must articulate compelling reasons, supported by specific
3 facts and legal justification, for the requested sealing order. Again, competent evidence
4 supporting the application to file documents under seal must be provided by
5 declaration.
6 Any document that is not confidential, privileged, or otherwise protectable in its
7 entirety will not be filed under seal if the confidential portions can be redacted. If
8 documents can be redacted, then a redacted version for public viewing, omitting only
9 the confidential, privileged, or otherwise protectable portions of the document, shall be
10 filed. Any application that seeks to file documents under seal in their entirety should
11 include an explanation of why redaction is not feasible.
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13 IV. DEFINITIONS
14 4.1 Action: this pending federal lawsuit.
15 4.2 Challenging Party: a Party or Non-Party that challenges the designation of
16 information or items under this Order.
17 4.3 “CONFIDENTIAL” Information or Items: information (regardless of how it
18 is generated, stored or maintained) or tangible things that qualify for protection under
19 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause
20 Statement.
21 4.4 Counsel: Outside Counsel of Record and House Counsel (as well as their
22 support staff).
23 4.5 Designating Party: a Party or Non-Party that designates information or items
24 that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.”
25 4.6 Disclosure or Discovery Material: all items or information, regardless of the
26 medium or manner in which it is generated, stored, or maintained (including, among
27 other things, testimony, transcripts, and tangible things), that are produced or generated
28 in disclosures or responses to discovery.
1 4.7 Expert: a person with specialized knowledge or experience in a matter
2 pertinent to the litigation who has been retained by a Party or its counsel to serve as an
3 expert witness or as a consultant in this Action.
4 4.8 House Counsel: attorneys who are employees of a party to this Action.
5 House Counsel does not include Outside Counsel of Record or any other outside
6 counsel.
7 4.9 Non-Party: any natural person, partnership, corporation, association or other
8 legal entity not named as a Party to this action.
9 4.10 Outside Counsel of Record: attorneys who are not employees of a party to
10 this Action but are retained to represent a party to this Action and have appeared in this
11 Action on behalf of that party or are affiliated with a law firm that has appeared on
12 behalf of that party, and includes support staff.
13 4.11 Party: any party to this Action, including all of its officers, directors,
14 employees, consultants, retained experts, and Outside Counsel of Record (and their
15 support staffs).
16 4.12 Producing Party: a Party or Non-Party that produces Disclosure or
17 Discovery Material in this Action.
18 4.13 Professional Vendors: persons or entities that provide litigation support
19 services (e.g., photocopying, videotaping, translating, preparing exhibits or
20 demonstrations, and organizing, storing, or retrieving data in any form or medium) and
21 their employees and subcontractors.
22 4.14 Protected Material: any Disclosure or Discovery Material that is designated
23 as “CONFIDENTIAL.”
24 4.15 Receiving Party: a Party that receives Disclosure or Discovery Material
25 from a Producing Party.
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1 V. SCOPE
2 The protections conferred by this Stipulation and Order cover not only Protected
3 Material (as defined above), but also (1) any information copied or extracted from
4 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected
5 Material; and (3) any testimony, conversations, or presentations by Parties or their
6 Counsel that might reveal Protected Material.
7 Any use of Protected Material at trial shall be governed by the orders of the trial judge
8 and other applicable authorities. This Order does not govern the use of Protected
9 Material at trial.
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11 VI. DURATION
12 Once a case proceeds to trial, information that was designated as
13 CONFIDENTIAL or maintained pursuant to this protective order used or introduced as
14 an exhibit at trial becomes public and will be presumptively available to all members
15 of the public, including the press, unless compelling reasons supported by specific
16 factual findings to proceed otherwise are made to the trial judge in advance of the trial.
17 See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” showing for sealing
18 documents produced in discovery from “compelling reasons” standard when merits-
19 related documents are part of court record). Accordingly, the terms of this protective
20 order do not extend beyond the commencement of the trial.
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22 VII. DESIGNATING PROTECTED MATERIAL
23 7.1 Exercise of Restraint and Care in Designating Material for Protection. Each
24 Party or Non-Party that designates information or items for protection under this Order
25 must take care to limit any such designation to specific material that qualifies under the
26 appropriate standards. The Designating Party must designate for protection only those
27 parts of material, documents, items or oral or written communications that qualify so
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1 that other portions of the material, documents, items or communications for which
2 protection is not warranted are not swept unjustifiably within the ambit of this Order.
3 Mass, indiscriminate or routinized designations are prohibited. Designations that
4 are shown to be clearly unjustified or that have been made for an improper purpose
5 (e.g., to unnecessarily encumber the case development process or to impose
6 unnecessary expenses and burdens on other parties) may expose the Designating Party
7 to sanctions.
8 If it comes to a Designating Party’s attention that information or items that it
9 designated for protection do not qualify for protection, that Designating Party must
10 promptly notify all other Parties that it is withdrawing the inapplicable designation.
11 7.2 Manner and Timing of Designations. Except as otherwise provided in this
12 Order, or as otherwise stipulated or ordered, Disclosure of Discovery Material that
13 qualifies for protection under this Order must be clearly so designated before the
14 material is disclosed or produced. Designation in conformity with this Order requires:
15 a) for information in documentary form (e.g., paper or electronic
16 documents, but excluding transcripts of depositions or other pretrial or
17 trial proceedings), that the Producing Party affix at a minimum, the
18 legend “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”),
19 to each page that contains protected material. If only a portion of the
20 material on a page qualifies for protection, the Producing Party also
21 must clearly identify the protected portion(s) (e.g., by making
22 appropriate markings in the margins).
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24 A Party or Non-Party that makes original documents available for
25 inspection need not designate them for protection until after the
26 inspecting Party has indicated which documents it would like copied
27 and produced.
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1 During the inspection and before the designation, all of the material
2 made available for inspection shall be deemed “CONFIDENTIAL.”
3 After the inspecting Party has identified the documents it wants copied
4 and produced, the Producing Party must determine which documents,
5 or portions thereof, qualify for protection under this Order. Then,
6 before producing the specified documents, the Producing Party must
7 affix the “CONFIDENTIAL legend” to each page that contains
8 Protected Material. If only a portion of the material on a page qualifies
9 for protection, the Producing Party also must clearly identify the
10 protected portion(s) (e.g., by making appropriate markings in the
11 margins).
12 b) for testimony given in depositions that the Designating Party identifies
13 the Disclosure or Discovery Material on the record, before the close of
14 the deposition all protected testimony.
15 c) for information produced in some form other than documentary and
16 for any other tangible items, that the Producing Party affix in a
17 prominent place on the exterior of the container or containers in which
18 the information is stored the legend “CONFIDENTIAL.” If only a
19 portion or portions of the information warrants protection, the
20 Producing Party, to the extent practicable, shall identify the protected
21 portion(s).
22 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure
23 to designate qualified information or items does not, standing alone, waive the
24 Designating Party’s right to secure protection under this Order for such material. Upon
25 timely correction of a designation, the Receiving Party must make reasonable efforts to
26 assure that the material is treated in accordance with the provisions of this Order.
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1 VIII. CHALLENGING CONFIDENTIALITY DESIGNATIONS
2 8.1. Timing of Challenges. Any Party or Non-Party may challenge a designation
3 of confidentiality at any time that is consistent with the Court’s Scheduling Order.
4 8.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution
5 process under Local Rule 37-1 et seq.
6 8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a joint
7 stipulation pursuant to Local Rule 37-2.
8 8.4 The burden of persuasion in any such challenge proceeding shall be on the
9 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g.,
10 to harass or impose unnecessary expenses and burdens on other parties) may expose
11 the Challenging Party to sanctions. Unless the Designating Party has waived or
12 withdrawn the confidentiality designation, all parties shall continue to afford the
13 material in question the level of protection to which it is entitled under the Producing
14 Party’s designation until the Court rules on the challenge.
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16 IX. ACCESS TO AND USE OF PROTECTED MATERIAL
17 9.1 Basic Principles. A Receiving Party may use Protected Material that is
18 disclosed or produced by another Party or by a Non-Party in connection with this
19 Action only for prosecuting, defending or attempting to settle this Action. Such
20 Protected Material may be disclosed only to the categories of persons and under the
21 conditions described in this Order. When the Action has been terminated, a Receiving
22 Party must comply with the provisions of section 15 below (FINAL DISPOSITION).
23 Protected Material must be stored and maintained by a Receiving Party at a location
24 and in a secure manner that ensures that access is limited to the persons authorized
25 under this Order.
26 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise
27 ordered by the court or permitted in writing by the Designating Party, a Receiving
28 Party may disclose any information or item designated “CONFIDENTIAL” only to:
1 a) the Receiving Party’s Outside Counsel of Record in this Action, as well as
2 employees of said Outside Counsel of Record to whom it is reasonably
3 necessary to disclose the information for this Action;
4 b) The officers, directors, and employees (including House Counsel) of the
5 Receiving Party to whom disclosure is reasonably necessary for this Action;
6 c) Experts (as defined in this Order) of the Receiving Party to whom disclosure
7 is reasonably necessary for this Action and who have signed the
8 “Acknowledgment and Agreement to Be Bound” (Exhibit A) [TO BE
9 NEGOTIATED AND PREPARED BY PARTIES AND ATTACHED TO
10 STIPULATION AND PROPOSED ORDER];
11 d) the court and its personnel;
12 e) court reporters and their staff;
13 f) professional jury or trial consultants, mock jurors, and Professional Vendors
14 to whom disclosure is reasonably necessary for this Action and who have
15 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
16 g) the author or recipient of a document containing the information or a
17 custodian or other person who otherwise possessed or knew the information;
18 h) during their depositions, witnesses, and attorneys for witnesses, in the Action
19 to whom disclosure is reasonably necessary provided: (1) the deposing party
20 requests that the witness sign the form attached as Exhibit A hereto; and (2)
21 they will not be permitted to keep any confidential information unless they
22 sign the “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
28 i) any mediators or settlement officers and their supporting personnel, mutually
1 agreed upon by any of the parties engaged in settlement discussions.
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3 X. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
4 IN OTHER LITIGATION
5 If a Party is served with a subpoena or a court order issued in other litigation that
6 compels disclosure of any information or items designated in this Action as
7 “CONFIDENTIAL,” that Party must:
8 a) promptly notify in writing the Designating Party. Such notification shall
9 include a copy of the subpoena or court order;
10 b) promptly notify in writing the party who caused the subpoena or order to
11 issue in the other litigation that some or all of the material covered by the
12 subpoena or order is subject to this Protective Order. Such notification shall
13 include a copy of this Stipulated Protective Order; and
14 c) cooperate with respect to all reasonable procedures sought to be pursued by
15 the Designating Party whose Protected Material may be affected. If the
16 Designating Party timely seeks a protective order, the Party served with the
17 subpoena or court order shall not produce any information designated in this
18 action as “CONFIDENTIAL” before a determination by the court from
19 which the subpoena or order issued, unless the Party has obtained the
20 Designating Party’s permission. The Designating Party shall bear the burden
21 and expense of seeking protection in that court of its confidential material
22 and nothing in these provisions should be construed as authorizing or
23 encouraging a Receiving Party in this Action to disobey a lawful directive
24 from another court.
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26 XI. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
27 PRODUCED IN THIS LITIGATION
28 a) The terms of this Order are applicable to information produced by a Non-
1 Party in this Action and designated as “CONFIDENTIAL.” Such information
2 produced by Non-Parties in connection with this litigation is protected by the
3 remedies and relief provided by this Order. Nothing in these provisions
4 should be construed as prohibiting a Non-Party from seeking additional
5 protections.
6 b) In the event that a Party is required, by a valid discovery request, to produce
7 a Non-Party’s confidential information in its possession, and the Party is
8 subject to an agreement with the Non-Party not to produce the Non-Party’s
9 confidential information, then the Party shall:
10 1) promptly notify in writing the Requesting Party and the Non-Party that
11 some or all of the information requested is subject to a confidentiality
12 agreement with a Non-Party;
13 2) promptly provide the Non-Party with a copy of the Stipulated
14 Protective Order in this Action, the relevant discovery request(s), and a
15 reasonably specific description of the information requested; and
16 3) make the information requested available for inspection by the Non-
17 Party, if requested.
18 c) If the Non-Party fails to seek a protective order from this court within 14
19 days of receiving the notice and accompanying information, the Receiving
20 Party may produce the Non-Party’s confidential information responsive to
21 the discovery request. If the Non-Party timely seeks a protective order, the
22 Receiving Party shall not produce any information in its possession or
23 control that is subject to the confidentiality agreement with the Non-Party
24 before a determination by the court. Absent a court order to the contrary, the
25 Non-Party shall bear the burden and expense of seeking protection in this
26 court of its Protected Material.
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1 XII. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
2 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
3 Protected Material to any person or in any circumstance not authorized under this
4 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing
5 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve
6 all unauthorized copies of the Protected Material, (c) inform the person or persons to
7 whom unauthorized disclosures were made of all the terms of this Order, and (d)
8 request such person or persons to execute the “Acknowledgment and Agreement to Be
9 Bound” attached hereto as Exhibit A.
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11 XIII. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
12 PROTECTED MATERIAL
13 When a Producing Party gives notice to Receiving Parties that certain
14 inadvertently produced material is subject to a claim of privilege or other protection,
15 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
16 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
17 may be established in an e-discovery order that provides for production without prior
18 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
19 parties reach an agreement on the effect of disclosure of a communication or
20 information covered by the attorney-client privilege or work product protection, the
21 parties may incorporate their agreement in the stipulated protective order submitted to
22 the court.
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24 XIV. MISCELLANEOUS
25 14.1 Right to Further Relief. Nothing in this Order abridges the right of any
26 person to seek its modification by the Court in the future.
27 14.2 Right to Assert Other Objections. By stipulating to the entry of this
28 Protective Order, no Party waives any right it otherwise would have to object to
1 disclosing or producing any information or item on any ground not addressed in this
2 Stipulated Protective Order. Similarly, no Party waives any right to object on any
3 ground to use in evidence of any of the material covered by this Protective Order.
4 14.3 Filing Protected Material. A Party that seeks to file under seal any
5 Protected Material must comply with Local Civil Rule 79-5. Protected Material may
6 only be filed under seal pursuant to a court order authorizing the sealing of the specific
7 Protected Material. If a Party’s request to file Protected Material under seal is denied
8 by the court, then the Receiving Party may file the information in the public record
9 unless otherwise instructed by the court.
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11 XV. FINAL DISPOSITION
12 After the final disposition of this Action, as defined in paragraph 6, within 60
13 days of a written request by the Designating Party, each Receiving Party must return
14 all Protected Material to the Producing Party or destroy such material. As used in this
15 subdivision, “all Protected Material” includes all copies, abstracts, compilations,
16 summaries, and any other format reproducing or capturing any of the Protected
17 Material. Whether the Protected Material is returned or destroyed, the Receiving Party
18 must submit a written certification to the Producing Party (and, if not the same person
19 or entity, to the Designating Party) by the 60-day deadline that (1) identifies (by
20 category, where appropriate) all the Protected Material that was returned or destroyed
21 and (2) affirms that the Receiving Party has not retained any copies, abstracts,
22 compilations, summaries or any other format reproducing or capturing any of the
23 Protected Material. Notwithstanding this provision, Counsel are entitled to retain an
24 archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts,
25 legal memoranda, correspondence, deposition and trial exhibits, expert reports,
26 attorney work product, and consultant and expert work product, even if such materials
27 contain Protected Material. Any such archival copies that contain or constitute
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1 Protected Material remain subject to this Protective Order as set forth in Section 6
2 ||(DURATION).
3
4 ||XVI. VIOLATION
5 Any violation of this Order may be punished by appropriate measures including,
6 || without limitation, contempt proceedings and/or monetary sanctions.
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8 || UPON STIPULATION OF THE PARTIES AND FOR GOOD CAUSE SHOWN,
9 |} IT IS SO ORDERED.
10 .
eNuin/
12 Dated: JULY 6, 2026 Hon. Brianna Fuller Mircheff
13 United States Magistrate Judge
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□□
1 EXHIBIT A
2 CERTIFICATION RE CONFIDENTIAL MATERIALS
3 I hereby acknowledge that I, _________________________________[NAME],
4 ______________________________________________ [POSITION AND
5 EMPLOYER], am about to receive Confidential Materials supplied in connection with
6 the proceeding titled SHLA Group Inc., et al., v. Kissler and Co. Inc., filed in the
7 United States District Court, Central District of California, Case No. 2:23-cv-07567-
8 TJH-BFM (the “Proceeding”). I certify that I understand that the Confidential
9 Materials are provided to me subject to the terms and restrictions of the Stipulation and
10 Protective Order filed in this Proceeding. I have been given a copy of the Stipulation
11 and Protective Order; I have read it, and I agree to be bound by its terms.
12 I understand that the Confidential Materials, as defined in the Stipulation and
13 Protective Order, including any notes or other records that may be made regarding any
14 such materials, shall not be disclosed to anyone except as expressly permitted by the
15 Stipulation and Protective Order. I will not copy or use, except solely for the purposes
16 of this Proceeding, any Confidential Materials obtained pursuant to this Stipulation and
17 Protective Order, except as provided therein or otherwise ordered by the Court.
18 I further agree to submit to the jurisdiction of the United States District Court for
19 the Central District of California for enforcing the terms of this Stipulated Protective
20 Order, even if such enforcement proceedings occur after termination of this action.
21 I further understand that I am to retain all copies of all Confidential Materials
22 provided to me in the proceeding in a secure manner, and that all copies of such
23 materials are to remain in my personal custody until the termination of my
24 participation in this Proceeding, whereupon the copies of such materials will be
25 returned to counsel who provided me with such materials.
26 I declare under penalty of perjury, under the laws of the State of California and
27 the United States, that the foregoing is true and correct. Executed this _____ day of
28 ______________, 20___, at _____________________________.
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2 DATED: ______________ BY:___________________________________
3 Signature
4 ______________________________________
5 Title
6 ______________________________________
7 Address
8 ______________________________________
9 City, State, Zip
10 ______________________________________
11 Telephone Number
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