Opinion

Courtney Washington v. Kia America Inc.

Court: District Court, C.D. California
Filed: Jan 27, 2022
Cited by: 0 cases
Authority: More cited than 16.3%

distinguishing "good cause" showing for sealing documents produced in discovery from "compelling reasons" standard when merits-related documents are part of court record

How later courts described this case

distinguishing "good cause" showing for sealing documents produced in discovery from "compelling reasons" standard when merits-related documents are part of court record
even stipulated protective orders require good cause showing

Written by the judges who cited it.

The opinion

PROTECTIVE ORDER Case No: 2:21-cv-08795-JFW-PD

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Case 2:21-cv-08795-JFW-PD Document 30 Filed 01/27/22 Page 1 of 15 Page ID #:201

HOLLAND & KNIGHT LLP

Zachary C. Frampton (SBN 303225)

zac.frampton@hklaw.com

400 South Hope Street, 8th Floor

Los Angeles, CA 90071

Telephone: 213.896.2400

Fax: 213.896.2450

Attorneys for Defendant

HYUNDAI CAPITAL AMERICA

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

COURTNEY WASHINGTON, an Case No.: 2:21-cv-08795-JFW-PDx

individual,

PROTECTIVE ORDER

Plaintiff,

vs. Judge John F. Walter

Mag. Judge Patricia Donahue

KIA AMERICA, INC., a California

corporation doing business as KIA OF Complaint Filed: Nov. 8, 2021

DOWNTOWN LOS ANGELES, and

HYUNDAI CAPITAL AMERICA, a [Removed from Los Angeles County

California corporation doing business

as KIA FINANCE, and DOES 1-20, Superior Court Case No.: 21-ST-CV-

36853]

Defendants.

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STIPULATED PROTECTIVE ORDER AND Case No: 2:21-cv-08795-JFW-PD

CONFIDENTIALITY AGREEMENT

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1. PURPOSES AND LIMITATIONS

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

proprietary, or private information for which special protection from public

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

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

Court to enter the following Stipulated Protective Order. The parties

acknowledge that this Order does not confer blanket protections on all

disclosures or responses to discovery and that the protection it affords from

public disclosure and use extends only to the limited information or items that

are entitled to confidential treatment under the applicable legal principles.

GOOD CAUSE STATEMENT

This action is likely to involve confidential, financial, and/or proprietary

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

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

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

confidential business or financial information, information regarding

confidential business practices, or other confidential, commercial information

(including information implicating privacy rights of third parties), information

otherwise generally unavailable to the public, or which may be privileged or

otherwise protected from disclosure under state or federal statutes, court rules,

case decisions, or common law. Accordingly, to expedite the flow of

information, to facilitate the prompt resolution of disputes over confidentiality

of discovery materials, to adequately protect information the parties are entitled

to keep confidential, to ensure that the parties are permitted reasonable necessary

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

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

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

the parties that information will not be designated as confidential for tactical

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PROTECTIVE ORDER Case No: 2:21-cv-08795-JFW-PD

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

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

not be part of the public record of this case.

ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL

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

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

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

standards that will be applied when a party seeks permission from the court to file

material under seal.

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

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

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

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

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

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

cause showing), and a specific showing of good cause or compelling reasons with

proper evidentiary support and legal justification, must be made with respect to

Protected Material that a party seeks to file under seal. The parties' mere designation

of Disclosure or Discovery Material as CONFIDENTIAL does not—without the

submission of competent evidence by declaration, establishing that the material sought

to be filed under seal qualifies as confidential, privileged, or otherwise protectable—

constitute good cause.

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

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

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

Pintos v. Pacific Creditors Ass'n., 605 F.3d 665, 677-79 (9th Cir. 2010). For each item

or type of information, document, or thing sought to be filed or introduced under seal

in connection with a dispositive motion or trial, the party seeking protection must

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PROTECTIVE ORDER Case No: 2:21-cv-08795-JFW-PD

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articulate compelling reasons, supported by specific facts and legal justification,

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

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

Any document that is not confidential, privileged, or otherwise

protectable in its entirety will not be filed under seal if the confidential portions

can be redacted. If documents can be redacted, then a redacted version for public

viewing, omitting only the confidential, privileged, or otherwise protectable

portions of the document, shall be filed. Any application that seeks to file

documents under seal in their entirety should include an explanation of why

redaction is not feasible.

2. DEFINITIONS

2.1 Action: the above-captioned case.

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

designation of information or items under this Order.

2.3 "CONFIDENTIAL" Information or Items: information (regardless

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

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

in the Good Cause Statement.

2.4 Counsel (without qualifier): Outside Counsel of Record and House

Counsel (as well as their support staff).

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

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

"CONFIDENTIAL."

2.6 Disclosure or Discovery Material: all items or information,

regardless of the medium or manner in which it is generated, stored, or

maintained (including, among other things, testimony, transcripts, and tangible

things), that are produced or generated in disclosures or responses to discovery

in this matter.

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PROTECTIVE ORDER Case No: 2:21-cv-08795-JFW-PD

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

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

expert witness or as a consultant in this Action.

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

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

counsel.

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

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

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

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

appeared in this action on behalf of that party or are affiliated with a law firm which

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

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

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

support staffs).

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

Discovery Material in this action.

2.13 Professional Vendors: persons or entities, not employed by or affiliated

with a Party, that provide litigation support services (e.g., photocopying, videotaping,

translating, preparing exhibits or demonstrations, and organizing, storing, or retrieving

data in any form or medium) and their employees and subcontractors.

2.14 Protected Material: any Disclosure or Discovery Material that is

designated as "CONFIDENTIAL."

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

from a Producing Party.

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3. SCOPE

The protections conferred by this Stipulation and Order cover not only Protected

Material (as defined above), but also (1) any information copied or extracted from

Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected

Material; and (3) any testimony, conversations, or presentations by Parties or

their Counsel that might reveal Protected Material.

Any use of Protected Material at trial shall be governed by the orders of

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

4. DURATION

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

CONFIDENTIAL or maintained pursuant to this protective order used or

introduced as an exhibit at trial becomes public and will be presumptively

available to all members of the public, including the press, unless compelling

reasons supported by specific factual findings to proceed otherwise are made to

the trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81

(distinguishing "good cause" showing for sealing documents produced in

discovery from "compelling reasons" standard when merits-related documents

are part of court record). Accordingly, the terms of this protective order do not

extend beyond the commencement of the trial.

5. DESIGNATING PROTECTED MATERIAL

5.1 Exercise of Restraint and Care in Designating Material for

Protection. Each Party or Non-Party that designates information or items for

protection under this Order must take care to limit any such designation to

specific material that qualifies under the appropriate standards. The Designating

Party must designate for protection only those parts of material, documents,

items or oral or written communications that qualify so that other portions of the

material, documents, items or communications for which protection is not

warranted are not swept unjustifiably within the ambit of this Order. Mass,

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PROTECTIVE ORDER Case No: 2:21-cv-08795-JFW-PD

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indiscriminate or routinized designations are prohibited. Designations that are shown

to be clearly unjustified or that have been made for an improper purpose (e.g., to

unnecessarily encumber the case development process or to impose unnecessary

expenses and burdens on other parties) may expose the Designating Party to sanctions.

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

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

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

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

Order, or as otherwise stipulated or ordered, Disclosure or Discovery Material that

qualifies for protection under this Order must be clearly so designated before the

material is disclosed or produced.

Designation in conformity with this Order requires:

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

but excluding transcripts of depositions or other pretrial or trial proceedings), that the

Producing Party affix at a minimum, the legend "CONFIDENTIAL" to each page that

contains protected material.

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

Disclosure or Discovery Material on the record, before the close of the deposition all

protected testimony.

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

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

"CONFIDENTIAL."

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

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

Designating Party's right to secure protection under this Order for such material. Upon

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

to assure that the material is treated in accordance with the provisions of this Order.

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6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

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

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

Scheduling Order.

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

resolution process under Local Rule 37-1 et seq.

6.3 Joint Stipulation. Any challenge submitted to the Court shall be via

a joint stipulation pursuant to Local Rule 37-2.

6.4 The burden of persuasion in any such challenge proceeding shall be

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

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

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

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

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

entitled under the Producing Party's designation until the Court rules on the

challenge.

7. ACCESS TO AND USE OF PROTECTED MATERIAL

7.1 Basic Principles. A Receiving Party may use Protected Material

that is disclosed or produced by another Party or by a Non-Party in connection

with this Action only, for prosecuting, defending or attempting to settle this

Action. Such Protected Material may be disclosed only to the categories of

persons and under the conditions described in this Order. When the Action has

been terminated, a Receiving Party must comply with the provisions of section

13 below (FINAL DISPOSITION). Protected Material must be stored and

maintained by a Receiving Party at a location and in a secure manner that ensures

that access is limited to the persons authorized under this Order.

7.2 Disclosure of "CONFIDENTIAL" Information or Items. Unless

otherwise ordered by the court or permitted in writing by the Designating Party,

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a Receiving Party may disclose any information or item designated

"CONFIDENTIAL" only to:

(a) the Receiving Party's Outside Counsel of Record in this action, as well

as employees of said Outside Counsel of Record to whom it is reasonably necessary

to disclose the information for this Action;

(b) the officers, directors, and employees (including House Counsel) of the

Receiving Party to whom disclosure is reasonably necessary for this Action;

disclosure is reasonably necessary for this Action and who have signed the

"Acknowledgment and Agreement to Be Bound" (Exhibit A);

(d) the court and its personnel;

(e) court reporters and their staff;

(f) professional jury or trial consultants, mock jurors, and Professional

Vendors to whom disclosure is reasonably necessary for this Action and who have

signed the "Acknowledgment and Agreement to Be Bound" (Exhibit A);

(g) the author or recipient of a document containing the information or a

custodian or other person who otherwise possessed or knew the information;

(h) during their depositions, witnesses, and attorneys for witnesses, in the

Action to whom disclosure is reasonably necessary provided: (1) the deposing party

requests that the witness sign the form attached as Exhibit A hereto; and (2) they will

not be permitted to keep any confidential information unless they sign the

"Acknowledgment and Agreement to Be Bound" (Exhibit A), unless otherwise agreed

by the Designating Party or ordered by the court. Pages of transcribed deposition

testimony or exhibits to depositions that reveal Protected Material may be separately

bound by the court reporter and may not be disclosed to anyone except as permitted

under this Stipulated Protective Order; and

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

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

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8. PROTECTED MATERIAL SUBPOENAED OR ORDERED

PRODUCED IN OTHER LITIGATION

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

litigation that compels disclosure of any information or items designated in this

Action as "CONFIDENTIAL," that Party must:

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

shall include a copy of the subpoena or court order;

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

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

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

include a copy of this Protective Order; and

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

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

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

action as "CONFIDENTIAL" before a determination by the court from which

the subpoena or order issued, unless the Party has obtained the Designating

Party's permission. The Designating Party shall bear the burden and expense of

seeking protection in that court of its confidential material and nothing in these

provisions should be construed as authorizing or encouraging a Receiving Party

in this Action to disobey a lawful directive from another court.

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

PRODUCED IN THIS LITIGATION

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

produced by a Non-Party in this Action and designated as

"CONFIDENTIAL." Such information produced by Non-Parties in

connection with this litigation is protected by the remedies and relief

provided by this Order. Nothing in these provisions should be construed

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as prohibiting a Non-Party from seeking additional protections.

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

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

subject to an agreement with the Non-Party not to produce the Non-Party's confidential

information, then the Party shall:

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

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

agreement with a Non-Party;

2) promptly notify in writing the Requesting Party and the Non-

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

agreement with a Non-Party;

3) make the information requested available for inspection by

the Non-Party, if requested.

within 14 days of receiving the notice and accompanying information, the Receiving

Party may produce the Non-Party's confidential information responsive to the

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

Party shall not produce any information in its possession or control that is subject to

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

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

of seeking protection in this court of its Protected Material.

9. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

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

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

the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve

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

whom unauthorized disclosures were made of all the terms of this Order, and (d)

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request such person or persons to execute the "Acknowledgment and Agreement

to Be Bound" that is attached hereto as Exhibit A.

10. INADVERTENT PRODUCTION OF PRIVILEGED OR

OTHERWISE PROTECTED MATERIAL

When a Producing Party gives notice to Receiving Parties that certain

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

protection, the obligations of the Receiving Parties are those set forth in Federal

Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify

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

production without prior privilege review. Pursuant to Federal Rule of Evidence

502(d) and (e), insofar as the parties reach an agreement on the effect of

disclosure of a communication or information covered by the attorney-client

privilege or work product protection, the parties may incorporate their agreement

in the stipulated protective order submitted to the court.

11. MISCELLANEOUS

11.1 Right to Further Relief. Nothing in this Order abridges the right of

any person to seek its modification by the court in the future.

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

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

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

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

on any ground to use in evidence of any of the material covered by this Protective

Order.

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

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

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

the specific Protected Material at issue. If a Party's request to file Protected

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

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

12. FINAL DISPOSITION

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

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

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

subdivision, "all Protected Material" includes all copies, abstracts, compilations,

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

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

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

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

category, where appropriate) all the Protected Material that was returned or destroyed

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

compilations, summaries or any other format reproducing or capturing any of the

Protected Material. Notwithstanding this provision, Counsel are entitled to retain an

archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts,

legal memoranda, correspondence, deposition and trial exhibits, expert reports,

attorney work product, and consultant and expert work 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.

13. VIOLATION

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

without limitation, contempt proceedings and/or monetary sanctions.

IT IS SO STIPULATED.

HOLLAND & KNIGHT, LLP

Dated: January 26, 2022 By: _/s/ Zachary C. Frampton

Zachary C. Frampton

Attorneys for Defendant

Hyundai Capital America

Case □□□□□□□□□□□□□□□□□□□□□ Document 30 Filed 01/27/22 Page 14of15 Page □□ #:214

Dated: January 24, 2022 LEGALAXXIS INC.

4 By: CSla, pots ahouleaae

Nazgole Hashemi

5 Tannaz Hashemi

6 Attorneys for Plaintiff

Courtney Washington

g Dated: January 25, 2022 MANNING LEAVER BRUDER AND

BERBERICH LLP

10 By: _/s/ Robert C. Jenkins

Robert C. Jenkins

11 Gary Haroutin Prudian

D Attorneys for Defendant

ee First Motor Group of Los Angeles LLC

4 .

22seeh dba Kia of Downtown Los Angeles

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2 Bs = 15|| FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

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S 17|| DATED: January 27, 2022

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39 || HON. PATRICIA DONAHUE

United States Magistrate Judge

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EXHIBIT A

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

I, ______________________________________________[print or type full

name], of ____________________________________________[print or type full

address], declare under penalty of perjury that I have read in its entirety and understand

the Stipulated Protective Order that was issued by the United States District Court for

the Central District of California on _____, 20__ in the case of Courtney Washington

v. Kia America Inc., et al, Case No. 2:21-cv-08795. I agree to comply with and to be

bound by all the terms of this Stipulated Protective Order and I understand and

acknowledge that failure to so comply could expose me to sanctions and punishment

in the nature of contempt. I solemnly promise that I will not disclose in any manner

any information or item that is subject to this Stipulated Protective Order to any person

or entity except in strict compliance with the provisions of this Order. I further agree

to submit to the jurisdiction of the United States District Court for the Central District

of California for enforcing the terms of this Stipulated Protective Order, even if such

enforcement proceedings occur after termination of this action.

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

_______________________________________ [print or type full address and

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

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

Order.

Date: ______________________________________

City and State where sworn and signed: _________________________________

Printed name: _______________________________

Signature: __________________________________

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.