The opinion
Case 2:21-cv-09881-AB-JEM Document 24 Filed 06/27/22 Page 1 of 15 Page ID #:237
1 Eugene J. Egan (State Bar No. 130108)
eje@manningllp.com
2 James A. Harris (State Bar No. 312309)
jah@manningllp.com
3 MANNING & KASS
ELLROD, RAMIREZ, TRESTER LLP
4 801 S. Figueroa St, 15th Floor
Los Angeles, California 90017-3012
5 Telephone: (213) 624-6900
Facsimile: (213) 624-6999
6
7 Attorneys for COSTCO WHOLESALE CORPORATION
8
Haleh Shekarchian, (State Bar No. 158449)
9 hs@halehshekarchian.com
THE LAW OFFICE OF HALEH SHEKARCHIAN, APC.
10
9440 Santa Monica Blvd., Suite 707
11 Beverly Hills, California 90210
Telephone: (310) 271-23121
12
Attorneys for ADRINA BAGHUMAN
13
14
UNITED STATES DISTRICT COURT
15
CENTRAL DISTRICT OF CALIFORNIA
16
17
18 ADRINA BAGHUMYAN. an Case No. 2:21-cv-09881-AB (JEMx)
individual,, [Assigned to the Hon. Andre Birotte,
19 Jr., Courtroom 7B]
Plaintiff,
20
v.
21 STIPULATED PROTECTIVE
COSTCO WHOLESALE ORDER
22 CORPORATION dba COSTCO, and
DOES 1 to 50, Inclusive,
23 Action filed: 08/03/21
Defendants. Trial date: 01/31/23
24
25
26 A. PURPOSES AND LIMITATIONS
27 Discovery in this action is likely to involve production of confidential,
28 proprietary, or private information for which special protection from public
STIPULATED PROTECTIVE ORDER
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1 disclosure and from use for any purpose other than prosecuting this litigation may
2 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to
3 enter the following Stipulated Protective Order. The parties acknowledge that this
4 Order does not confer blanket protections on all disclosures or responses to
5 discovery and that the protection it affords from public disclosure and use extends
6 only to the limited information or items that are entitled to confidential treatment
7 under the applicable legal principles. The parties further acknowledge, as set forth
8 in Section 12.3 (Filing Protected Material), below, that this Stipulated Protective
9 Order does not entitle them to a file confidential information under seal; Civil Local
10 Rule 79-5 sets forth the procedures that must be followed and the standards that will
11 be applied when a party seeks permission from the court to file material under seal.
12
13 B. GOOD CAUSE STATEMENT
14
15 Good cause exists for this stipulated protective order because Costco's
16 policies and procedures documents contain proprietary information of Costco and
17 Costco only authorizes production of these proprietary documents subject to a
18 protective order. Costco would suffer harm if its proprietary policies and
19 procedures documents and surveillance video were disseminated. Such confidential
20 and proprietary materials and information consist of, among other things,
21 confidential business or financial information, information regarding confidential
22 business practices, or other confidential research, development, or commercial
23 information (including information implicating privacy rights of third parties),
24 information otherwise generally unavailable to the public, or which may be
25 privileged or otherwise protected from disclosure under state or federal statutes,
26 court rules, case decisions, or common law. Accordingly, to expedite the flow of
27 information, to facilitate the prompt resolution of disputes over confidentiality of
28 discovery materials, to adequately protect information the parties are entitled to
2
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1 keep confidential, to ensure that the parties are permitted reasonable necessary uses
2 of such material in preparation for and in the conduct of trial, to address their
3 handling at the end of the litigation, and serve the ends of justice, a protective order
4 for such information is justified in this matter. It is the intent of the parties that
5 information will not be designated as confidential for tactical reasons and that
6 nothing be so designated without a good faith belief that it has been maintained in a
7 confidential, non-public manner, and there is good cause why it should not be part
8 of the public record of this case.
9 Good cause also exists for this stipulated protective order because
10 Adrina Baghumyan has a privacy interest in her personal medical and financial
11 information, however stored, whether in documents, disk, x-rays, etc. Adrina
12 Baghumyan would be harmed if such personal information were to be made public.
13 The rest of the text of this GOOD CAUSE STATEMENT shall be applied and
14 modified to apply to the personal privacy information, medical and financial, of
15 Adrina Baghumyan.
16
17 1. DEFINITIONS
18 1.1 Action: Adrina Baghumyan, an Individual v. Costco Wholesale
19 Corporation dba Costco; and Does 1 to 50, Inclusive; Case No. 2:21-cv-09581 AB
20 (JEMx).
21 1.2 Challenging Party: a Party or Non-Party that challenges the
22 designation of information or items under this Order.
23 1.3 “CONFIDENTIAL” Information or Items: information (regardless of
24 how it is generated, stored, or maintained) or tangible things that qualify for
25 protection under Federal Rule of Civil Procedure 26(c), and as specified above in
26 the Good Cause Statement.
27 1.4 Counsel: Outside Counsel of Record and House Counsel (as well as
28 their support staff).
3
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1 1.5 Designating Party: a Party or Non-Party that designates information
2 or items that it produces in disclosures or in responses to discovery as
3 “CONFIDENTIAL.”
4 1.6 Disclosure or Discovery Material: all items or information, regardless
5 of the medium or manner in which it is generated, stored, or maintained (including,
6 among other things, testimony, transcripts, and tangible things), that are produced
7 or generated in disclosures or responses to discovery in this matter.
8 1.7 Expert: a person with specialized knowledge or experience in a matter
9 pertinent to the litigation who has been retained by a Party or its counsel to serve as
10 an expert witness or as a consultant in this Action.
11 1.8 House Counsel: attorneys who are employees of a party to this Action.
12 House Counsel does not include Outside Counsel of Record or any other outside
13 counsel.
14 1.9 Non-Party: any natural person, partnership, corporation, association,
15 or other legal entity not named as a Party to this action.
16 1.10 Outside Counsel of Record: attorneys who are not employees of a
17 party to this Action but are retained to represent or advise a party to this Action and
18 have appeared in this Action on behalf of that party or are affiliated or assisting with
19 a law firm which has appeared on behalf of that party, including support staff.
20 1.11 Party: any party to this Action, including all of its officers, directors,
21 employees, consultants, retained experts, and Outside Counsel of Record (and their
22 support staffs).
23 1.12 Producing Party: a Party or Non-Party that produces Disclosure or
24 Discovery Material in this Action.
25 1.13 Professional Vendors: persons or entities that provide litigation
26 support services (e.g., photocopying, videotaping, translating, preparing exhibits or
27 demonstrations, and organizing, storing, or retrieving data in any form or medium)
28 and their employees and subcontractors.
4
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1 1.14 Protected Material: any Disclosure or Discovery Material that is
2 designated as “CONFIDENTIAL.”
3 1.15 Receiving Party: a Party that receives Disclosure or Discovery
4 Material from a Producing Party.
5
6 2. 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 Order does not govern the use of Protected Material at trial.
14 3. DURATION
15 FINAL DISPOSITION of the action is defined as the conclusion of any
16 appellate proceedings, or, if no appeal is taken, when the time for filing of an appeal
17 has run. Except as set forth below, the terms of this protective order apply through
18 FINAL DISPOSITION of the action. The parties may stipulate that the they will be
19 contractually bound by the terms of this agreement beyond FINAL DISPOSITION,
20 but will have to file a separate action for enforcement of the agreement once all
21 proceedings in this case are complete.
22
23 Once a case proceeds to trial, information that was designated as
24 CONFIDENTIAL or maintained pursuant to this protective order used or introduced
25 as an exhibit at trial becomes public and will be presumptively available to all
26 members of the public, including the press, unless compelling reasons supported by
27 specific factual findings to proceed otherwise are made to the trial judge in advance
28 of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause”
5
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1 showing for sealing documents produced in discovery from “compelling reasons”
2 standard when merits-related documents are part of court record). Accordingly, for
3 such materials, the terms of this protective order do not extend beyond the
4 commencement of the trial.
5
6 4. DESIGNATING PROTECTED MATERIAL
7 4.1 Exercise of Restraint and Care in Designating Material for Protection.
8 Each Party or Non-Party that designates information or items for protection under
9 this Order must take care to limit any such designation to specific material that
10 qualifies under the appropriate standards. The Designating Party must designate for
11 protection only those parts of material, documents, items, or oral or written
12 communications that qualify so that other portions of the material, documents,
13 items, or communications for which protection is not warranted are not swept
14 unjustifiably within the ambit of this Order.
15 Mass, indiscriminate, or routinized designations are prohibited. Designations
16 that are shown to be clearly unjustified or that have been made for an improper
17 purpose (e.g., to unnecessarily encumber the case development process or to impose
18 unnecessary expenses and burdens on other parties) may expose the Designating
19 Party to sanctions.
20 If it comes to a Designating Party’s attention that information or items that it
21 designated for protection do not qualify for protection, that Designating Party must
22 promptly notify all other Parties that it is withdrawing the inapplicable designation.
23 4.2 Manner and Timing of Designations. Except as otherwise provided in
24 this Order (see, e.g., second paragraph of Section 5.2(a) below), or as otherwise
25 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
26 under this Order must be clearly so designated before the material is disclosed or
27 produced.
28 Designation in conformity with this Order requires:
6
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1 (a) for information in documentary form (e.g., paper or electronic
2 documents, but excluding transcripts of depositions or other pretrial or trial
3 proceedings), that the Producing Party affix at a minimum, the legend
4 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
5 contains protected material. If only a portion or portions of the material on a page
6 qualifies for protection, the Producing Party also must clearly identify the protected
7 portion(s) (e.g., by making appropriate markings in the margins).
8 A Party or Non-Party that makes original documents available for
9 inspection need not designate them for protection until after the inspecting Party has
10 indicated which documents it would like copied and produced. During the
11 inspection and before the designation, all of the material made available for
12 inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has
13 identified the documents it wants copied and produced, the Producing Party must
14 determine which documents, or portions thereof, qualify for protection under this
15 Order. Then, before producing the specified documents, the Producing Party must
16 affix the “CONFIDENTIAL legend” to each page that contains Protected Material.
17 If only a portion or portions of the material on a page qualifies for protection, the
18 Producing Party also must clearly identify the protected portion(s) (e.g., by making
19 appropriate markings in the margins).
20 (b) for testimony given in depositions that the Designating Party identify
21 the Disclosure or Discovery Material on the record, before the close of the
22 deposition all protected testimony.
23 (c) for information produced in some form other than documentary and
24 for any other tangible items, that the Producing Party affix in a prominent place on
25 the exterior of the container or containers in which the information is stored the
26 legend “CONFIDENTIAL.” If only a portion or portions of the information
27 warrants protection, the Producing Party, to the extent practicable, shall identify the
28 protected portion(s).
7
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1 4.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
2 failure to designate qualified information or items does not, standing alone, waive
3 the Designating Party’s right to secure protection under this Order for such material.
4 Upon timely correction of a designation, the Receiving Party must make reasonable
5 efforts to assure that the material is treated in accordance with the provisions of this
6 Order.
7
8 5. CHALLENGING CONFIDENTIALITY DESIGNATIONS
9 5.1 Timing of Challenges. Any Party or Non-Party may challenge a
10 designation of confidentiality at any time that is consistent with the Court’s
11 Scheduling Order.
12 5.2 Meet and Confer. The Challenging Party Shall initiate the dispute
13 resolution process under Civil Local Rule 37-1 et seq.
14 5.3 The burden of persuasion in any such challenge proceeding shall be
15 on the Designating Party. Frivolous challenges, and those made for an improper
16 purpose (e.g., to harass or impose unnecessary expenses and burdens on other
17 parties), may expose the Challenging Party to sanctions. Unless the Designating
18 Party has waived or withdrawn the confidentiality designation, all parties shall
19 continue to afford the material in question the level of protection to which it
20 is entitled under the Producing Party’s designation until the Court rules on the
21 challenge.
22
23 6. ACCESS TO AND USE OF PROTECTED MATERIAL
24 6.1 Basic Principles. A Receiving Party may use Protected Material that
25 is disclosed or produced by another Party or by a Non-Party in connection with
26 this Action only for prosecuting, defending, or attempting to settle this Action.
27 Such Protected Material may be disclosed only to the categories of persons and
28 under the conditions described in this Order. When the Action has been
8
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1 terminated, a Receiving Party must comply with the provisions of Section 13 below
2 (FINAL DISPOSITION).
3 Protected Material must be stored and maintained by a Receiving Party at
4 a location and in a secure manner that ensures that access is limited to the
5 persons authorized under this Order.
6 6.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
7 otherwise ordered by the Court or permitted in writing by the Designating Party, a
8 Receiving Party may disclose any information or item designated
9 “CONFIDENTIAL” only to:
10 (a) the Receiving Party’s Outside Counsel of Record in this Action, as
11 well as employees of said Outside Counsel of Record to whom it is reasonably
12 necessary to disclose the information for this Action;
13 (b) the officers, directors, and employees (including House Counsel) of
14 the Receiving Party to whom disclosure is reasonably necessary for this Action;
15 (c) Experts (as defined in this Order) of the Receiving Party to whom
16 disclosure is reasonably necessary for this Action and who have signed the
17 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
18 (d) the Court and its personnel;
19 (e) court reporters and their staff;
20 (f) professional jury or trial consultants, mock jurors, and Professional
21 Vendors to whom disclosure is reasonably necessary for this Action and who have
22 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
23 (g) the author or recipient of a document containing the information or a
24 custodian or other person who otherwise possessed or knew the information;
25 (h) during their depositions, witnesses, and attorneys for witnesses, in
26 the Action to whom disclosure is reasonably necessary provided: (1) the deposing
27 party requests that the witness sign the form attached as Exhibit A hereto; and (2)
28 they will not be permitted to keep any confidential information unless they sign the
9
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1 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
2 agreed by the Designating Party or ordered by the Court. Pages of transcribed
3 deposition testimony or exhibits to depositions that reveal Protected Material may
4 be separately bound by the court reporter and may not be disclosed to anyone except
5 as permitted under this Stipulated Protective Order; and
6 (i) any mediator or settlement officer, and their supporting personnel,
7 mutually agreed upon by any of the parties engaged in settlement discussions.
8
9 7. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
10 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 with
23 the subpoena or court order shall not produce any information designated in this
24 action as “CONFIDENTIAL” before a determination by the court from which the
25 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
10
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1 to disobey a lawful directive from another court.
2
3 8. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
4 PRODUCED IN THIS LITIGATION
5 (a) The terms of this Order are applicable to information produced by a
6 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
7 produced by Non-Parties in connection with this litigation is protected by the
8 remedies and relief provided by this Order. Nothing in these provisions should be
9 construed as prohibiting a Non-Party from seeking additional protections.
10 (b) In the event that a Party is required, by a valid discovery request, to
11 produce a Non-Party’s confidential information in its possession, and the Party is
12 subject to an agreement with the Non-Party not to produce the Non-Party’s
13 confidential information, then the Party shall:
14 (1) promptly notify in writing the Requesting Party and the Non-Party
15 that some or all of the information requested is subject to a confidentiality agreement
16 with a Non-Party;
17 (2) promptly provide the Non-Party with a copy of the Stipulated
18 Protective Order in this Action, the relevant discovery request(s), and a reasonably
19 specific description of the information requested; and
20 (3) make the information requested available for inspection by the Non-
21 Party, if requested.
22 (c) If the Non-Party fails to seek a protective order from this Court within
23 14 days of receiving the notice and accompanying information, the Receiving Party
24 may produce the Non-Party’s confidential information responsive to the discovery
25 request. If the Non-Party timely seeks a protective order, the Receiving Party shall
26 not produce any information in its possession or control that is subject to the
27 confidentiality agreement with the Non-Party before a determination by the Court.
28 Absent a court order to the contrary, the Non-Party shall bear the burden and
11
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1 expense of seeking protection in this Court of its Protected Material.
2
3 9. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
4 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
5 Protected Material to any person or in any circumstance not authorized under this
6 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
7 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
8 to retrieve all unauthorized copies of the Protected Material, (c) inform the person
9 or persons to whom unauthorized disclosures were made of all the terms of this
10 Order, and (d) request such person or persons to execute the “Acknowledgment and
11 Agreement to Be Bound” that is attached hereto as Exhibit A.
12
13 10. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
14 PROTECTED MATERIAL
15 When a Producing Party gives notice to Receiving Parties that certain
16 inadvertently produced material is subject to a claim of privilege or other protection,
17 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
18 Procedure 26(b)(5)(B). This provision is not intended to modify whatever
19 procedure may be established in an e-discovery order that provides for production
20 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and
21 (e), insofar as the parties reach an agreement on the effect of disclosure of a
22 communication or information covered by the attorney-client privilege or work
23 product protection, the parties may incorporate their agreement in the stipulated
24 protective order submitted to the Court.
25
26 11. MISCELLANEOUS
27 11.1 Right to Relief. Nothing in this Order abridges the right of any person
28 to seek its modification by the Court in the future.
12
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1 11.2 Right to Assert Other Objections. By stipulating to the entry of this
2 Protective Order, no Party waives any right it otherwise would have to object to
3 disclosing or producing any information or item on any ground not addressed in this
4 Stipulated Protective Order. Similarly, no Party waives any right to object on any
5 ground to use in evidence of any of the material covered by this Protective Order.
6 11.3 Filing Protected Material. A Party that seeks to file under seal any
7 Protected Material must comply with Civil Local Rule 79-5. Protected Material
8 may only be filed under seal pursuant to a court order authorizing the sealing of the
9 specific Protected Material at issue. If a Party’s request to file Protected Material
10 under seal is denied by the court, then the Receiving Party may file the information
11 in the public record unless otherwise instructed by the court.
12
13 12. FINAL DISPOSITION
14 After the final disposition of this Action, as defined in Section 4
15 (DURATION), within 60 days of a written request by the Designating Party, each
16 Receiving Party must return all Protected Material to the Producing Party or destroy
17 such material. As used in this subdivision, “all Protected Material” includes all
18 copies, abstracts, compilations, summaries, and any other format reproducing or
19 capturing any of the Protected Material. Whether the Protected Material is returned
20 or destroyed, the Receiving Party must submit a written certification to the
21 Producing Party (and, if not the same person or entity, to the Designating Party) by
22 the 60 day deadline that (1) identifies (by category, where appropriate) all the
23 Protected Material that was returned or destroyed; and (2) affirms that the Receiving
24 Party has not retained any copies, abstracts, compilations, summaries, or any other
25 format reproducing or capturing any of the Protected Material. Notwithstanding this
26 provision, Counsel are entitled to retain an archival copy of all pleadings, motion
27 papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence,
28 deposition and trial exhibits, expert reports, attorney work product, and consultant
13
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1 | and expert work product, even if such materials contain Protected Material. Any
2] such archival copies that contain or constitute Protected Material remain subject to
3 | this Protective Order as set forth in Section 4 (DURATION).
S| 13. Any violation of this Order may be punished by any and all appropriate
6 measures including, without limitation, contempt proceedings and/or
7 monetary sanctions.
8} IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
10} DATED: 6/24/22
11
12 /s/ Haleh Shekarchian
13 | Attorneys for Plaintiff.
14
15 | DATED: 6/24/22
6 yO
17 \
18 | Attorneys for Defendant.
19
20 | FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
21
22) DATED: 6/27/22
23
Ph E WeBerial_
25 norable John E. McDermott
6 nited States Magistrate Judge
27
28
14
TO STIPULATED PROTECTIVE ORDER □□□□□□□□□□□□□□□□□□□□□□□□□□□□
Case 2:21-cv-09881-AB-JEM Document 24 Filed 06/27/22 Page 15 of 15 Page ID #:251
1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3 13.1 I, _____________________________ [print or type full name], of
4 _________________ [print or type full address], declare under penalty of perjury
5 that I have read in its entirety and understand the Stipulated Protective Order that
6 was issued by the United States District Court for the Central District of California
7 on [date] in the case of Adrina Baghumyan, an Individual v. Costco Wholesale
8 Corporation dba Costco; and Does 1 to 50, Inclusive; Case No. 2:21-cv-09581 AB
9 (JEMx). I agree to comply with and to be bound by all the terms of this Stipulated
10 Protective Order, and I understand and acknowledge that failure to so comply could
11 expose me to sanctions and punishment in the nature of contempt. I solemnly
12 promise that I will not disclose in any manner any information or item that is subject
13 to this Stipulated Protective Order to any person or entity except in strict compliance
14 with the provisions of this Order.
15 I further agree to submit to the jurisdiction of the United States District Court
16 for the Central District of California for the purpose of enforcing the terms of this
17 Stipulated Protective Order, even if such enforcement proceedings occur after
18 termination of this action. I hereby appoint __________________________ [print
19 or type full name] of _______________________________________ [print or type
20 full address and telephone number] as my California agent for service of process in
21 connection with this action or any proceedings related to enforcement of this
22 Stipulated Protective Order.
23 Date: ______________________________________
24 City and State where sworn and signed: _________________________________
25
26 Printed name: _______________________________
27
28 Signature: __________________________________
15
STIPULATED PROTECTIVE ORDER