Emil Ebrahim v. Elite Financial Services, Inc.

Case 2:22-cv-00890-DMG-RAO Document 40 Filed 07/25/22 Page 1 of 16 Page ID #:233

1 GERMAIN LABAT (CBN 203907)

germain.labat@gmlaw.com

2

GREENSPOON MARDER LLP

3 1875 Century Park East, Suite 1900

Los Angeles, California 90067

4

Tel: (323) 880-4520

5 Fax: (954) 771-9264

LAWREN A. ZANN (Admitted Pro Hac Vice)

6

lawren.zann@gmlaw.com

7 GREENSPOON MARDER LLP

200 East Broward Boulevard, Suite 1800

8

Fort Lauderdale, Florida 33301

9 Tel: (954) 333-4345

Fax: (954) 333-4027

10

Attorneys for Defendant,

11 Elite Financial Services, Inc.

12

UNITED STATES DISTRICT COURT

13 CENTRAL DISTRICT OF CALIFORNIA

14

EMIL EBRAHIM and HANAA Case No. 2:22-cv-00890-DMG-RAO

15 SHARMOUKH,

16 Plaintiffs,

17 STIPULATED PROTECTIVE ORDER1

v.

18

19 ELITE FINANCIAL SERVICES,

INC.,

20

21 Defendants.

22

23

24

25

26

27

28

1 This Stipulated Protective Order is substantially based on the model protective

order provided under Magistrate Judge Rozella A. Oliver’s Procedures.

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1 1. A. 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 prosecuting 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

8 the 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.

11

12 B. GOOD CAUSE STATEMENT

13 This action is likely to involve trade secrets, pricing lists, and other valuable

14 research, development, commercial, financial, technical and/or proprietary

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

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

17 proprietary materials and information may 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, or information otherwise generally unavailable to the public or which

21 may be privileged or otherwise protected from disclosure under state or federal

22 statutes, court rules, case decisions, or common law. Accordingly, to expedite the

23 flow of information, to facilitate the prompt resolution of disputes over confidentiality

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

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

26 of such material in preparation for and in the conduct of trial, to address their handling

27 at the end of the litigation, and serve the ends of justice, a protective order for such

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1 information is justified in this matter. It is the intent of the parties that information

2 will not be designated as confidential for tactical reasons and that nothing be so

3 designated without a good faith belief that it has been maintained in a confidential,

4 non-public manner, and there is good cause why it should not be part of the public

5 record of this case.

6

7 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL

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

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

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

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

12 material under seal.

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

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

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

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

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

18 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require good

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

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

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

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

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

24 sought to be filed under seal qualifies as confidential, privileged, or otherwise

25 protectable—constitute good cause.

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

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

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

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

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

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

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

6 the requested sealing order. Again, competent evidence supporting the application to

7 file documents under seal must be provided by declaration.

8 Any document that is not confidential, privileged, or otherwise protectable in

9 its entirety will not be filed under seal if the confidential portions can be redacted. If

10 documents can be redacted, then a redacted version for public viewing, omitting only

11 the confidential, privileged, or otherwise protectable portions of the document shall

12 be filed. Any application that seeks to file documents under seal in their entirety

13 should include an explanation of why redaction is not feasible.

14

15 2. DEFINITIONS

16 2.1 Action: this pending federal lawsuit.

17 2.2 Challenging Party: a Party or Non-Party that challenges the designation

18 of information or items under this Order.

19 2.3 “CONFIDENTIAL” Information or Items: information (regardless of

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

21 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good

22 Cause Statement.

23 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their

24 support staff).

25 2.5 Designating Party: a Party or Non-Party that designates information or

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

27 “CONFIDENTIAL.”

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1 2.6 Disclosure or Discovery Material: all items or information, regardless

2 of the medium or manner in which it is generated, stored, or maintained (including,

3 among other things, testimony, transcripts, and tangible things) that are produced or

4 generated in disclosures or responses to discovery in this matter.

5 2.7 Expert: a person with specialized knowledge or experience in a matter

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

7 an expert witness or as a consultant in this Action.

8 2.8 House Counsel: attorneys who are employees of a party to this Action.

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

10 counsel.

11 2.9 Non-Party: any natural person, partnership, corporation, association or

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

13 2.10 Outside Counsel of Record: attorneys who are not employees of a party

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

15 appeared in this Action on behalf of that party or are affiliated with a law firm that

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

17 2.11 Party: any party to this Action, including all of its officers, directors,

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

19 support staffs).

20 2.12 Producing Party: a Party or Non-Party that produces Disclosure or

21 Discovery Material in this Action.

22 2.13 Professional Vendors: persons or entities that provide litigation support

23 services (e.g., photocopying, videotaping, translating, preparing exhibits or

24 demonstrations, and organizing, storing, or retrieving data in any form or medium)

25 and their employees and subcontractors.

26 2.14 Protected Material: any Disclosure or Discovery Material that is

27 designated as “CONFIDENTIAL.”

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1 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material

2 from a Producing Party.

3

4 3. SCOPE

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

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

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

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

9 or their Counsel that might reveal Protected Material.

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

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

12

13 4. DURATION

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

15 CONFIDENTIAL or maintained pursuant to this protective order used or introduced

16 as an exhibit at trial becomes public and will be presumptively available to all

17 members of the public, including the press, unless compelling reasons supported by

18 specific factual findings to proceed otherwise are made to the trial judge in advance

19 of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause”

20 showing for sealing documents produced in discovery from “compelling reasons”

21 standard when merits-related documents are part of court record). Accordingly, the

22 terms of this protective order do not extend beyond the commencement of the trial.

23

24 5. DESIGNATING PROTECTED MATERIAL

25 5.1 Exercise of Restraint and Care in Designating Material for Protection.

26 Each Party or Non-Party that designates information or items for protection under this

27 Order must take care to limit any such designation to specific material that qualifies

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1 under the appropriate standards. The Designating Party must designate for protection

2 only those parts of material, documents, items or oral or written communications that

3 qualify so that other portions of the material, documents, items or communications

4 for which protection is not warranted are not swept unjustifiably within the ambit of

5 this Order.

6 Mass, indiscriminate or routinized designations are prohibited. Designations

7 that are shown to be clearly unjustified or that have been made for an improper

8 purpose (e.g., to unnecessarily encumber the case development process or to impose

9 unnecessary expenses and burdens on other parties) may expose the Designating Party

10 to sanctions.

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

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

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

14 5.2 Manner and Timing of Designations. Except as otherwise provided in

15 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise

16 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection

17 under this Order must be clearly so designated before the material is disclosed or

18 produced.

19 Designation in conformity with this Order requires:

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

21 documents, but excluding transcripts of depositions or other pretrial or trial

22 proceedings), that the Producing Party affix at a minimum, the legend

23 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that

24 contains protected material. If only a portion of the material on a page qualifies for

25 protection, the Producing Party also must clearly identify the protected portion(s)

26 (e.g., by making appropriate markings in the margins).

27 A Party or Non-Party that makes original documents available for inspection

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1 need not designate them for protection until after the inspecting Party has indicated

2 which documents it would like copied and produced. During the inspection and

3 before the designation, all of the material made available for inspection shall be

4 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents

5 it wants copied and produced, the Producing Party must determine which documents,

6 or portions thereof, qualify for protection under this Order. Then, before producing

7 the specified documents, the Producing Party must affix the “CONFIDENTIAL

8 legend” to each page that contains Protected Material. If only a portion of the material

9 on a page qualifies for protection, the Producing Party also must clearly identify the

10 protected portion(s) (e.g., by making appropriate markings in the margins).

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

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

13 all protected testimony.

14 (c) for information produced in some form other than documentary and for

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

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

17 “CONFIDENTIAL.” If only a portion or portions of the information warrants

18 protection, the Producing Party, to the extent practicable, shall identify the protected

19 portion(s).

20 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent

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

22 Designating Party’s right to secure protection under this Order for such material.

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

24 efforts to assure that the material is treated in accordance with the provisions of this

25 Order.

26

27 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

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1 6.1 Timing of Challenges. Any Party or Non-Party may challenge a

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

3 Scheduling Order.

4 6.2 Meet and Confer. The Challenging Party shall initiate the dispute

5 resolution process under Local Rule 37.1 et seq.

6 6.3 The burden of persuasion in any such challenge proceeding shall be on

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

8 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may

9 expose the Challenging Party to sanctions. Unless the Designating Party has waived

10 or withdrawn the confidentiality designation, all parties shall continue to afford the

11 material in question the level of protection to which it is entitled under the Producing

12 Party’s designation until the Court rules on the challenge.

13

14 7. ACCESS TO AND USE OF PROTECTED MATERIAL

15 7.1 Basic Principles. A Receiving Party may use Protected Material that is

16 disclosed or produced by another Party or by a Non-Party in connection with this

17 Action only for prosecuting, defending or attempting to settle this Action. Such

18 Protected Material may be disclosed only to the categories of persons and under the

19 conditions described in this Order. When the Action has been terminated, a Receiving

20 Party must comply with the provisions of section 13 below (FINAL DISPOSITION).

21 Protected Material must be stored and maintained by a Receiving Party at a

22 location and in a secure manner that ensures that access is limited to the persons

23 authorized under this Order.

24 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless

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

26 Receiving Party may disclose any information or item designated

27 “CONFIDENTIAL” only to:

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1 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well

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

3 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

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

8 “Acknowledgment and Agreement to Be Bound” (Exhibit A);

9 (d) the court and its personnel;

10 (e) court reporters and their staff;

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

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

13 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);

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

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

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

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

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

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

20 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise

21 agreed by the Designating Party or ordered by the court. Pages of transcribed

22 deposition testimony or exhibits to depositions that reveal Protected Material may be

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

24 permitted under this Stipulated Protective Order; and

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

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

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1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN

2 OTHER LITIGATION

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

4 that compels disclosure of any information or items designated in this Action as

5 “CONFIDENTIAL,” that Party must:

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

7 include a copy of the subpoena or court order;

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

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

10 or order is subject to this Protective Order. Such notification shall include a copy of

11 this Stipulated Protective Order; and

12 (c) cooperate with respect to all reasonable procedures sought to be pursued

13 by the Designating Party whose Protected Material may be affected.

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

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

16 as “CONFIDENTIAL” before a determination by the court from which the subpoena

17 or order issued, unless the Party has obtained the Designating Party’s permission. The

18 Designating Party shall bear the burden and expense of seeking protection in that court

19 of its confidential material and nothing in these provisions should be construed as

20 authorizing or encouraging a Receiving Party in this Action to disobey a lawful

21 directive from another court.

22

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

24 PRODUCED IN THIS LITIGATION

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

26 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information

27 produced by Non-Parties in connection with this litigation is protected by the

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1 remedies and relief provided by this Order. Nothing in these provisions should be

2 construed as prohibiting a Non-Party from seeking additional protections.

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

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

5 subject to an agreement with the Non-Party not to produce the Non-Party’s

6 confidential information, then the Party shall:

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

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

9 with a Non-Party;

10 (2) promptly provide the Non-Party with a copy of the Stipulated

11 Protective Order in this Action, the relevant discovery request(s), and a reasonably

12 specific description of the information requested; and

13 (3) make the information requested available for inspection by the Non-

14 Party, if requested.

15 (c) If the Non-Party fails to seek a protective order from this court within

16 14 days of receiving the notice and accompanying information, the Receiving Party

17 may produce the Non-Party’s confidential information responsive to the discovery

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

19 not produce any information in its possession or control that is subject to the

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

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

22 of seeking protection in this court of its Protected Material.

23

24 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

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

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

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1 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts

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

3 persons to whom unauthorized disclosures were made of all the terms of this Order,

4 and (d) request such person or persons to execute the “Acknowledgment and

5 Agreement to Be Bound” that is attached hereto as Exhibit A.

6

7 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

8 PROTECTED MATERIAL

9 When a Producing Party gives notice to Receiving Parties that certain

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

11 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil

12 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure

13 may be established in an e-discovery order that provides for production without prior

14 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the

15 parties reach an agreement on the effect of disclosure of a communication or

16 information covered by the attorney-client privilege or work product protection, the

17 parties may incorporate their agreement in the stipulated protective order submitted

18 to the court.

19

20 12. MISCELLANEOUS

21 12.1 Right to Further Relief. Nothing in this Order abridges the right of any

22 person to seek its modification by the Court in the future.

23 12.2 Right to Assert Other Objections. By stipulating to the entry of this

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

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

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

27 ground to use in evidence of any of the material covered by this Protective Order.

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1 12.3 Filing Protected Material. A Party that seeks to file under seal any

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

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

4 Protected Material at issue. If a Party’s request to file Protected Material under seal

5 is denied by the court, then the Receiving Party may file the information in the public

6 record unless otherwise instructed by the court.

7

8 13. FINAL DISPOSITION

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

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

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

12 subdivision, “all Protected Material” includes all copies, abstracts, compilations,

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

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

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

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

17 (by category, where appropriate) all the Protected Material that was returned or

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

19 abstracts, compilations, summaries or any other format reproducing or capturing any

20 of the Protected Material. Notwithstanding this provision, Counsel are entitled to

21 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing

22 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert

23 reports, attorney work product, and consultant and expert work product, even if such

24 materials contain Protected Material. Any such archival copies that contain or

25 constitute Protected Material remain subject to this Protective Order as set forth in

26 Section 4 (DURATION).

27 ///

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1 || 14. VIOLATION

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

3 || without limitation, contempt proceedings and/or monetary sanctions.

5 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD.

7 || DATED: July 21, 2022

9 || /s/ Nathan C. Volheim, Esq. (with permission)

10 Attorneys for Plaintiff

11

12 || DATED: July 21, 2022

13

14 || /s/Lawren_A. Zann

3 Attorneys for Defendant

16

17 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

18

19 || DATED: July 25, 2022

* | Raykin a, QC—

22 || United States Magisirate Judge

23

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1 EXHIBIT A

2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3

4 I, _____________________________ [print or type full name], of

5 _________________ [print or type full address], declare under penalty of perjury

6 that I have read in its entirety and understand the Stipulated Protective Order that

7 was issued by the United States District Court for the Central District of California

8 on [date] in the case of Emil Ebrahim, et al. v. Elite Financial Services, Inc.; Case

9 No. 2:22-cv-00890-DMG-RAO. I agree to comply with and to be bound by all the

10 terms of this Stipulated Protective Order and I understand and acknowledge that

11 failure to so comply could expose me to sanctions and punishment in the nature of

12 contempt. I solemnly promise that I will not disclose in any manner any

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

14 or entity except in strict compliance with the provisions of this Order.

15 I further agree to submit to the jurisdiction of the United States District Court for the

16 Central District of California for enforcing the terms of this Stipulated Protective

17 Order, even if such enforcement proceedings occur after termination of this action.

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

19 _______________________________________ [print or type full address and

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

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

22 Order.

23 Date: ______________________________________

24 City and State where sworn and signed: _________________________________

25 Printed name: _______________________________

26

27 Signature: __________________________________

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