distinguishing “good cause” showing for sealing documents produced 16 in discovery from “compelling reasons” standard when merits-related documents are 17 part of court record
How later courts described this case
- distinguishing “good cause” showing for sealing documents produced 16 in discovery from “compelling reasons” standard when merits-related documents are 17 part of court record
Written by the judges who cited it.
The opinion
Case 2:22-cv-06152-SB-AS Document 35 Filed 10/14/22 Page 1 of 15 Page ID #:1652
1 Thomas C. Cronin (SBN 200754)
CRONIN & CO., LTD.
2 120 North LaSalle Street, 20th Floor
Chicago, Illinois 60602
3 Tel: 312-500-2100
tcc@cronincoltd.com
4
Robert R. Duncan
5 James Podolny
DUNCAN LAW GROUP, LLC
6 161 North Clark Street, Suite 2550
Chicago, Illinois 60601
7 Tel: 312-202-3283
rrd@duncanlawgroup.com
8 jp@duncanlawgroup.com
9 Attorneys for Plaintiffs
BARBARA McHUGH et al.
10
DENTONS US LLP
11 MICHAEL J. DUVALL (SBN 276994)
michael.duvall@dentons.com
12 SANDRA D. HAUSER
sandra.hauser@dentons.com
13 DREW W. MARROCCO
drew.marrocco@dentons.com
14 MARILYN B. ROSEN
marilyn.rosen@dentons.com
15 601 South Figueroa Street, Suite 2500
Los Angeles, California 90017-5704
16 Tel: 213-623-9300 / Fax: 213-623-9924
17 Attorneys for Defendant
METROPOLITAN LIFE INSURANCE COMPANY
18
19 UNITED STATES DISTRICT COURT
20 CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION
21 BARBARA MCHUGH, CHARLES Case No. 2:22-cv-6152
PATRICK MCHUGH, JOHN
Honorable Stanley Blumenfeld, Jr.
22 ELLSWORTH, and all others similarly
situated,
23 STIPULATED PROTECTIVE
Plaintiffs, ORDER
24
v.
25
METROPOLITAN LIFE INSURANCE
26 COMPANY, a New York Corporation;
27 Defendant.
28
1
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1 STIPULATED PROTECTIVE ORDER
2 1. A. PURPOSES AND LIMITATIONS
3 Discovery in this action is likely to involve production of confidential,
4 proprietary or private information for which special protection from public disclosure
5 and from use for any purpose other than prosecuting this litigation may be warranted.
6 Accordingly, the parties hereby stipulate to and petition the Court to enter the
7 following Stipulated Protective Order. The parties acknowledge that this Order does
8 not confer blanket protections on all disclosures or responses to discovery and that
9 the protection it affords from public disclosure and use extends only to the limited
10 information or items that are entitled to confidential treatment under the applicable
11 legal principles. The parties further acknowledge, as set forth in Section 12.3 below,
12 that this Stipulated Protective Order does not entitle them to file confidential
13 information under seal; Civil Local Rule 79-5 sets forth the procedures that must be
14 followed and the standards that will be applied when a party seeks permission from
15 the court to file material under seal.
16 B. GOOD CAUSE STATEMENT
17 This action is likely to involve trade secrets, customer and pricing lists and
18 other valuable research, actuarial methodologies, processes, and assumptions,
19 development, commercial, financial, technical and/or proprietary information for
20 which special protection from public disclosure and from use for any purpose other
21 than prosecution of this action is warranted. Such confidential and proprietary
22 materials and information consist of, among other things, confidential business or
23 financial information, information regarding confidential business practices, or other
24 confidential research, development, or commercial information (including
25 information implicating privacy rights of third parties), information otherwise
26 generally unavailable to the public, or which may be privileged or otherwise
27 protected from disclosure under state or federal statutes, court rules, case decisions,
28
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1 or common law. Accordingly, to expedite the flow of information, to facilitate the
2 prompt resolution of disputes over confidentiality of discovery materials, to
3 adequately protect information the parties are entitled to keep confidential, to ensure
4 that the parties are permitted reasonable necessary uses of such material in
5 preparation for and in the conduct of trial, to address their handling at the end of the
6 litigation, and serve the ends of justice, a protective order for such information is
7 justified in this matter. It is the intent of the parties that information will not be
8 designated as confidential for tactical reasons and that nothing be so designated
9 without a good faith belief that it has been maintained in a confidential, non-public
10 manner, and there is good cause why it should not be part of the public record of this
11 case.
12 .2. DEFINITIONS
13 2.1 Action: McHugh, et al. v. Metropolitan Life Insurance Company, Case
14 Number 2:22-cv-6152, pending in the United States District Court for the Central
15 District of California.
16 2.2 Challenging Party: a Party or Non-Party that challenges the designation
17 of information or items under this Order.
18 2.3 “CONFIDENTIAL” Information or Items: information (regardless of
19 how it is generated, stored or maintained) or tangible things that qualify for protection
20 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good
21 Cause Statement.
22 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as
23 their support staff).
24 2.5 Designating Party: a Party or Non-Party that designates information or
25 items that it produces in disclosures or in responses to discovery as
26 “CONFIDENTIAL.”
27 2.6 Disclosure or Discovery Material: all items or information, regardless
28 of the medium or manner in which it is generated, stored, or maintained (including,
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1 among other things, testimony, transcripts, and tangible things), that are produced or
2 generated in disclosures or responses to discovery in this matter.
3 2.7 Expert: a person with specialized knowledge or experience in a matter
4 pertinent to the litigation who has been retained by a Party or its counsel to serve as
5 an expert witness or as a consultant in this Action.
6 2.8 House Counsel: attorneys who are employees of a party to this Action.
7 House Counsel does not include Outside Counsel of Record or any other outside
8 counsel.
9 2.9 Non-Party: any natural person, partnership, corporation, association or
10 other legal entity not named as a Party to this action.
11 2.10 Outside Counsel of Record: attorneys who are not employees of a party
12 to this Action but are retained to represent or advise a party to this Action and have
13 appeared in this Action on behalf of that party or are affiliated with a law firm that
14 has appeared on behalf of that party, and includes support staff.
15 2.11 Party: any party to this Action, including all of its officers, directors,
16 employees, consultants, retained experts, and Outside Counsel of Record (and their
17 support staffs).
18 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
19 Discovery Material in this Action.
20 2.13 Professional Vendors: persons or entities that provide litigation support
21 services (e.g., photocopying, videotaping, translating, preparing exhibits or
22 demonstrations, and organizing, storing, or retrieving data in any form or medium)
23 and their employees and subcontractors.
24 2.14 Protected Material: any Disclosure or Discovery Material that is
25 designated as “CONFIDENTIAL.”
26 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material
27 from a Producing Party.
28 3. SCOPE
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1 The protections conferred by this Stipulation and Order cover not only
2 Protected Material (as defined above), but also (1) any information copied or
3 extracted from Protected Material; (2) all copies, excerpts, summaries, or
4 compilations of Protected Material; and (3) any testimony, conversations, or
5 presentations by Parties or their Counsel that might reveal Protected Material.
6 Any use of Protected Material at trial shall be governed by the orders of the
7 trial judge. This Order does not govern the use of Protected Material at trial.
8 4. DURATION
9 Once a case proceeds to trial, information that was designated as
10 CONFIDENTIAL or maintained pursuant to this protective order used or introduced
11 as an exhibit at trial becomes public and will be presumptively available to all
12 members of the public, including the press, unless compelling reasons supported by
13 specific factual findings to proceed otherwise are made to the trial judge in advance
14 of the trial. See Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1180-81
15 (9th Cir. 2006) (distinguishing “good cause” showing for sealing documents produced
16 in discovery from “compelling reasons” standard when merits-related documents are
17 part of court record). Accordingly, the terms of this protective order do not extend
18 beyond the commencement of the trial.
19 5. DESIGNATING PROTECTED MATERIAL
20 5.1 Exercise of Restraint and Care in Designating Material for Protection.
21 Each Party or Non-Party that designates information or items for protection under
22 this Order must take care to limit any such designation to specific material that
23 qualifies under the appropriate standards. The Designating Party must designate for
24 protection only those parts of material, documents, items, or oral or written
25 communications that qualify so that other portions of the material, documents, items,
26 or communications for which protection is not warranted are not swept unjustifiably
27 within the ambit of this Order.
28 Mass, indiscriminate, or routinized designations are prohibited. Designations
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1 that are shown to be clearly unjustified or that have been made for an improper
2 purpose (e.g. to unnecessarily encumber the case development process or to impose
3 unnecessary expenses and burdens on other parties) may expose the Designating
4 Party to sanctions.
5 If it comes to a Designating Party’s attention that information or items that it
6 designated for protection do not qualify for protection, that Designating Party must
7 promptly notify all other Parties that it is withdrawing the inapplicable designation.
8 5.2 Manner and Timing of Designations. Except as otherwise provided in
9 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
10 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
11 under this Order must be clearly so designated before the material is disclosed or
12 produced.
13 Designation in conformity with this Order requires:
14 (a) for information in documentary form (e.g., paper or electronic
15 documents, but excluding transcripts of depositions or other pretrial or trial
16 proceedings), that the Producing Party affix at a minimum, the legend
17 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
18 contains protected material. If only a portion or portions of the material on a page
19 qualifies for protection, the Producing Party also must clearly identify the protected
20 portion(s) (e.g., by making appropriate markings in the margins).
21 A Party or Non-Party that makes original documents available for inspection
22 need not designate them for protection until after the inspecting Party has indicated
23 which documents it would like copied and produced. During the inspection and
24 before the designation, all of the material made available for inspection shall be
25 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents
26 it wants copied and produced, the Producing Party must determine which documents,
27 or portions thereof, qualify for protection under this Order. Then, before producing
28 the specified documents, the Producing Party must affix the “CONFIDENTIAL
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1 legend” to each page that contains Protected Material. If only a portion or portions
2 of the material on a page qualifies for protection, the Producing Party must clearly
3 identify the protected portion(s) (e.g. by making appropriate markings in the
4 margins).
5 (b) for testimony given in depositions, the entire transcript is treated as
6 confidential for 30 days during which time the parties may designate portions of the
7 record as CONFIDENTIAL.
8 (c) for information produced in some form other than documentary and for
9 any other tangible items, that the Producing Party affix in a prominent place on the
10 exterior of the container or containers in which the information is stored the legend
11 “CONFIDENTIAL.”
12 5.3 Inadvertent Failures to Designate. If timely corrected after discovery an
13 inadvertent failure to designate qualified information or items does not, standing
14 alone, waive the Designating Party’s right to secure protection under this Order for
15 such material. Upon timely correction of a designation, the Receiving Party must
16 make reasonable efforts to assure that the material is treated in accordance with the
17 provisions of this Order.
18 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
19 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
20 designation of confidentiality at any time that is consistent with the Court’s
21 Scheduling Order.
22 6.2 Meet and Confer. The Challenging Party shall initiate the informal
23 dispute resolution process set forth in the Court's Procedures and Schedules. See
24 http://www.cacd.uscourts.gov/honorable-alka-sagar
25 6.3 Joint Stipulation. Any challenge submitted to the Court shall be via a
26 joint stipulation pursuant to Local Rule 37-2.
27 6.4 The burden of persuasion in any such challenge proceeding shall be on
28 the Designating Party. Frivolous challenges, and those made for an improper purpose
Case No. 2:22-cv-6152 AGREED PROTECTIVE ORDER
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1 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may
2 expose the Challenging Party to sanctions. Unless the Designating Party has waived
3 or withdrawn the confidentiality designation, all parties shall continue to afford the
4 material in question the level of protection to which it is entitled under the Producing
5 Party’s designation until the Court rules on the challenge.
6 7. ACCESS TO AND USE OF PROTECTED MATERIAL
7 7.1 Basic Principles. A Receiving Party may use Protected Material that is
8 disclosed or produced by another Party or by a Non-Party in connection with this
9 Action only for prosecuting, defending or attempting to settle this Action. Such
10 Protected Material may be disclosed only to the categories of persons and under the
11 conditions described in this Order. When the Action has been terminated, a Receiving
12 Party must comply with the provisions of section 13 below (FINAL DISPOSITION).
13 Protected Material must be stored and maintained by a Receiving Party at a
14 location and in a secure manner that ensures that access is limited to the persons
15 authorized under this Order.
16 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
17 otherwise ordered by the court or permitted in writing by the Designating Party, a
18 Receiving Party may disclose any information or item designated
19 “CONFIDENTIAL” only to:
20 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well
21 as employees of said Outside Counsel of Record to whom it is reasonably necessary
22 to disclose the information for this Action;
23 (b) the officers, directors, and employees (including House Counsel) of the
24 Receiving Party to whom disclosure is reasonably necessary for this Action;
25 (c) Experts (as defined in this Order) of the Receiving Party to whom
26 disclosure is reasonably necessary for this Action and who have signed the
27 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
28 (d) the court and its personnel;
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1 (e) court reporters and their staff;
2 (f) professional jury or trial consultants, mock jurors, and Professional
3 Vendors to whom disclosure is reasonably necessary for this Action and who have
4 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
5 (g) the author or recipient of a document containing the information or a
6 custodian or other person who otherwise possessed or knew the information;
7 (h) during their depositions, witnesses, and attorneys for witnesses, in the
8 Action to whom disclosure is reasonably necessary provided: (1) the deposing party
9 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will
10 not be permitted to keep any confidential information unless they sign the
11 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
12 agreed by the Designating Party or ordered by the court. Pages of transcribed
13 deposition testimony or exhibits to depositions that reveal Protected Material may be
14 separately bound by the court reporter and may not be disclosed to anyone except as
15 permitted under this Stipulated Protective Order; and
16 (i) any mediator or settlement officer, and their supporting personnel,
17 mutually agreed upon by any of the parties engaged in settlement discussions.
18 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
19 IN OTHER LITIGATION
20 If a Party is served with a subpoena or a court order issued in other litigation
21 that compels disclosure of any information or items designated in this Action as
22 “CONFIDENTIAL,” that Party must:
23 (a) promptly notify in writing the Designating Party. Such notification shall
24 include a copy of the subpoena or court order;
25 (b) promptly notify in writing the party who caused the subpoena or order
26 to issue in the other litigation that some or all of the material covered by the subpoena
27 or order is subject to this Protective Order. Such notification shall include a copy of
28 this Stipulated Protective Order; and
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1 (c) cooperate with respect to all reasonable procedures sought to be pursued
2 by the Designating Party whose Protected Material may be affected.
3 If the Designating Party timely seeks a protective order, the Party served with
4 the subpoena or court order shall not produce any information designated in this
5 action as “CONFIDENTIAL” before a determination by the court from which the
6 subpoena or order issued, unless the Party has obtained the Designating Party’s
7 permission. The Designating Party shall bear the burden and expense of seeking
8 protection in that court of its confidential material and nothing in these provisions
9 should be construed as authorizing or encouraging a Receiving Party in this Action
10 to disobey a lawful directive from another court.
11 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
12 PRODUCED IN THIS LITIGATION
13 (a) The terms of this Order are applicable to information produced by a
14 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
15 produced by Non-Parties in connection with this litigation is protected by the
16 remedies and relief provided by this Order. Nothing in these provisions should be
17 construed as prohibiting a Non-Party from seeking additional protections.
18 (b) In the event that a Party is required, by a valid discovery request, to
19 produce a Non-Party’s confidential information in its possession, and the Party is
20 subject to an agreement with the Non-Party not to produce the Non-Party’s
21 confidential information, then the Party shall:
22 (1) promptly notify in writing the Requesting Party and the Non-
23 Party that some or all of the information requested is subject to a confidentiality
24 agreement with a Non-Party;
25 (2) promptly provide the Non-Party with a copy of the Stipulated
26 Protective Order in this Action, the relevant discovery request(s), and a reasonably
27 specific description of the information requested; and
28 (3) make the information requested available for inspection by the
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1 Non-Party, if requested.
2 (c) If the Non-Party fails to seek a protective order from this court within
3 14 days of receiving the notice and accompanying information, the Receiving Party
4 may produce the Non-Party’s confidential information responsive to the discovery
5 request. If the Non-Party timely seeks a protective order, the Receiving Party shall
6 not produce any information in its possession or control that is subject to the
7 confidentiality agreement with the Non-Party before a determination by the court.
8 Absent a court order to the contrary, the Non-Party shall bear the burden and expense
9 of seeking protection in this court of its Protected Material.
10 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
11 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
12 Protected Material to any person or in any circumstance not authorized under this
13 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
14 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
15 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
16 persons to whom unauthorized disclosures were made of all the terms of this Order,
17 and (d) request such person or persons to execute the “Acknowledgment and
18 Agreement to Be Bound” that is attached hereto as Exhibit A.
19 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
20 PROTECTED MATERIAL
21 When a Producing Party gives notice to Receiving Parties that certain
22 inadvertently produced material is subject to a claim of privilege or other protection,
23 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
24 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
25 may be established in an e-discovery order that provides for production without prior
26 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
27 parties reach an agreement on the effect of disclosure of a communication or
28 information covered by the attorney-client privilege or work product protection, the
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1 parties may incorporate their agreement in the stipulated protective order submitted
2 to the court.
3 12. MISCELLANEOUS
4 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
5 person to seek its modification by the Court in the future.
6 12.2 Right to Assert Other Objections. By stipulating to the entry of this
7 Protective Order, no Party waives any right it otherwise would have to object to
8 disclosing or producing any information or item on any ground not addressed in
9 this Stipulated Protective Order. Similarly, no Party waives any right to object on
10 any ground to use in evidence of any of the material covered by this Protective
11 Order.
12 12.3 Filing Protected Material. A Party that seeks to file under seal any
13 Protected Material must comply with Civil Local Rule 79-5. Protected Material
14 may only be filed under seal pursuant to a court order authorizing the sealing of the
15 specific Protected Material at issue. If a Party’s request to file Protected Material
16 under seal is denied by the court, then the Receiving Party may file the information
17 in the public record unless otherwise instructed by the court.
18 13. FINAL DISPOSITION
19 After the final disposition of this Action, as defined in paragraph 4, within 60
20 days of a written request by the Designating Party, each Receiving Party must return
21 all Protected Material to the Producing Party or destroy such material. As used in this
22 subdivision, “all Protected Material” includes all copies, abstracts, compilations,
23 summaries, and any other format reproducing or capturing any of the Protected
24 Material. Whether the Protected Material is returned or destroyed, the Receiving
25 Party must submit a written certification to the Producing Party (and, if not the same
26 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies
27 (by category, where appropriate) all the Protected Material that was returned or
28 destroyed and (2) affirms that the Receiving Party has made best efforts to confirm
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1 that it has not retained any copies, abstracts, compilations, summaries or any other
2 format reproducing or capturing any of the Protected Material. Notwithstanding this
3 provision, Counsel are entitled to retain an archival copy of all pleadings, motion
4 papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence,
5 deposition and trial exhibits, expert reports, attorney work product, and consultant
6 and expert work product, even if such materials contain Protected Material. Any such
7 archival copies that contain or constitute Protected Material remain subject to this
8 Protective Order as set forth in Section 4 (DURATION). In addition,
9 notwithstanding this provision, (i) the Parties shall have the right to retain all
10 Protected Material in their respective possessions that they are required to maintain
11 to fulfill their potential obligations to their reinsurers, insurers, regulators and/or
12 auditors, or as otherwise required by law or regulation, or (ii) that are retained as part
13 of an electronic backup, recovery or archival system, so long as such Information is
14 not accessible in the ordinary course of business and is not accessed except as
15 required by law, regulation or legal process or for backup, recovery, contingency
16 planning or business continuity planning purposes. Any such archival copies that
17 contain or constitute Protected Material remain subject to this Protective Order.
18 14. VIOLATION
19 Any violation of this Order may be punished by appropriate measures
20 including, without limitation, contempt proceedings and/or monetary sanctions.
21
IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
22
23
24
25
26
27
28
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1
DATED: October 12, 2022
2
/s Thomas C. Cronin
3
Attorneys for Plaintiffs
4
/s Michael J. Duvall
5 Attorneys for Defendant
6
FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
7
8
DATED: 10/14/2022
9
10 /s/
Honorable Alka Sagar
11 United States Magistrate Judge
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
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1 EXHIBIT A
2 ACKNOWLEDGEMENT AND AGREEMENT TO BE BOUND
I, [print or type full name], of
3
[print or type full address],
4
declare under penalty of perjury that I have read in its entirety and understand the
5
Stipulated Protective Order that was issued by the United States District Court for
6
the Central District of California on [date] in the case of
7
8 [insert formal name of the case and the number and initials assigned to it by
9
the court]. I agree to comply with and to be bound by all terms of this Stipulated
Protective Order and I understand and acknowledge that failure to so comply could
10
expose me to sanctions and punishment in the nature of contempt. I solemnly
11
promise that I will not disclose in any manner any information or item that is
12
subject to this Stipulated Protective Order to any person or entity except in strict
13
compliance with the provisions of this Order. I further agree to submit to the
14
jurisdiction of the United States District Court for the Central District of California
15
for enforcing the terms of this Stipulated Protective Order, even if such
16
enforcement proceedings occur after termination of this action. I hereby appoint
17
[print or type full name] of
18
[print or type full address and telephone
19
number] as my California agent for service of process in connection with this action
20
or any proceedings related to enforcement of this Stipulated Protective Order.
21
Date:
22
City and State where sworn and signed:
23
Printed name:
24
25
Signature:
26
27
28
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15