Raquel Martin v. Jacobs Engineering Group, Inc.

Case 2:22-cv-06240-RGK-JEM Document 20 Filed 01/09/23 Page 1 of 16 Page ID #:208

NOTE CHANGES MADE TO

THIS DOCUMENT BY THE

1 Anita Grace Edwards (SBN 189468) COURT

anita@agedwardslaw.com

2 LAW OFFICES OF ANITA GRACE EDWARDS

3811 Long Beach Blvd., Ste. A

3 Long Beach, CA 90807

(562) 490-3825

4

Attorney for Plaintiff Raquel Martin

5

6 Jessica M. Iglesias (SBN 280484)

iglesias@sanchez-amador.com

7 SANCHEZ & AMADOR, LLP

800 S. Figueroa Street, 11th Floor

8 Los Angeles, California 90017

(213) 955-7200 Tel

9 (213) 955-7201 Fax

10 Attorneys for

Jacobs Engineering Group Inc.

11

12 UNITED STATES DISTRICT COURT

13 CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION

14

15 RAQUEL MARTIN, an individual, Case No. 2:22-cv-06240 RGK(JEMx)

16 Plaintiff, STIPULATED PROTECTIVE

ORDER

17 v.

18 JACOBS ENGINEERING GROUP

INC., a corporation and DOES 1

19 THROUGH 25, inclusive,

20 Defendants.

21

22 I. PURPOSES AND LIMITATIONS

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

24 proprietary, or private information for which special protection from public

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

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

27 enter the following Stipulated Protective Order. The parties acknowledge that this

28 Order does not confer blanket protections on all disclosures or responses to

434009.1

STIPULATED PROTECTIVE ORDER

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1 discovery and that the protection it affords from public disclosure and use extends

2 only to the limited information or items that are entitled to confidential treatment

3 under the applicable legal principles. The parties further acknowledge, as set forth

4 in Section XIII(C), below, that this Stipulated Protective Order does not entitle them

5 to file confidential information under seal; Civil Local Rule 79-5 sets forth the

6 procedures that must be followed and the standards that will be applied when a party

7 seeks permission from the Court to file material under seal.

8 II. GOOD CAUSE STATEMENT

9 This action is likely to involve confidential commercial, personnel,

10 proprietary, and personal medical information for which special protection from

11 public disclosure and from use for any purpose other than prosecution of this action

12 is warranted. Such confidential and proprietary materials and information consist of,

13 among other things, information regarding confidential recruitment practices, or

14 other confidential research, development, or commercial information (including

15 information implicating privacy rights of third parties), information otherwise

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

17 protected from disclosure under state or federal statutes, court rules, case decisions,

18 or common law. Accordingly, to expedite the flow of information, to facilitate the

19 prompt resolution of disputes over confidentiality of discovery materials, to

20 adequately protect information the parties are entitled to keep confidential, to ensure

21 that the parties are permitted reasonable necessary uses of such material in

22 preparation for and in the conduct of trial, to address their handling at the end of the

23 litigation, and serve the ends of justice, a protective order for such information is

24 justified in this matter. It is the intent of the parties that information will not be

25 designated as confidential for tactical reasons and that nothing be so designated

26 without a good faith belief that it has been maintained in a confidential, non-public

27 manner, and there is good cause why it should not be part of the public record of this

28 case.

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STIPULATED PROTECTIVE ORDER

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1 III. DEFINITIONS

2 A. Action: Raquel Martin v. Jacobs Engineering Group Inc., Case No.

3 2:22-cv-06240 RGK(JEMx).

4 B. Challenging Party: A Party or Non-Party that challenges the

5 designation of information or items under this Order.

6 C. “CONFIDENTIAL” Information or Items: Information (regardless of

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

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

9 the Good Cause Statement.

10 D. Counsel: Outside Counsel of Record and House Counsel (as well as

11 their support staff).

12 E. Designating Party: A Party or Non-Party that designates information or

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

14 “CONFIDENTIAL.”

15 F. Disclosure or Discovery Material: All items or information, regardless

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

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

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

19 G. Expert: A person with specialized knowledge or experience in a matter

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

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

22 H. House Counsel: Attorneys who are employees of a party to this Action.

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

24 counsel.

25 I. Non-Party: Any natural person, partnership, corporation, association,

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

27 J. Outside Counsel of Record: Attorneys who are not employees of a

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

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STIPULATED PROTECTIVE ORDER

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

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

3 K. Party: Any party to this Action, including all of its officers, directors,

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

5 support staffs).

6 L. Producing Party: A Party or Non-Party that produces Disclosure or

7 Discovery Material in this Action.

8 M. Professional Vendors: Persons or entities that provide litigation

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

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

11 and their employees and subcontractors.

12 N. Protected Material: Any Disclosure or Discovery Material that is

13 designated as “CONFIDENTIAL.”

14 O. Receiving Party: A Party that receives Disclosure or Discovery

15 Material from a Producing Party.

16 IV. SCOPE

17 A. The protections conferred by this Stipulation and Order cover not only

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

19 extracted from Protected Material; (2) all copies, excerpts, summaries, or

20 compilations of Protected Material; and (3) any testimony, conversations, or

21 presentations by Parties or their Counsel that might reveal Protected Material.

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

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

24 V. DURATION

25 Once a case proceeds to trial, all of the information that was designated as

26 confidential or maintained pursuant to this Protective Order becomes public and will

27 be presumptively available to all members of the public, including the press, unless

28 compelling reasons supported by specific factual findings to proceed otherwise are

434009.1 4

STIPULATED PROTECTIVE ORDER

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1 made to the trial judge in advance of the trial. See Kamakana v. City and County of

2 Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing “good cause”

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

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

5 terms of this Protective Order do not extend beyond the commencement of the trial.

6 VI. DESIGNATING PROTECTED MATERIAL

7 A. Exercise of Restraint and Care in Designating Material for Protection

8 1. Each Party or Non-Party that designates information or items for

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

10 material that qualifies under the appropriate standards. The Designating Party must

11 designate for protection only those parts of material, documents, items, or oral or

12 written communications that qualify so that other portions of the material,

13 documents, items, or communications for which protection is not warranted are not

14 swept unjustifiably within the ambit of this Order.

15 2. Mass, indiscriminate, or routinized designations are prohibited.

16 Designations that are shown to be clearly unjustified or that have been made for an

17 improper purpose (e.g., to unnecessarily encumber the case development process or

18 to impose unnecessary expenses and burdens on other parties) may expose the

19 Designating Party to sanctions.

20 3. If it comes to a Designating Party’s attention that information or

21 items that it designated for protection do not qualify for protection, that Designating

22 Party must promptly notify all other Parties that it is withdrawing the inapplicable

23 designation.

24 B. Manner and Timing of Designations

25 1. Except as otherwise provided in this Order (see, e.g., Section

26 B(2)(b) below), or as otherwise stipulated or ordered, Disclosure or Discovery

27 Material that qualifies for protection under this Order must be clearly so designated

28 before the material is disclosed or produced.

434009.1 5

STIPULATED PROTECTIVE ORDER

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1 2. Designation in conformity with this Order requires the following:

2 a. For information in documentary form (e.g., paper or

3 electronic documents, but excluding transcripts of depositions or other

4 pretrial or trial proceedings), that the Producing Party affix at a

5 minimum, the legend “CONFIDENTIAL” (hereinafter

6 “CONFIDENTIAL legend”), to each page that contains protected

7 material. If only a portion or portions of the material on a page

8 qualifies for protection, the Producing Party also must clearly identify

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

10 margins).

11 b. A Party or Non-Party that makes original documents

12 available for inspection need not designate them for protection until

13 after the inspecting Party has indicated which documents it would like

14 copied and produced. During the inspection and before the

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

16 deemed “CONFIDENTIAL.” After the inspecting Party has identified

17 the documents it wants copied and produced, the Producing Party must

18 determine which documents, or portions thereof, qualify for protection

19 under this Order. Then, before producing the specified documents, the

20 Producing Party must affix the “CONFIDENTIAL legend” to each

21 page that contains Protected Material. If only a portion or portions of

22 the material on a page qualifies for protection, the Producing Party also

23 must clearly identify the protected portion(s) (e.g., by making

24 appropriate markings in the margins).

25 c. For testimony given in depositions, that the Designating

26 Party identify the Disclosure or Discovery Material on the record,

27 before the close of the deposition all protected testimony.

28 d. For information produced in form other than document

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STIPULATED PROTECTIVE ORDER

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1 and for any other tangible items, that the Producing Party affix in a

2 prominent place on the exterior of the container or containers in which

3 the information is stored the legend “CONFIDENTIAL.” If only a

4 portion or portions of the information warrants protection, the

5 Producing Party, to the extent practicable, shall identify the protected

6 portion(s).

7 C. Inadvertent Failure to Designate

8 1. If timely corrected, an inadvertent failure to designate qualified

9 information or items does not, standing alone, waive the Designating Party’s right to

10 secure protection under this Order for such material. Upon timely correction of a

11 designation, the Receiving Party must make reasonable efforts to assure that the

12 material is treated in accordance with the provisions of this Order.

13 VII. CHALLENGING CONFIDENTIALITY DESIGNATIONS

14 A. Timing of Challenges

15 1. Any party or Non-Party may challenge a designation of

16 confidentiality at any time that is consistent with the Court’s Scheduling Order.

17 B. Meet and Confer

18 1. The Challenging Party shall initiate the dispute resolution

19 process under Local Rule 37.1 et seq.

20 C. The burden of persuasion in any such challenge proceeding shall be on

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

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

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

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

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

26 entitled under the Producing Party’s designation until the Court rules on the

27 challenge.

28

434009.1 7

STIPULATED PROTECTIVE ORDER

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1 VIII. ACCESS TO AND USE OF PROTECTED MATERIAL

2 A. Basic Principles

3 1. A Receiving Party may use Protected Material that is disclosed

4 or produced by another Party or by a Non-Party in connection with this Action only

5 for prosecuting, defending, or attempting to settle this Action. Such Protected

6 Material may be disclosed only to the categories of persons and under the conditions

7 described in this Order. When the Action has been terminated, a Receiving Party

8 must comply with the provisions of Section XIV below.

9 2. Protected Material must be stored and maintained by a Receiving

10 Party at a location and in a secure manner that ensures that access is limited to the

11 persons authorized under this Order.

12 B. Disclosure of “CONFIDENTIAL” Information or Items

13 1. Unless otherwise ordered by the Court or permitted in writing by

14 the Designating Party, a Receiving Party may disclose any information or item

15 designated “CONFIDENTIAL” only to:

16 a. The Receiving Party’s Outside Counsel of Record in this

17 Action, as well as employees of said Outside Counsel of Record to

18 whom it is reasonably necessary to disclose the information for this

19 Action;

20 b. The officers, directors, and employees (including House

21 Counsel) of the Receiving Party to whom disclosure is reasonably

22 necessary for this Action;

23 c. Experts (as defined in this Order) of the Receiving Party to

24 whom disclosure is reasonably necessary for this Action and who have

25 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit

26 A);

27 d. The Court and its personnel;

28 e. Court reporters and their staff;

434009.1 8

STIPULATED PROTECTIVE ORDER

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1 f. Professional jury or trial consultants, mock jurors, and

2 Professional Vendors to whom disclosure is reasonably necessary for

3 this Action and who have signed the “Acknowledgment and Agreement

4 to be Bound” attached as Exhibit A hereto;

5 g. The author or recipient of a document containing the

6 information or a custodian or other person who otherwise possessed or

7 knew the information;

8 h. During their depositions, witnesses, and attorneys for

9 witnesses, in the Action to whom disclosure is reasonably necessary

10 provided: (i) the deposing party requests that the witness sign the

11 “Acknowledgment and Agreement to Be Bound;” and (ii) they will not

12 be permitted to keep any confidential information unless they sign the

13 “Acknowledgment and Agreement to Be Bound,” unless otherwise

14 agreed by the Designating Party or ordered by the Court. Pages of

15 transcribed deposition testimony or exhibits to depositions that reveal

16 Protected Material may be separately bound by the court reporter and

17 may not be disclosed to anyone except as permitted under this

18 Stipulated Protective Order; and

19 i. Any mediator or settlement officer, and their supporting

20 personnel, mutually agreed upon by any of the parties engaged in

21 settlement discussions.

22 IX. PROTECTED MATERIAL SUBPOENAED OR ORDERED

23 PRODUCED IN OTHER LITIGATION

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

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

26 Action as “CONFIDENTIAL,” that Party must:

27 1. Promptly notify in writing the Designating Party. Such

28 notification shall include a copy of the subpoena or court order;

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1 2. Promptly notify in writing the party who caused the subpoena or

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

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

4 a copy of this Stipulated Protective Order; and

5 3. Cooperate with respect to all reasonable procedures sought to be

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

7 B. If the Designating Party timely seeks a protective order, the Party

8 served with the subpoena or court order shall not produce any information

9 designated in this action as “CONFIDENTIAL” before a determination by the Court

10 from which the subpoena or order issued, unless the Party has obtained the

11 Designating Party’s permission. The Designating Party shall bear the burden and

12 expense of seeking protection in that court of its confidential material and nothing in

13 these provisions should be construed as authorizing or encouraging a Receiving

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

15 X. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

16 PRODUCED IN THIS LITIGATION

17 A. The terms of this Order are applicable to information produced by a

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

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

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

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

22 B. In the event that a Party is required, by a valid discovery request, to

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

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

25 confidential information, then the Party shall:

26 1. Promptly notify in writing the Requesting Party and the Non-

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

28 agreement with a Non-Party;

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STIPULATED PROTECTIVE ORDER

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1 2. Promptly provide the Non-Party with a copy of the Stipulated

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

3 specific description of the information requested; and

4 3. Make the information requested available for inspection by the

5 Non-Party, if requested.

6 C. If the Non-Party fails to seek a protective order from this court within

7 14 days of receiving the notice and accompanying information, the Receiving Party

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

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

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

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

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

13 expense of seeking protection in this court of its Protected Material.

14 XI. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

15 A. If a Receiving Party learns that, by inadvertence or otherwise, it has

16 disclosed Protected Material to any person or in any circumstance not authorized

17 under this Stipulated Protective Order, the Receiving Party must immediately (1)

18 notify in writing the Designating Party of the unauthorized disclosures, (2) use its

19 best efforts to retrieve all unauthorized copies of the Protected Material, (3) inform

20 the person or persons to whom unauthorized disclosures were made of all the terms

21 of this Order, and (4) request such person or persons to execute the

22 “Acknowledgment and Agreement to be Bound” that is attached hereto as Exhibit

23 A.

24 XII. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

25 PROTECTED MATERIAL

26 A. When a Producing Party gives notice to Receiving Parties that certain

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

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

434009.1 11

STIPULATED PROTECTIVE ORDER

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

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

3 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and

4 (e), insofar as the parties reach an agreement on the effect of disclosure of a

5 communication or information covered by the attorney-client privilege or work

6 product protection, the parties may incorporate their agreement in the Stipulated

7 Protective Order submitted to the Court.

8 XIII. MISCELLANEOUS

9 A. Right to Further Relief

10 1. Nothing in this Order abridges the right of any person to seek its

11 modification by the Court in the future.

12 B. Right to Assert Other Objections

13 1. By stipulating to the entry of this Protective Order, no Party

14 waives any right it otherwise would have to object to disclosing or producing any

15 information or item on any ground not addressed in this Stipulated Protective Order.

16 Similarly, no Party waives any right to object on any ground to use in evidence of

17 any of the material covered by this Protective Order.

18 C. Filing Protected Material

19 1. A Party that seeks to file under seal any Protected Material must

20 comply with Civil Local Rule 79-5. Protected Material may only be filed under seal

21 pursuant to a court order authorizing the sealing of the specific Protected Material at

22 issue. If a Party's request to file Protected Material under seal is denied by the

23 Court, then the Receiving Party may file the information in the public record unless

24 otherwise instructed by the Court.

25 XIV. FINAL DISPOSITION

26 A. After the final disposition of this Action, as defined in Section V,

27 within sixty (60) days of a written request by the Designating Party, each Receiving

28 Party must return all Protected Material to the Producing Party or destroy such

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STIPULATED PROTECTIVE ORDER

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1 material. As used in this subdivision, “all Protected Material” includes all copies,

2 abstracts, compilations, summaries, and any other format reproducing or capturing

3 any of the Protected Material. Whether the Protected Material is returned or

4 destroyed, the Receiving Party must submit a written certification to the Producing

5 Party (and, if not the same person or entity, to the Designating Party) by the 60 day

6 deadline that (1) identifies (by category, where appropriate) all the Protected

7 Material that was returned or destroyed and (2) affirms that the Receiving Party has

8 not retained any copies, abstracts, compilations, summaries or any other format

9 reproducing or capturing any of the Protected Material. Notwithstanding this

10 provision, Counsel are entitled to retain an archival copy of all pleadings, motion

11 papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence,

12 deposition and trial exhibits, expert reports, attorney work product, and consultant

13 and expert work product, even if such materials contain Protected Material. Any

14 such archival copies that contain or constitute Protected Material remain subject to

15 this Protective Order as set forth in Section V.

16 B. Any violation of this Order may be punished by any and all appropriate

17 measures including, without limitation, contempt proceedings and/or monetary

18 sanctions.

19 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

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STIPULATED PROTECTIVE ORDER

Case 2:42-cv-06240-RGK-JEM Document 20 Filed 01/09/23 Page 14 0f16 Page ID #:221

1} DATED: January 5, 2023 LAW OFFICE OF ANITA GRACE

4 EDWARDS

ikntla G. Edwards 7

4 a G. Edwards

Attorneys for Ptamtiff Raquel Martin

5

DATED: January 5, 2023 SANCHEZ & AMADOR, LLP

9 Lifehind —___

M, aJ. Reyes

10 Jessica M. Iglesias

Attorneys for Jacobs Engineering Group

Inc.

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l ORDER

2 FOR GOOD CAUSE SHOWN, the Court hereby approves the parties’

3 || Stipulated Protective Order.

4 IT IS SO ORDERED.

6|| DATED: January 9, 2023 ph Wadena}

United States Magistrate Judge

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1 EXHIBIT A

2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

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

4 ___________________________[print or type full address], declare under penalty

5 of perjury that I have read in its entirety and understand the Stipulated Protective

6 Order that was issue by the United States District Court for the Central District of

7 California on _________ [DATE] in the case of Raquel Martin v. Jacobs

8 Engineering Group Inc., 22-cv-06240 RGK(JEMx). I agree to comply with and to

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

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

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

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

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

14 I further agree to submit to the jurisdiction of the United States District

15 Court for the Central District of California for the purpose of enforcing the terms of

16 this Stipulated Protective Order, even if such enforcement proceedings occur after

17 termination of this action. I hereby appoint ___________________ [print or type

18 full name] of ____________________________ [print or type full address and

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

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

21 Order.

22 Date: _____________________

23 City and State where sworn and signed: __________________________

24 Printed Name: ________________________

25 Signature: ________________________

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STIPULATED PROTECTIVE ORDER