discussing privacy of financial information
How later courts described this case
- discussing privacy of financial information
Written by the judges who cited it.
The opinion
Case 2:22-cv-07770-DSF-PVC Document 33 Filed 03/17/23 Page 1 of 15 Page ID #:219
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8 UNITED STATES DISTRICT COURT
9 CENTRAL DISTRICT OF CALIFORNIA
10
11 Shanan Guinn, Case No. 2:22-CV-07770-DSF
(PVCx)
12 Plaintiff,
13 v. STIPULATED PROTECTIVE
ORDER
14 The Walt Disney Company,
15
Defendant.
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17
18 1. INTRODUCTION
19 1.1 PURPOSES AND LIMITATIONS
20 Discovery in this action is likely to involve production of confidential,
21 proprietary, or private information for which special protection from public
22 disclosure and from use for any purpose other than prosecuting this litigation may
23 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to
24 enter the following Stipulated Protective Order. The parties acknowledge that this
25 Order does not confer blanket protections on all disclosures or responses to
26 discovery and that the protection it affords from public disclosure and use extends
27 only to the limited information or items that are entitled to confidential treatment
28 under the applicable legal principles. The parties further acknowledge, as set forth
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1 in Section 12.3, below, that this Stipulated Protective Order does not entitle them to
2 file confidential information under seal; Civil Local Rule 79-5 sets forth the
3 procedures that must be followed and the standards that will be applied when a party
4 seeks permission from the court to file material under seal.
5 1.2 GOOD CAUSE STATEMENT
6 Good cause exists in this case to enter a pretrial protective order. This case
7 involves factual allegations concerning a reorganization in the Company, including
8 the elimination of the Corporate Affairs Organization as well as Plaintiff alleging
9 detrimental reliance in resigning her prior employment with a Non-Party to this
10 matter. As a result, the Parties anticipate that discovery will involve confidential,
11 private, competitively sensitive and/or trade secret information relating to the
12 internal organization of the Company and Plaintiff’s prior employment, business
13 planning, and strategic considerations regarding the Company’s affairs.
14 Additionally, the Parties anticipate that discovery may implicate private and
15 personal employee information, such as personnel and/or employment files,
16 financial and compensation information, mitigation efforts, and the like, raising
17 additional concerns regarding constitutional privacy rights. Grobee v. Corr. Corp.
18 of Am., No. 13CV1060-GPC DHB, 2014 WL 229266, at *2 (S.D. Cal. Jan. 17,
19 2014)(“Because jurisdiction in this action is based upon diversity, state law governs
20 Defendant’s privacy claims. . . .Under California law, personnel records of
21 employees are protected by California’s constitutional right of privacy.”)(citing Cal.
22 Const., art. I, § 1); see also In re Insurance Installment Fee Cases, 211 Cal.App.4th
23 1395, 1428 (2012) (discussing privacy of financial information). Disclosure of such
24 information without proper confidentiality protections in place could injure the
25 rights and interests of the individuals and entities implicated.
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27 2. DEFINITIONS
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1 2.1 Action: this pending federal lawsuit.
2 2.2 Challenging Party: a Party or Non-Party that challenges the
3 designation of information or items under this Order.
4 2.3 “CONFIDENTIAL” Information or Items: information (regardless of
5 how it is generated, stored or maintained) or tangible things that qualify for
6 protection under Federal Rule of Civil Procedure 26(c), and information that (1)
7 constitutes a trade secret within the meaning of 18 U.S. Code § 1839 or California
8 Civil Code section 3426; (2) is confidential, business, proprietary, or compensation
9 information, contractual, or personnel information not generally available to the
10 public; (3) contains personal information of any prospective, current, or former
11 Company employee, including addresses, social security numbers, personnel
12 records, payroll, compensation, or other benefits information, health, and medical
13 and/or workers’ compensation information; and (4) Plaintiff’s mitigation efforts
14 including prospective employers.
15 2.4 Counsel: All Counsel including Outside Counsel of Record and House
16 Counsel (as well as their firm attorneys and staff).
17 2.5 Designating Party: a Party or Non-Party that designates information or
18 items that it produces in disclosures or in responses to discovery as
19 “CONFIDENTIAL.”
20 2.6 Disclosure or Discovery Material: all items or information, regardless
21 of the medium or manner in which it is generated, stored, or maintained (including,
22 among other things, testimony, transcripts, and tangible things), that are produced or
23 generated in disclosures or responses to discovery in this matter.
24 2.7 Expert: a person with specialized knowledge or experience in a matter
25 pertinent to the litigation who has been retained by a Party or its counsel to serve as
26 an expert witness or as a consultant in this Action.
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1 2.8 House Counsel: attorneys who are employees of a party to this Action.
2 House Counsel does not include Outside Counsel of Record or any other outside
3 counsel.
4 2.9 Non-Party: any natural person, partnership, corporation, association, or
5 other legal entity not named as a Party to this action.
6 2.10 Outside Counsel of Record: attorneys who are not employees of a
7 party to this Action but are retained to represent or advise a party to this Action and
8 have appeared in this Action on behalf of that party or are affiliated with a law firm
9 which has appeared on behalf of that party, and includes support staff.
10 2.11 Party: any party to this Action, including all of its officers, directors,
11 employees, consultants, retained experts, and Outside Counsel of Record (and their
12 support staffs).
13 2.12 Producing Party: a Party or Non-Party that produces Disclosure or
14 Discovery Material in this Action.
15 2.13 Professional Vendors: persons or entities that provide litigation
16 support services (e.g., photocopying, videotaping, translating, preparing exhibits or
17 demonstrations, and organizing, storing, or retrieving data in any form or medium)
18 and their employees and subcontractors.
19 2.14 Protected Material: any Disclosure or Discovery Material that is
20 designated as “CONFIDENTIAL.”
21 2.15 Receiving Party: a Party that receives Disclosure or Discovery
22 Material from a Producing Party.
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24 3. SCOPE
25 The protections conferred by this Stipulation and Order cover not only
26 Protected Material (as defined above), but also (1) any information copied or
27 extracted from Protected Material; (2) all copies, excerpts, summaries, or
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1 compilations of Protected Material; and (3) any testimony, conversations, or
2 presentations by Parties or their Counsel that might reveal Protected Material.
3 Any use of Protected Material at trial will be governed by the orders of the
4 trial judge. This Order does not govern the use of Protected Material at trial.
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6 4. DURATION
7 Even after final disposition of this litigation, the confidentiality obligations
8 imposed by this Order will remain in effect until a Designating Party agrees
9 otherwise in writing or a court order otherwise directs. Final disposition will be
10 deemed to be the later of (1) dismissal of all claims and defenses in this Action, with
11 or without prejudice; and (2) final judgment herein after the completion and
12 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action,
13 including the time limits for filing any motions or applications for extension of time
14 pursuant to applicable law.
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16 5. DESIGNATING PROTECTED MATERIAL
17 5.1 Exercise of Restraint and Care in Designating Material for Protection.
18 Each Party or Non-Party that designates information or items for protection under
19 this Order must take care to limit any such designation to specific material that
20 qualifies under the appropriate standards. The Designating Party must designate for
21 protection only those parts of material, documents, items, or oral or written
22 communications that qualify so that other portions of the material, documents,
23 items, or communications for which protection is not warranted are not swept
24 unjustifiably within the ambit of this Order.
25 Mass, indiscriminate, or routinized designations are prohibited. Designations
26 that are shown to be clearly unjustified or that have been made for an improper
27 purpose (e.g., to unnecessarily encumber the case development process or to impose
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1 unnecessary expenses and burdens on other parties) may expose the Designating
2 Party to sanctions.
3 If it comes to a Designating Party’s attention that information or items that it
4 designated for protection do not qualify for protection, that Designating Party must
5 promptly notify all other Parties that it is withdrawing the inapplicable designation.
6 5.2 Manner and Timing of Designations. Except as otherwise provided in
7 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
8 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
9 under this Order must be clearly so designated before the material is disclosed or
10 produced.
11 Designation in conformity with this Order requires:
12 (a) for information in documentary form (e.g., paper or electronic documents,
13 but excluding transcripts of depositions or other pretrial or trial proceedings), that
14 the Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter
15 “CONFIDENTIAL legend”), to each page that contains protected material. For
16 documents produced in native format where application of a legend to each “page”
17 is either impracticable or impossible, the Designating Party shall include the legend
18 in the file name or in a corresponding cover page.
19 A Party or Non-Party that makes original documents available for
20 inspection need not designate them for protection until after the inspecting Party has
21 indicated which documents it would like copied and produced. During the
22 inspection and before the designation, all of the material made available for
23 inspection will be deemed “CONFIDENTIAL.” After the inspecting Party has
24 identified the documents it wants copied and produced, the Producing Party must
25 determine which documents, or portions thereof, qualify for protection under this
26 Order. Then, before producing the specified documents, the Producing Party must
27 affix the “CONFIDENTIAL legend” to each page that contains Protected Material.
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1 For documents produced in native format where application of a legend to each
2 “page” is either impracticable or impossible, the Producing Party shall include the
3 legend in the file name or in a corresponding cover page.
4 (b) for testimony given in depositions that the Designating Party either: (i)
5 identify the Disclosure or Discovery Material on the record, before the close of the
6 deposition all protected testimony, or (ii) temporarily designate the entirety of the
7 testimony at the deposition as “Confidential” (before the deposition is concluded)
8 and within 30 days following receipt of the certified deposition transcript, identify
9 the specific portions of the testimony to which protection is sought. If no
10 designation is made at the deposition, deposition transcripts shall be treated by
11 default as Confidential for 10 business days following release of the certified
12 transcript to allow the Designating Party to communicate specific portions of the
13 deposition as to which protection is sought, if any. Thereafter, a Party shall have no
14 more than 20 business days in which to communicate those specific designations.
15 However, if a Party needs additional time, the Parties agree to meet and confer in
16 good faith regarding an extension of those deadlines.
17 (c) for information produced in some form other than documentary and for
18 any other tangible items, that the Producing Party affix in a prominent place on the
19 exterior of the container or containers in which the information is stored the legend
20 “CONFIDENTIAL.” If only a portion or portions of the information warrants
21 protection, the Producing Party, to the extent practicable, will identify the protected
22 portion(s).
23 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
24 failure to designate qualified information or items does not, standing alone, waive
25 the Designating Party’s right to secure protection under this Order for such material.
26 Upon timely correction of a designation, the Receiving Party must make reasonable
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1 efforts to assure that the material is treated in accordance with the provisions of this
2 Order.
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4 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
5 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
6 designation of confidentiality at any time that is consistent with the Court’s
7 Scheduling Order.
8 6.2 Meet and Confer. The Challenging Party will initiate the dispute
9 resolution process (and, if necessary, file a discovery motion) under Local Rule 37.1
10 et seq.
11 6.3 The burden of persuasion in any such challenge proceeding will be on
12 the Designating Party. Frivolous challenges, and those made for an improper
13 purpose (e.g., to harass or impose unnecessary expenses and burdens on other
14 parties) may expose the Challenging Party to sanctions. Unless the Designating
15 Party has waived or withdrawn the confidentiality designation, all parties will
16 continue to afford the material in question the level of protection to which it is
17 entitled under the Producing Party’s designation until the Court rules on the
18 challenge.
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20 7. ACCESS TO AND USE OF PROTECTED MATERIAL
21 7.1 Basic Principles. A Receiving Party may use Protected Material that is
22 disclosed or produced by another Party or by a Non-Party in connection with this
23 Action only for prosecuting, defending, or attempting to settle this Action. Such
24 Protected Material may be disclosed only to the categories of persons and under the
25 conditions described in this Order. When the Action has been terminated, a
26 Receiving Party must comply with the provisions of section 13 below (FINAL
27 DISPOSITION).
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1 Protected Material must be stored and maintained by a Receiving Party at a
2 location and in a secure manner that ensures that access is limited to the persons
3 authorized under this Order.
4 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
5 otherwise ordered by the court or permitted in writing by the Designating Party, a
6 Receiving Party may disclose any information or item designated
7 “CONFIDENTIAL” only to:
8 (a) the Receiving Party’s Outside Counsel of Record in this Action, as
9 well as employees of said Outside Counsel of Record to whom it is reasonably
10 necessary to disclose the information for this Action;
11 (b) the officers, directors, and employees (including House Counsel) of
12 the Receiving Party to whom disclosure is reasonably necessary for this Action;
13 (c) Experts (as defined in this Order) of the Receiving Party to whom
14 disclosure is reasonably necessary for this Action and who have signed the
15 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
16 (d) the Court and its personnel;
17 (e) professional vendors, court reporters and videographers in this Action
18 and their staff who have signed the “Acknowledgment and Agreement to Be Bound”
19 (Exhibit A);
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 the
26 Action to whom disclosure is reasonably necessary provided: (1) the deposing party
27 requests that the witness sign the form attached as Exhibit A hereto; and (2) they
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1 will not be permitted to keep any confidential information unless they sign the
2 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
3 agreed by the Designating Party or ordered by the court. Pages of transcribed
4 deposition testimony or exhibits to depositions that reveal Protected Material may
5 be separately bound by the court reporter and may not be disclosed to anyone except
6 as permitted under this Stipulated Protective Order; and
7 (i) any mediator or settlement officer, and their supporting personnel,
8 mutually agreed upon by any of the parties engaged in settlement discussions.
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10 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
11 IN OTHER LITIGATION
12 If a Party is served with a subpoena or a court order issued in other litigation
13 that compels disclosure of any information or items designated in this Action as
14 “CONFIDENTIAL,” that Party must:
15 (a) promptly notify in writing the Designating Party. Such notification
16 will include a copy of the subpoena or court order;
17 (b) promptly notify in writing the party who caused the subpoena or order
18 to issue in the other litigation that some or all of the material covered by the
19 subpoena or order is subject to this Protective Order. Such notification will include
20 a copy of this Stipulated Protective Order; and
21 (c) cooperate with respect to all reasonable procedures sought to be
22 pursued by the Designating Party whose Protected Material may be affected.
23 If the Designating Party timely seeks a protective order, the Party served with
24 the subpoena or court order will not produce any information designated in this
25 action as “CONFIDENTIAL” before a determination by the court from which the
26 subpoena or order issued, unless the Party has obtained the Designating Party’s
27 permission. The Designating Party will bear the burden and expense of seeking
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1 protection in that court of its confidential material and nothing in these provisions
2 should be construed as authorizing or encouraging a Receiving Party in this Action
3 to disobey a lawful directive from another court.
4
5 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
6 PRODUCED IN THIS LITIGATION
7 (a) The terms of this Order are applicable to information produced by a
8 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
9 produced by Non-Parties in connection with this litigation is protected by the
10 remedies and relief provided by this Order. Nothing in these provisions should be
11 construed as prohibiting a Non-Party from seeking additional protections.
12 (b) In the event that a Party is required, by a valid discovery request, to
13 produce a Non-Party’s confidential information in its possession, and the Party is
14 subject to an agreement with the Non-Party not to produce the Non-Party’s
15 confidential information, then the Party will:
16 (1) promptly notify in writing the Requesting Party and the Non-Party
17 that some or all of the information requested is subject to a confidentiality
18 agreement with a Non-Party;
19 (2) promptly provide the Non-Party with a copy of the Stipulated
20 Protective Order in this Action, the relevant discovery request(s), and a reasonably
21 specific description of the information requested; and
22 (3) make the information requested available for inspection by the
23 Non-Party, if requested.
24 (c) If the Non-Party fails to seek a protective order from this court within
25 14 days of receiving the notice and accompanying information, the Receiving Party
26 may produce the Non-Party’s confidential information responsive to the discovery
27 request. If the Non-Party timely seeks a protective order, the Receiving Party will
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1 not produce any information in its possession or control that is subject to the
2 confidentiality agreement with the Non-Party before a determination by the court.
3 Absent a court order to the contrary, the Non-Party will bear the burden and expense
4 of seeking protection in this court of its Protected Material.
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6 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
7 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
8 Protected Material to any person or in any circumstance not authorized under this
9 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
10 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
11 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
12 persons to whom unauthorized disclosures were made of all the terms of this Order,
13 and (d) request such person or persons to execute the “Acknowledgment and
14 Agreement to Be Bound” that is attached hereto as Exhibit A.
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16 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
17 PROTECTED MATERIAL
18 When a Producing Party gives notice to Receiving Parties that certain
19 inadvertently produced material is subject to a claim of privilege or other protection,
20 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
21 Procedure 26(b)(5)(B). This provision is not intended to modify whatever
22 procedure may be established in an e-discovery order that provides for production
23 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and
24 (e), insofar as the parties reach an agreement on the effect of disclosure of a
25 communication or information covered by the attorney-client privilege or work
26 product protection, the parties may incorporate their agreement in the stipulated
27 protective order submitted to the court.
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1 12. MISCELLANEOUS
2 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
3 person to seek its modification by the Court in the future.
4 12.2 Right to Assert Other Objections. By stipulating to the entry of this
5 Protective Order no Party waives any right it otherwise would have to object to
6 disclosing or producing any information or item on any ground not addressed in this
7 Stipulated Protective Order. Similarly, no Party waives any right to object on any
8 ground to use in evidence of any of the material covered by this Protective Order.
9 12.3 Filing Protected Material. A Party that seeks to file under seal any
10 Protected Material must comply with Civil Local Rule 79-5. Protected Material may
11 only be filed under seal pursuant to a court order authorizing the sealing of the
12 specific Protected Material at issue. If a Party's request to file Protected Material
13 under seal is denied by the court, then the Receiving Party may file the information
14 in the public record unless otherwise instructed by the court. Before quoting from
15 or presenting any Confidential Materials in open court, a Party shall state its
16 intention to do so on the record to allow the Designating Party an opportunity to
17 object.
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19 13. FINAL DISPOSITION
20 After the final disposition of this Action, as defined in paragraph 4, within 60
21 days of a written request by the Designating Party, each Receiving Party must return
22 all Protected Material to the Producing Party or destroy such material. As used in
23 this subdivision, “all Protected Material” includes all copies, abstracts, compilations,
24 summaries, and any other format reproducing or capturing any of the Protected
25 Material. Whether the Protected Material is returned or destroyed, the Receiving
26 Party must submit a written certification to the Producing Party (and, if not the same
27 person or entity, to the Designating Party) by the 60 day deadline that affirms that
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1 || the Receiving Party has not retained any copies, abstracts, compilations, summaries
2 || or any other format reproducing or capturing any of the Protected Material.
3 || Notwithstanding this provision, Counsel are entitled to retain an archival copy of all
4 || pleadings, motion papers, trial, deposition, and hearing transcripts, legal
5 || memoranda, correspondence, deposition and trial exhibits, expert reports, attorney
6 || work product, and consultant and expert work product, even if such materials
7 || contain Protected Material. Any such archival copies that contain or constitute
8 || Protected Material remain subject to this Protective Order as set forth in Section 4
9 || (DURATION).
10 || 14.) Any willful violation of this Order may be punished by civil or criminal
11 || contempt proceedings, financial or evidentiary sanctions, reference to disciplinary
12 || authorities, or other appropriate action at the discretion of the Court.
13
14 || FOR GOOD CAUSE SHOWN BY THE PARTIES’ STIPULATION, IT IS SO
15 || ORDERED.
16
17 fuk f Af
18 |} DATED: March 17, 2023
19 United States Magistrate Iudge
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1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3
4 I, _____________________________ [full name], of _________________
5 [full address], declare under penalty of perjury that I have read in its entirety and
6 understand the Stipulated Protective Order that was issued by the United States
7 District Court for the Central District of California on [date] in the case of
8 ___________ [insert case name and number]. I agree to comply with and to be
9 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 Court
15 for the Central District of California for the purpose of enforcing the terms of this
16 Stipulated Protective Order, even if such enforcement proceedings occur after
17 termination of this action. I hereby appoint __________________________ [full
18 name] of _______________________________________ [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 signed: _________________________________
24
25 Printed name: _______________________________
26
27 Signature: __________________________________
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