818 Aviation, Inc. v. Aerospace Turbine Rotables, Inc.

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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818 AVIATION, INC., Case No. 2:21-CV-08894-MEMF-

11 (RAO)

12 Plaintiff, [Consol. with Case No.: 2:22-CV-

13 06929-MEMF-(RAO)]

v.

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STIPULATED PROTECTIVE

15 AEROSPACE TURBINE ORDER1

ROTABLES, INC.,

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Defendant.

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And related counteraction and

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consolidated case.

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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

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

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

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

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

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

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

10 under the applicable legal principles.

11 B. GOOD CAUSE STATEMENT

12 This action is likely to involve trade secrets, customer and pricing lists and

13 other valuable research, development, commercial, financial, technical and/or

14 proprietary information for which special protection from public disclosure and

15 from use for any purpose other than prosecution of this action is warranted. Such

16 confidential and proprietary materials and information consist of, among other

17 things, confidential business or financial information, information regarding

18 confidential business practices, or other confidential research, development, or

19 commercial information (including information implicating privacy rights of third

20 parties), information otherwise generally unavailable to the public, or which may be

21 privileged or otherwise protected from disclosure under state or federal statutes,

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

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

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

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

26 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

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

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

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

4 record of this case.

5 Certain documents constitute AeTR’s work product will be produced in this

6 litigation, including: (a) traceability documents for any components returned or

7 exchanged by third parties, (b) inspection results, including dimensional

8 measurements and non-destructive testing results, (c) documents which detail

9 AeTR’s repair and refurbishment efforts that would enable 818 to have its inventory

10 certified as airworthy and saleable, (d) competition-sensitive documents relating to

11 AeTR’s suppliers, including contract information and vendor pricing and

12 (e) competition-sensitive documents relating to AeTR’s customers, including

13 contract information and AeTR’s pricing.

14 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL

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

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

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

18 and the standards that will be applied when a party seeks permission from the court

19 to file material under seal.

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

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

22 good cause must be shown to support a filing under seal. See Kamakana v. City and

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

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

25 Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders

26 require good cause showing), and a specific showing of good cause or compelling

27 reasons with proper evidentiary support and legal justification, must be made with

1 designation of Disclosure or Discovery Material as CONFIDENTIAL does not—

2 without the submission of competent evidence by declaration, establishing that the

3 material sought to be filed under seal qualifies as confidential, privileged, or

4 otherwise protectable—constitute good cause.

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

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

7 relief sought shall be narrowly tailored to serve the specific interest to be protected.

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

9 each item or type of information, document, or thing sought to be filed or introduced

10 under seal in connection with a dispositive motion or trial, the party seeking

11 protection must articulate compelling reasons, supported by specific facts and legal

12 justification, for the requested sealing order. Again, competent evidence supporting

13 the application to file documents under seal must be provided by declaration.

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

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

16 If documents can be redacted, then a redacted version for public viewing, omitting

17 only the confidential, privileged, or otherwise protectable portions of the document

18 shall be filed. Any application that seeks to file documents under seal in their

19 entirety should include an explanation of why redaction is not feasible.

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21 2. DEFINITIONS

22 2.1 Action: this pending federal lawsuit and the consolidated action listed

23 in the caption.

24 2.2 Challenging Party: a Party or Non-Party that challenges the

25 designation of information or items under this Order.

26 2.3 “CONFIDENTIAL” Information or Items: information (regardless of

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

1 the Good Cause Statement.

2 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as

3 their support staff).

4 2.5 Designating Party: a Party or Non-Party that designates information or

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

6 “CONFIDENTIAL.”

7 2.6 Disclosure or Discovery Material: all items or information, regardless

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

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

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

11 2.7 Expert: a person with specialized knowledge or experience in a matter

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

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

14 2.8 House Counsel: attorneys who are employees of a party to this Action.

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

16 counsel.

17 2.9 Non-Party: any natural person, partnership, corporation, association or

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

19 2.10 Outside Counsel of Record: attorneys who are not employees of a

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

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

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

23 2.11 Party: any party to this Action, including all of its officers, directors,

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

25 support staffs).

26 2.12 Producing Party: a Party or Non-Party that produces Disclosure or

27 Discovery Material in this Action.

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

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

3 and their employees and subcontractors.

4 2.14 Protected Material: any Disclosure or Discovery Material that is

5 designated as “CONFIDENTIAL.”

6 2.15 Receiving Party: a Party that receives Disclosure or Discovery

7 Material from a Producing Party.

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9 3. SCOPE

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

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

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

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

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

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

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

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18 4. DURATION

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

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

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

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

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

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

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

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

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

1 5. DESIGNATING PROTECTED MATERIAL

2 5.1 Exercise of Restraint and Care in Designating Material for Protection.

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

4 this Order must take care to limit any such designation to specific material that

5 qualifies under the appropriate standards. The Designating Party must designate for

6 protection only those parts of material, documents, items or oral or written

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

8 or communications for which protection is not warranted are not swept unjustifiably

9 within the ambit of this Order.

10 Mass, indiscriminate or routinized designations are prohibited. Designations

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

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

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

14 Party to sanctions.

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

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

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

18 5.2 Manner and Timing of Designations. Except as otherwise provided in

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

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

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

22 produced.

23 Designation in conformity with this Order requires:

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

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

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

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

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

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

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

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

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

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

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

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

9 documents, or portions thereof, qualify for protection under this Order. Then,

10 before producing the specified documents, the Producing Party must affix the

11 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a

12 portion of the material on a page qualifies for protection, the Producing Party also

13 must clearly identify the protected portion(s) (e.g., by making appropriate markings

14 in the margins).

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

16 the Disclosure or Discovery Material on the record, before the close of the

17 deposition all protected testimony.

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

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

20 the exterior of the container or containers in which the information is stored the

21 legend “CONFIDENTIAL.” If only a portion or portions of the information

22 warrants protection, the Producing Party, to the extent practicable, shall identify the

23 protected portion(s).

24 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent

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

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

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

1 Order.

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3 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

4 6.1 Timing of Challenges. Any Party or Non-Party may challenge a

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

6 Scheduling Order.

7 6.2 Meet and Confer. The Challenging Party shall initiate the dispute

8 resolution process under Local Rule 37.1 et seq.

9 6.3 The burden of persuasion in any such challenge proceeding shall be on

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

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

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

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

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

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

16 challenge.

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18 7. ACCESS TO AND USE OF PROTECTED MATERIAL

19 7.1 Basic Principles. A Receiving Party may use Protected Material that is

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

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

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

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

24 Receiving Party must comply with the provisions of section 13 below (FINAL

25 DISPOSITION).

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

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

1 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless

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

3 Receiving Party may disclose any information or item designated

4 “CONFIDENTIAL” only to:

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

6 well as employees of said Outside Counsel of Record to whom it is reasonably

7 necessary to disclose the information for this Action;

8 (b) the officers, directors, and employees (including House Counsel) of

9 the Receiving Party to whom disclosure is reasonably necessary for this Action;

10 (c) Experts (as defined in this Order) of the Receiving Party to whom

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

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

13 (d) the court and its personnel;

14 (e) court reporters and their staff;

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

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

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

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

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

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

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

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

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

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

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

26 deposition testimony or exhibits to depositions that reveal Protected Material may

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

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

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

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4 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED

5 IN OTHER LITIGATION

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

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

8 “CONFIDENTIAL,” that Party must:

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

10 shall include a copy of the subpoena or court order;

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

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

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

14 a copy of this Stipulated Protective Order; and

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

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

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

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

19 action as “CONFIDENTIAL” before a determination by the court from which the

20 subpoena or order issued, unless the Party has obtained the Designating Party’s

21 permission. The Designating Party shall bear the burden and expense of seeking

22 protection in that court of its confidential material and nothing in these provisions

23 should be construed as authorizing or encouraging a Receiving Party in this Action

24 to disobey a lawful directive from another court.

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

27 PRODUCED IN THIS LITIGATION

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

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

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

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

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

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

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

8 confidential information, then the Party shall:

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

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

11 agreement with a Non-Party;

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

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

14 specific description of the information requested; and

15 (3) make the information requested available for inspection by the

16 Non-Party, if requested.

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

18 14 days of receiving the notice and accompanying information, the Receiving Party

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

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

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

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

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

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

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26 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

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

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

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

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

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

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

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8 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

9 PROTECTED MATERIAL

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

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

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

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

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

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

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

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

18 product protection, the parties may incorporate their agreement in the stipulated

19 protective order submitted to the court.

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21 12. MISCELLANEOUS

22 12.1 Right to Further Relief. Nothing in this Order abridges the right of any

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

24 12.2 Right to Assert Other Objections. By stipulating to the entry of this

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

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

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

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

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

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

5 under seal is denied by the court, then the Receiving Party may file the information

6 in the public record unless otherwise instructed by the court.

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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

12 this 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).

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1 Any violation of this Order may be punished by appropriate measures

2 including, without limitation, contempt proceedings and/or monetary sanctions.

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4 15. Special Protection for Documents Which AeTR Maintains Have Independent

5 Commercial Value (AeTR’s Work Product)

6 The documents which constitute AeTR’s work product are: (a) traceability

7 documents for any components returned or exchanged by third parties, (b)

8 inspection results, including dimensional measurements and non-destructive testing

9 results, (c) documents which detail AeTR’s repair and refurbishment efforts that

10 would enable 818 to have its inventory certified as airworthy and saleable, (d)

11 competition-sensitive documents relating to AeTR’s suppliers, including contract

12 information and vendor pricing and (e) competition-sensitive documents relating to

13 AeTR’s customers, including contract information and AeTR’s pricing. These are

14 documents which AeTR maintains have independent commercial value which 818

15 has not paid for. They shall be labeled CONFIDENTIAL, SUBJECT TO

16 PROTECTIVE ORDER, NOT TO BE USED FOR CERTIFICATION/RETURN

17 TO SERVICE PURPOSES.

18 Absent further order of the Court, AeTR may produce its work product

19 electronically and take measures necessary to prohibit the dissemination of those

20 documents to persons other than 818’s counsel, Talkov Law Corp., and Scott

21 Charles, 818’s president. Receipt of AeTR’s work product by those persons will

22 allow 818 to evaluate AeTR’s claim for recovery of money in these cases.

23 //

24 //

25 //

26 //

27 //

1 Absent further order of the Court, 818 and its counsel may not duplicate

2 || AeTR’s work product or show it to any other person. 818 may not use the

3 || information in AeTR’s work product in an attempt to obtain FAA approval for

4 || return to service of the parts it owns and which are currently in AeTR’s possession.

5

6

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

8

9 || DATED —__ 3/29/23

10

11 /s/

Attorneys for Plaintiff, Katja M. Grosch, Esq.

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14 || DATED: 3/29/23

15

16 /s/

Attorneys for Defendant, Scott Gunderson, Esq.

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

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21 || DATED: May 9, 2023

22 .

03 _ Rapin a. QO2—

24 || United States Magistrate Judge

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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 ___________ [insert formal name of the case and the

9 number and initials assigned to it by the court]. I agree to comply with and to be

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

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

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

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

14 person 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: _________________________________

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26 Printed name: _______________________________

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