Classic Distributing and Beverage Group Inc v. Travelers Casualty and Surety Company of America

Filing 20

PROTECTIVE ORDER by Magistrate Judge Ralph Zarefsky, re: Stipulation for Protective Order, 19 . (mz)

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DAVID P. BENDER, JR., Bar No. 123976
[e-mail]
DAVID A. SHANEYFELT, Bar No. 240777
[e-mail]
CAROLINE HURTADO, Bar No. 230526
[e-mail]
JOSEPH G. BALICE, Bar No. 245509
[e-mail]
ANDERSON KILL WOOD & BENDER LLP
864 E. Santa Clara St.
Ventura, CA 93001
Tel: [phone]
Fax: [phone]

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Attorneys for Plaintiff Classic Distributing and Beverage Group, Inc.

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864 E. SANTACLARA STREET ■ VENTURA, CA 93001 ■ TELEPHONE: [phone] ■ FAX: [phone] ■ WWW.ANDERSONKILL. COM

ANDERSON KILL WOOD & BENDER P.C.

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SEDGWICK LLP
BRIAN D. HARRISON Bar No. 157123
[e-mail]
ERIN A. CORNELL Bar No. 227135
[e-mail]
333 Bush Street, 30th Floor
San Francisco, CA 94104-2834
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendant Travelers Casualty And Surety Company Of America

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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CLASSIC DISTRIBUTING AND
BEVERAGE GROUP, INC., a
California corporation,

) CASE NO.: CV 11-07075 GAF (RZx)
) (Assigned to Hon. Gary A. Fees and
) Hon. Ralph Zarefsky, Magistrate)
)
Plaintiff,
)
) [PROPOSED] ORDER ON
vs.
) STIPULATION FOR PROTECTIVE
) ORDER REGARDING
TRAVELERS CASUALTY AND
) CONFIDENTIALITY
SURETY COMPANY OF AMERICA, )
a Connecticut corporation,
)
)
Defendant.
)
)

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[PROPOSED] ORDER ON STIPULATION FOR PROTECTIVE ORDER

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Plaintiff Classic Distributing and Beverage Group, Inc. (“Classic”) and

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Defendant Travelers Casualty and Surety Company of America (“Travelers”),

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through their counsel of record, hereby stipulate to the following Protective Order

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governing the disclosure of certain private and/or proprietary documents or

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864 E. SANTACLARA STREET ■ VENTURA, CA 93001 ■ TELEPHONE: [phone] ■ FAX: [phone] ■ WWW.ANDERSONKILL. COM

IT IS HEREBY ORDERED:

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ANDERSON KILL WOOD & BENDER P.C.

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information that may be produced by the Parties or third parties during this

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litigation:

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1.0

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This is an insurance coverage action concerning, among other things, defense

GOOD CAUSE STATEMENT

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expenses incurred in defense of the Underlying Action. Classic must prove those

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expenses by production of defense counsel billing records. These records include

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the monthly billing statements of defense counsel which include details concerning

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defense and strategy regarding the Underlying Action. These records must be kept

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confidential, because they would reveal Classic’s defense and strategy in other

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employment-related class actions. Accordingly, Under Rule 26(c)(1)(G), a

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protective order (“Order”) is necessary to avoid any prejudice or harm in the form of

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loss of attorney client work product or attorney client privilege which could result if

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such information is disclosed in the absence of the protections set forth herein.

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The Parties acknowledge that this Order does not confer blanket protections

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on all disclosures or responses to discovery and that the protection it affords extends

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only to the limited information or items that are entitled under the applicable legal

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principles to treatment as confidential. The Parties further acknowledge, as set forth

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in Section 11, below, that this Stipulated Protective Order creates no entitlement to

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file confidential information under seal; Civil Local Rule 79-5.1 sets forth the

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procedures that must be followed and reflects the standards that will be applied

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when a Party seeks permission from the court to file material under seal.

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Furthermore, the Parties acknowledge that this Order is not intended to circumscribe

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the confidential or proprietary topics the parties may request or exchange.
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[PROPOSED] ORDER ON STIPULATION FOR PROTECTIVE ORDER

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2.0

DEFINITIONS

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2.1

Party: any party to this action, including all of its officers, directors,

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employees, consultants, retained experts, and outside counsel (and their support

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staff).

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2.2

Disclosure or Discovery Material: all items or information, regardless

864 E. SANTACLARA STREET ■ VENTURA, CA 93001 ■ TELEPHONE: [phone] ■ FAX: [phone] ■ WWW.ANDERSONKILL. COM

ANDERSON KILL WOOD & BENDER P.C.

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of the medium or manner generated, stored, or maintained (including, among other

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things, testimony, transcripts, or tangible things) that are produced or generated in

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disclosures or responses to discovery in this matter.

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2.3

“Confidential” Information or Items: information (regardless of how

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generated, stored or maintained) or tangible things that qualify for protection under

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standards developed under Fed. R. Civ. P. 26(c) and include all monthly billing

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statements and/or invoices sent by Steven W. Brennan and/or the law firm of St.

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John Wallace Brennan & Folan LLP, to Classic for services rendered in relation to

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the Underlying Action.

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2.4

Receiving Party: a Party that receives Disclosure or Discovery Material

from a Producing Party.
2.5

Producing Party: a Party or non-party that produces Disclosure or

Discovery Material in this action.
2.6

Designating Party: a Party or non-party that designates information or

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items that it produces in disclosures or in responses to discovery as “Confidential” or

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“Highly Confidential - Attorneys’ Eyes Only.”

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2.7

Protected Material: any Disclosure or Discovery Material that is

designated as “Confidential.”
2.8

Outside Counsel: attorneys who are not employees of a Party but who

are retained to represent or advise a Party in this action.

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2.9

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2.10 Counsel (without qualifier): Outside Counsel and House Counsel (as

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House Counsel: attorneys who are employees of a Party.

well as their support staffs).
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[PROPOSED] ORDER ON STIPULATION FOR PROTECTIVE ORDER

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

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an expert witness or as a consultant in this action and who is not a past or a current

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employee of a Party or of a competitor of a Party’s and who, at the time of retention,

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is not anticipated to become an employee of a Party or a competitor of a Party’s.

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864 E. SANTACLARA STREET ■ VENTURA, CA 93001 ■ TELEPHONE: [phone] ■ FAX: [phone] ■ WWW.ANDERSONKILL. COM

2.11 Expert: a person with specialized knowledge or experience in a matter

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ANDERSON KILL WOOD & BENDER P.C.

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This definition includes a professional jury or trial consultant retained in connection

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with this litigation.

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2.12 Professional Vendors: persons or entities that provide litigation support
services (e.g., photocopying; videotaping; translating; preparing exhibits or

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demonstrations; organizing, storing, retrieving data in any form or medium; etc.) and

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their employees and subcontractors.

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2.13 Confidentiality Agreement: the agreement attached as Exhibit A hereto.

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2.14 Underlying Action: All proceedings under the case captioned,

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Amezquita v. Classic Distributing and Beverage Group, Inc., No. BC412216, Los

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Angeles County Superior Court.

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3.0

SCOPE

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3.1

The protections conferred by this Stipulation and Order cover not only

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

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therefrom, as well as all copies, excerpts, summaries, or compilations thereof, plus

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testimony, conversations, or presentations by parties or counsel to or in court or in

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other settings that might reveal Protected Material.

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3.2

This order shall not govern in connection with dispositive motions or at

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trial. If protection is desired in connection with those proceedings, it must be sought

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separately, from the judicial officer who will preside at those proceedings. See Foltz

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v. State Farm Mutual Auto Ins. Co., 331 F.3d 1122, 1136 (9th Cir. 2003); Kamakana

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v. City and County of Honolulu, 447 F.3d 1172 (9th Cir. 2006).

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[PROPOSED] ORDER ON STIPULATION FOR PROTECTIVE ORDER

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4.0

DURATION

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Even after the termination of this litigation, the confidentiality obligations

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imposed by this Order shall remain in effect until a Designating Party agrees

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otherwise in writing or a court order otherwise directs.

864 E. SANTACLARA STREET ■ VENTURA, CA 93001 ■ TELEPHONE: [phone] ■ FAX: [phone] ■ WWW.ANDERSONKILL. COM

5.0

DESIGNATING PROTECTED MATERIAL

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ANDERSON KILL WOOD & BENDER P.C.

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5.1

Exercise of Restraint and Care in Designating Material for Protection.

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Each Party or non-party that designates information or items for protection under

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

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qualifies under the appropriate standards. A Designating Party must take care to

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

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

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

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swept unjustifiably within the ambit of this Order.

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Mass, indiscriminate, or routinized designations are prohibited. Designations

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

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

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

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Designating Party to sanctions.

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If it comes to a Party’s or a non-party’s attention that information or items that

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it designated for protection do not qualify for protection at all, or do not qualify for

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the level of protection initially asserted, that Party or non-party must promptly notify

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all other parties that it is withdrawing the mistaken designation.

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5.2

Manner and Timing of Designations. Except as otherwise provided in

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

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stipulated or ordered, material that qualifies for protection under this Order must be

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clearly so designated before the material is disclosed or produced.

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[PROPOSED] ORDER ON STIPULATION FOR PROTECTIVE ORDER

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Designation in conformity with this Order requires:

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(a)

for information in documentary form (apart from transcripts of

legend “CONFIDENTIAL” at the top or bottom of each page that contains protected

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

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864 E. SANTACLARA STREET ■ VENTURA, CA 93001 ■ TELEPHONE: [phone] ■ FAX: [phone] ■ WWW.ANDERSONKILL. COM

depositions or other pretrial or trial proceedings), that the Producing Party affix the

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ANDERSON KILL WOOD & BENDER P.C.

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

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

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A Party or non-party that makes original documents or materials available for

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

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indicated which material it would like copied and produced.
During the inspection and before the designation, all of the material made

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available for inspection shall be deemed “CONFIDENTIAL.” After the inspecting

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Party has identified the documents it wants copied and produced, the Producing

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Party must determine which documents, or portions thereof, qualify for protection

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under this Order, then, before producing the specified documents, the Producing

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Party must affix the appropriate legend (“CONFIDENTIAL”) at the top of each page

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that contains Protected Material. If only a portion or portions of the material on a

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

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

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(b)

for testimony given in deposition or in other pretrial or trial

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proceedings, that the Party or non-party offering or sponsoring the testimony

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identify on the record, before the close of the deposition, hearing, or other

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proceeding, all protected testimony, and further specify any portions of the

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testimony that qualify as “CONFIDENTIAL.” When it is impractical to identify

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separately each portion of testimony that is entitled to protection, and when it

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appears that substantial portions of the testimony may qualify for protection, the

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Party or non-party that sponsors, offers, or gives the testimony may invoke on the

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record (before the deposition or proceeding is concluded) a right to have up to 20
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[PROPOSED] ORDER ON STIPULATION FOR PROTECTIVE ORDER

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days to identify the specific portions of the testimony as to which protection is

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sought. Only those portions of the testimony that are appropriately designated for

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protection within the 20 days shall be covered by the provisions of this Stipulated

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Protective Order.

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Transcript pages containing Protected Material must be separately bound by

864 E. SANTACLARA STREET ■ VENTURA, CA 93001 ■ TELEPHONE: [phone] ■ FAX: [phone] ■ WWW.ANDERSONKILL. COM

ANDERSON KILL WOOD & BENDER P.C.

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the court reporter, who must affix to the top of each such page the legend

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“CONFIDENTIAL” or “HIGHLY CONFIDENTIAL - ATTORNEYS’ EYES

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ONLY,” as instructed by the Party or nonparty offering or sponsoring the witness or

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presenting the testimony.

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(c)

for information produced in some form other than documentary, and for

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

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

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legend “CONFIDENTIAL.” If only portions of the information or item warrant

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

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portions as “CONFIDENTIAL.”

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5.3

Inadvertent Failures to Designate. If timely corrected, an inadvertent

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failure to designate qualified information or items as “CONFIDENTIAL” does not,

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standing alone, waive the Designating Party’s right to secure protection under this

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Order for such material. If material is appropriately designated as

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“CONFIDENTIAL” after the material was initially produced, the Receiving Party,

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on timely notification of the designation, must make reasonable efforts to assure that

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

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6.0

CHALLENGING CONFIDENTIALITY DESIGNATIONS

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6.1

Timing of Challenges. Unless a prompt challenge to a Designating

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Party’s confidentiality designation is necessary to avoid foreseeable substantial

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unfairness, unnecessary economic burdens, or a later significant disruption or delay

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of the litigation, a Party does not waive its right to challenge a confidentiality

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[PROPOSED] ORDER ON STIPULATION FOR PROTECTIVE ORDER

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designation by electing not to mount a challenge promptly after the original

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designation is disclosed.
6.2

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Meet and Confer. A Party that elects to initiate a challenge to a

comply with Civil Local Rule 37-1. In conferring, the challenging Party must

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864 E. SANTACLARA STREET ■ VENTURA, CA 93001 ■ TELEPHONE: [phone] ■ FAX: [phone] ■ WWW.ANDERSONKILL. COM

Designating Party’s confidentiality designation must do so in good faith and must

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ANDERSON KILL WOOD & BENDER P.C.

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explain the basis for its belief that the confidentiality designation was not proper and

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must give the Designating Party an opportunity to review the designated material, to

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reconsider the circumstances, and, if no change in designation is offered, to explain

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the basis for the chosen designation. A challenging Party may proceed to the next

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stage of the challenge process only if it has engaged in this meet and confer process

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first.

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6.3

Judicial Intervention. If counsel are unable to settle their differences

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over a confidentiality designation after considering the justification offered by the

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Designating Party, the parties shall formulate a written stipulation under Civil Local

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Rule 37-2 (and in compliance with Civil Local Rules 37-2.1 through 37-4). Each

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such motion must be accompanied by a competent declaration that affirms that the

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movant has complied with the meet and confer requirements imposed in the

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preceding paragraph and that sets forth with specificity the justification for the

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confidentiality designation that was given by the Designating Party in the meet and

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confer dialogue.

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

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Designating Party. Until the court rules on the challenge, all parties shall continue

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

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the Producing Party’s designation.

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7.0

ACCESS TO AND USE OF PROTECTED MATERIAL

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7.1

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

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disclosed or produced by another Party or by a non-party in connection with this

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case only for prosecuting, defending, or attempting to settle this litigation. Such
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[PROPOSED] ORDER ON STIPULATION FOR PROTECTIVE ORDER

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

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

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Receiving Party must comply with the provisions of section 12, below (FINAL

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DISPOSITION).

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

864 E. SANTACLARA STREET ■ VENTURA, CA 93001 ■ TELEPHONE: [phone] ■ FAX: [phone] ■ WWW.ANDERSONKILL. COM

ANDERSON KILL WOOD & BENDER P.C.

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

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authorized under this Order.

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7.2

Disclosure of “CONFIDENTIAL” Information or Items. Unless

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

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Receiving Party may disclose any information or item designated CONFIDENTIAL

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only to:

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(a)

the Receiving Party’s Outside Counsel of record in this action, as well

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as employees of said Counsel to whom it is reasonably necessary to disclose the

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information for this litigation;

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(b)

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

Receiving Party to whom disclosure is reasonably necessary for this;
(c)

experts (as defined in this Order) of the Receiving Party to whom

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disclosure is reasonably necessary for this litigation and who have signed the

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Confidentiality Agreement;

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(d)

the Court and its personnel;

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(e)

court reporters, their staffs, and professional vendors to whom

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disclosure is reasonably necessary for this litigation and who have signed the

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Confidentiality Agreement;

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(f)

during their depositions, witnesses in the action to whom disclosure is

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reasonably necessary and who have signed the Confidentiality Agreement. Pages of

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transcribed deposition testimony or exhibits to depositions that reveal Protected

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Material must be separately bound by the court reporter and may not be disclosed to

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anyone except as permitted under this Stipulated Protective Order;
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[PROPOSED] ORDER ON STIPULATION FOR PROTECTIVE ORDER

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(g)

the author of the document or the original source of the information.

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8.0

PROTECTED MATERIAL SUBPOENAED OR ORDERED

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PRODUCED IN OTHER LITIGATION.
If a Receiving Party is served with a subpoena or an order issued in other

864 E. SANTACLARA STREET ■ VENTURA, CA 93001 ■ TELEPHONE: [phone] ■ FAX: [phone] ■ WWW.ANDERSONKILL. COM

litigation that would compel disclosure of any information or items designated in

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ANDERSON KILL WOOD & BENDER P.C.

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this action as “CONFIDENTIAL,” the Receiving Party must so notify the

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Designating Party, in writing (by fax, if possible) immediately and in no event more

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than three court days after receiving the subpoena or order. Such notification must

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include a copy of the subpoena or court order.

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The Receiving Party also must immediately inform in writing the Party who

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caused the subpoena or order to issue in the other litigation that some or all the

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material covered by the subpoena or order is the subject of this Protective Order. In

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addition, the Receiving Party must deliver a copy of this Stipulated Protective Order

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promptly to the Party in the other action that caused the subpoena or order to issue.

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The purpose of imposing these duties is to alert the interested parties to the

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existence of this Protective Order and to afford the Designating Party in this case an

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opportunity to try to protect its confidentiality interests in the court from which the

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subpoena or order issued. The Designating Party shall bear the burdens and the

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expenses of seeking protection in that court of its confidential material - and nothing

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

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

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9.0

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

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

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

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

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

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[PROPOSED] ORDER ON STIPULATION FOR PROTECTIVE ORDER

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whom unauthorized disclosures were made of all the terms of this Order, and (d)

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request such person or persons to execute the Confidentiality Agreement.

Without written permission from the Designating Party or a court order

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secured after appropriate notice to all interested persons, a Party may not file in the

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864 E. SANTACLARA STREET ■ VENTURA, CA 93001 ■ TELEPHONE: [phone] ■ FAX: [phone] ■ WWW.ANDERSONKILL. COM

10.0 FILING PROTECTED MATERIAL.

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ANDERSON KILL WOOD & BENDER P.C.

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public record in this action any Protected Material. A Party that seeks to file under

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seal any Protected Material must comply with Civil Local Rule 79-5.1.

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11.0 FINAL DISPOSITION.

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Unless otherwise ordered or agreed in writing by the Producing Party, within

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sixty days after the final termination of this action, each Receiving Party must return

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all Protected Material to the Producing Party. As used in this subdivision, “all

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Protected Material” includes all copies, abstracts, compilations, summaries or any

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other form of reproducing or capturing any of the Protected Material. With

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permission in writing from the Designating Party, the Receiving Party may destroy

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some or all of the Protected Material instead of returning it. Whether the Protected

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Material is returned or destroyed, the Receiving Party must submit a written

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certification to the Producing Party (and, if not the same person or entity, to the

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Designating Party) by the sixty day deadline that identifies (by category, where

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appropriate) all the Protected Material that was returned or destroyed and that

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affirms that the Receiving Party has not retained any copies, abstracts, compilations,

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summaries or other forms of reproducing or capturing any of the Protected Material.

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Notwithstanding this provision, Counsel are entitled to retain an archival copy of all

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pleadings, motion papers, transcripts, legal memoranda, correspondence or attorney

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work product, even if such materials contain Protected Material. Any such archival

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copies that contain or constitute Protected Material remain subject to this Protective

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Order as set forth in Section 4 (DURATION), above.

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[PROPOSED] ORDER ON STIPULATION FOR PROTECTIVE ORDER

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12.0 MISCELLANEOUS

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

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person to seek its modification by the Court in the future.
12.2 Right to Assert Other Objections. By stipulating to the entry of this

864 E. SANTACLARA STREET ■ VENTURA, CA 93001 ■ TELEPHONE: [phone] ■ FAX: [phone] ■ WWW.ANDERSONKILL. COM

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

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ANDERSON KILL WOOD & BENDER P.C.

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

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

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

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12.3 Limited to Discovery Only. This Order shall not govern materials

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submitted in connection with dispositive motions or at trial. If the parties desire

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protection for materials submitted in connection with those proceedings, they must

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apply separately to the jurist who will preside at those proceedings. Foltz v. State

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Farm Mut. Auto Ins. Co., 331 F.3d 1122, 1136 (9th Cir2003); Kamamana v. City

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and County of Honolulu, 447 F.3d 1172 (9th Cir. 2006).

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IT IS SO ORDERED:

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Date: July 11, 2012

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By:

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Hon. Ralph Zarefsky
United States Magistrate Judge

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[PROPOSED] ORDER ON STIPULATION FOR PROTECTIVE ORDER

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EXHIBIT A

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CONFIDENTALITY AGREEMENT

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I, _________________________________________________________,

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in this action, CLASSIC DISTRIBUTING AND BEVERAGE GROUP, INC. v.

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864 E. SANTACLARA STREET ■ VENTURA, CA 93001 ■ TELEPHONE: [phone] ■ FAX: [phone] ■ WWW.ANDERSONKILL. COM

acknowledge I have read the Stipulated Protective Order Re: Confidentiality entered

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ANDERSON KILL WOOD & BENDER P.C.

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TRAVELERS CASUALTY AND SURETY COMPANY OF AMERICA, et al.,

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United States District Court Case No. CV 11-07075 GAF (RZx). I understand the

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terms of the Stipulated Protective Order Re: Confidentiality, and I agree to be bound

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by it. I further understand that a violation of this Stipulated Protective Order Re:

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Confidentiality may be punishable as a contempt of court.

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By:

__________________________

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Print: __________________________

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Date: __________________________

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[PROPOSED] ORDER ON STIPULATED PROTECTIVE ORDER

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CERTIFICATE OF SERVICE

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I, David A. Shaneyfelt, an attorney, hereby certify that on July 9, 2012, I

Filing (ECF) system in the United States District Court for the Central District of

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864 E. SANTACLARA STREET ■ VENTURA, CA 93001 ■ TELEPHONE: [phone] ■ FAX: [phone] ■ WWW.ANDERSONKILL.COM

caused a copy of the foregoing document to be served via the Electronic Case

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ANDERSON KILL WOOD & BENDER P.C.

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California, on all parties registered for e-filing in Case Number CV 11-07075 GAF

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(RZx). Counsel of record are required by the Court to be registered e-filers, and as

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such, are automatically e-served with a copy of the documents upon confirmation

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of e-filing.

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s/ David A. Shaneyfelt_________
David A. Shaneyfelt

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14
[PROPOSED] ORDER ON STIPULATED PROTECTIVE ORDER

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