Will Loomis v. Jessica Cornish et al

Filing 25

PROTECTIVE ORDER by Magistrate Judge John E. McDermott re Stipulation for Protective Order 24 . (san)

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CHRISTINE LEPERA (admitted pro hac vice)
[e-mail]
CHRISTINA E. DJORDJEVICH (SBN 262721),
[e-mail]
MITCHELL SILBERBERG & KNUPP LLP
12 E. 49th Street, 30th Floor
New York, NY 10017
Telephone: [phone]
ELAINE K. KIM (SBN 242066)
[e-mail]
MITCHELL SILBERBERG & KNUPP LLP
11377 West Olympic Boulevard
Los Angeles, California 90064-1683
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendants Jessica Cornish,
UMG Recordings, Inc. (erroneously sued as
Universal Music Group, Inc.) and Universal
Republic Records, a division of
UMG Recordings, Inc.

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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WILL LOOMIS, an individual,
Plaintiff,

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Hon. John E. McDermott

v.

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CASE NO. CV 12-5525-RSWL(JEMx)

JESSICA CORNISH, P/K/A JESSIE J,
an individual; UNIVERSAL MUSIC
GROUP, INC., a Delaware corporation;
LAVA RECORDS LLC, a limited
liability company; UNIVERSAL
REPUBLIC RECORDINGS, business
form unknown; and DOES 1 – 10
INCLUSIVE,

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[PROPOSED] PROTECTIVE
ORDER

Courtroom: C, 8th Floor

Defendants.

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This Court finds that good cause exists for a Protective Order on the terms
and conditions stipulated by the parties.
Therefore, IT IS ORDERED as follows:

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1.

DEFINITIONS

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1.1

As used herein, the term “Confidential Information” shall mean: (a)

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any type of information that has not been made generally available to the public

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and the disclosure of which the disclosing party or third party contends would

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cause serious harm to the disclosing party’s or third party’s business operations or

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interests, including, but not limited to, contracts for personal services, customer

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lists, customer data, costs of goods or services sold, manufacturing or other costs

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of doing business, employee salaries, marketing plans, financial performance data,

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sales records, inventory sheets, and manufacturing, product development, and

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business development strategies; (b) data derived from such Confidential

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Information, including any summaries, compilations, quotes, or paraphrases

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thereof; (c) any other oral, written, or recorded material that consists of or contains

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trade secrets (as defined in California Civil Code § 3426.1(d)) or other confidential

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research, development, or commercial information (as referred to in Fed. R. Civ. P.

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26(c)(1)(G)); or (d) any other information that the designating party reasonably

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believes (1) constitutes proprietary information, confidential business information,

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information that the designating party may need, for any business, employment or

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competitive purposes, to be protected from disclosure, trade secrets, and/or

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information in which the party or any third party has a privacy interest, or (2) is

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subject to protection from disclosure, or limitation upon disclosure, under

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applicable law.

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1.2

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As used herein, the terms “document,” “documents,” “tangible

things,” “recordings,” and “photographs” mean documents, writings, tangible

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things, recordings, and photographs as defined in Fed. R. Civ. P. 34(a) and Fed. R.

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Evid. 1001, and include, but are not limited to, records, exhibits, reports, samples,

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transcripts, video or audio recordings, disks, affidavits, briefs, summaries, notes,

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abstracts, drawings, company records and reports, answers to interrogatories,

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responses to requests for admissions, and motions, including copies or computer-

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stored versions of any of the foregoing.

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2.

DESIGNATION OF CONFIDENTIAL INFORMATION

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2.1

This PROTECTIVE ORDER applies to all discovery responses,

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documents, testimony, and other information or materials containing Confidential

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Information disclosed in this action that are designated by a party or third party as

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CONFIDENTIAL or HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY,

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as defined below, whether such disclosure is by order of the Court or by response

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to questions in a deposition, written interrogatories, requests for the production of

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documents and other tangible things, requests for admission, Rule 45 subpoenas to

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third parties, or any other discovery undertaken in this action.

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2.2

Any party or third party responding to discovery in this action shall

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have the right to designate any document, testimony, or other information or

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material as “Highly Confidential – Attorneys’ Eyes Only.” “Highly Confidential –

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Attorneys’ Eyes Only” information is information that the designating party

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reasonably believes contains Confidential Information which reasonably requires

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for its protection to be treated as “Highly Confidential – Attorneys’ Eyes Only.”

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2.3

Such designation shall be accomplished by placing the notation

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ONLY” on every page of each document or portion thereof so designated. In the

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case of Confidential Information disclosed in a non-paper medium (e.g., videotape,

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“CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES

audiotape, computer disks, etc.), the appropriate notation shall be affixed to the

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[PROPOSED] PROTECTIVE ORDER

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outside of the medium or its container so as to clearly give notice of the

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designation. Such designation is deemed to apply to the document itself and to the

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Confidential Information contained therein.
2.4

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Confidential Information so designated shall be used only for the

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purposes of this litigation and may not be used by any party to whom or which that

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information is produced or disclosed for research, development, sales, marketing,

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publicity, or competitive purposes, or any other purpose. Confidential Information

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so designated shall not be disclosed to anyone other than those persons identified

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in Paragraphs 4.3 and 4.4, infra, except as may be ordered by the Court or agreed

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to in writing by the parties. If any information designated by a party or third party

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as CONFIDENTIAL or HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES

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ONLY is thereafter used by a party to whom or which it has been produced or

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disclosed as part of a paper filed or lodged with the Court in this action or in a

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response to a discovery request in this action, the party using that information shall

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take all reasonable steps to preserve the continued confidentiality of that

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designated Confidential Information. This includes maintaining the designation of

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confidentiality in all places where that information is so used and requesting that

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such information is filed or lodged with the Court under seal in accordance with

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the procedures of C.D. Cal. Local Rule 79-5.1.
2.5

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The parties and any third parties responding to discovery in this action

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shall use reasonable care to avoid designating any materials as CONFIDENTIAL

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or HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY that are: (a) not

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entitled to such designation, or (b) generally available to the public.

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3.

DEPOSITIONS

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3.1

With respect to the examination of witnesses upon oral deposition,

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when designated Confidential Information is supplied to the deponent, or when the

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deponent’s testimony contains, reflects, or comments on designated Confidential

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Information, the deposition reporter and/or videotape operator shall be informed of

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this PROTECTIVE ORDER by the party or third party seeking to invoke its

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protection, and will be required to agree to be bound by its terms. The reporter

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and/or videotape operator then shall place on the cover of any deposition transcript

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or videotape that contains any designated Confidential Information the words

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“CONTAINS CONFIDENTIAL INFORMATION SUBJECT TO A COURT

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PROTECTIVE ORDER.” Counsel for the parties then shall take appropriate steps

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to prevent any portions of any deposition transcript or videotape designated

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CONFIDENTIAL or HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY

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from being disclosed to any person, except as provided in this PROTECTIVE

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ORDER.

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3.2

Testimony at a deposition may be designated CONFIDENTIAL or

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HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY if this PROTECTIVE

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ORDER is invoked at the deposition by counsel for a party or third party or the

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deponent. The designating party or third party also may, within thirty (30) days

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after receiving a copy of the deposition transcript, provide all parties with a written

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list of the page(s) of the deposition transcript, and any exhibits attached thereto,

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that the party or third party designates as CONFIDENTIAL or HIGHLY

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CONFIDENTIAL – ATTORNEYS’ EYES ONLY. If a deponent has disclosed

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something at a deposition that a party or third party believes constitutes

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Confidential Information and should be designated as such, the party or third party

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so believing can go back during the deposition and designate that information as

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may be appropriate.
3.3

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Each deponent to whom any party or third party proposes to disclose

designated Confidential Information at a deposition, trial, or other proceeding shall

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be given a copy of this PROTECTIVE ORDER and informed of its contents and

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the parties shall take all reasonable steps to have such witnesses abide by the same.
3.4

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If designated Confidential Information is to be discussed or disclosed

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in a deposition, any party or third party claiming such confidentiality may exclude

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from the room any person who is not entitled to receive such Confidential

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Information during that portion of the deposition in which the Confidential

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Information is actually discussed or disclosed. If designated Confidential

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Information is to be discussed or disclosed at a hearing or at trial, the parties may

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request that the Court exclude from the courtroom any person who is not entitled to

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receive such Confidential Information during that portion of the hearing or trial in

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which the Confidential Information is actually discussed or disclosed.

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4.

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DISCLOSURE OF DESIGNATED CONFIDENTIAL
INFORMATION

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4.1

The parties, counsel for the parties, and all persons who view

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designated Confidential Information shall maintain all information designated as

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CONFIDENTIAL or HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY

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in confidence and shall not disclose such information, directly or indirectly, to any

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person except as provided in this PROTECTIVE ORDER.

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4.2

While the disclosure of Confidential Information designated

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CONFIDENTIAL or HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY

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to persons not authorized by this PROTECTIVE ORDER could, by definition, be

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prejudicial to the business, operations, or interests of the designating party or third

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party, the designations should not be overused.

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4.3

Access to Confidential Information designated as CONFIDENTIAL

shall be limited to the following persons:

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4.3.1

Outside and in-house counsel for the parties and their

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support personnel such as paralegal assistants, secretarial, stenographic and clerical

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employees and contractors, and outside copying services who are working on this

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litigation under the direction of such attorneys and to whom it is necessary that the

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materials be disclosed for purposes of this litigation.
4.3.2

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Bona fide experts and/or consultants (together with their

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clerical staff) retained by counsel of record on behalf of the parties for purposes of

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this litigation.
4.3.3

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Pursuant to Paragraphs 3.1 through 3.4, supra, deponents

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at their depositions. Counsel should have a good faith belief that such disclosure is

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necessary before disclosing designated Confidential Information to the deponent.

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4.3.4

Court reporter(s) employed in this litigation.

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4.3.5

The parties to this action, as well as current officers,

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directors, and employees of the parties to this action that are corporate entities.
4.3.6

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The Court and its staff, mediators used in settlement

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proceedings in this action and their staff, and members of a jury impaneled for a

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trial in this action.
4.4

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Access to Confidential Information designated as HIGHLY

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CONFIDENTIAL – ATTORNEYS’ EYES ONLY shall be limited to the

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following persons:

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4.4.1

Outside and in-house counsel for the parties and their

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support personnel such as paralegal assistants, secretarial, stenographic and clerical

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employees and contractors, and outside copying services who are working on this

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litigation under the direction of such attorneys and to whom it is necessary that the

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materials be disclosed for purposes of this litigation.

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4.4.2

Bona fide experts and/or consultants (together with their

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clerical staff) retained by counsel of record on behalf of the parties for purposes of

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this litigation.
4.4.3

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Pursuant to Paragraphs 3.1 through 3.4, supra, deponents

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at their depositions. Counsel should have a good faith belief that such disclosure is

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necessary before disclosing designated Confidential Information to the deponent.

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4.4.4

Court reporter(s) employed in this litigation.

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4.4.5

The Court and its staff, mediators used in settlement

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proceedings in this action and their staff, and members of a jury impaneled for a
trial in this action.
4.5

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Nothing herein shall prohibit a party, or his or its counsel, from

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disclosing a document that contains Confidential Information to the person whom

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the document identifies as an author, addressee, or recipient of such document.

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5.

CHALLENGING A DESIGNATION

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5.1

A party which disputes the propriety of a designation shall challenge

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such designation within a reasonable time after the materials are so designated. In

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the event that a party challenges such designation, the party shall provide written

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notice to the designating party of its disagreement with the designation. The

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parties shall first attempt to resolve the dispute in good faith and shall employ the

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procedures of Local Rules 37-1 through 37-4 to resolve that dispute. If the dispute

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cannot be resolved, the receiving party may apply to the Court for a ruling

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concerning the status of such material, and, pending such application and ruling,

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the receiving party shall treat such material as Confidential Information under this

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PROTECTIVE ORDER. Upon any hearing, the burden of proving that material

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has been properly designated is on the party making such designation.

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5.2

For documents that any party might wish to file with the Court under

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seal, that party shall employ the procedures of Local Rule 79-5.1 and comply with

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the requirements of Section 9, infra.
5.3

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No party shall be obliged to challenge the propriety of a designation,

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and a failure to do so shall not preclude a subsequent attack on the propriety of any

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other designation.

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6.

INADVERTENT FAILURE TO DESIGNATE

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6.1

The inadvertent failure to designate Confidential Information as

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CONFIDENTIAL or HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY

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prior to or at the time of disclosure shall not operate as a waiver of a party’s or

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third party’s right to designate such information within thirty (30) days after such

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disclosure or, if the information is provided by a third party, within thirty (30) days

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after notice of such disclosure.

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6.2

In the event that Confidential Information is designated as

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CONFIDENTIAL or HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY

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after disclosure but within the thirty (30) day period allowed under Paragraph 6.1,

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supra, the receiving party shall employ reasonable efforts to ensure that all

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previously disclosed Confidential Information is subsequently treated as

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CONFIDENTIAL or HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY,

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as appropriate, pursuant to the terms of this PROTECTIVE ORDER.

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6.3

Should any document or information designated as CONFIDENTIAL

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through inadvertence or otherwise, to any person or party not authorized to see

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such materials under this PROTECTIVE ORDER, then the disclosing party or

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third party shall use its best efforts to bind such person to the terms of this

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or HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY be disclosed,

PROTECTIVE ORDER, and the disclosing party shall: (a) promptly inform such

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person of all the provisions of this PROTECTIVE ORDER, and (b) identify the

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name, address, telephone number, employer, and title or position of such person

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immediately to the party or third party that or who designated the document.

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7.

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CUSTODY AND DISPOSITION OF DESIGNATED
CONFIDENTIAL INFORMATION

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7.1

Confidential Information designated CONFIDENTIAL or HIGHLY

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CONFIDENTIAL – ATTORNEYS’ EYES ONLY shall be maintained in the

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custody of counsel for the parties, except for information in the custody of: (a) the

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Court; (b) any court reporter transcribing testimony given in this action, for the

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limited purpose of rendering his or her normal transcribing services; and (c)

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consultants entitled to see such information under the terms of this PROTECTIVE

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ORDER, to the extent necessary for their study, analysis, and preparation of the

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case. Except for the Court, a person with custody of information designated

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CONFIDENTIAL or HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY

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shall maintain it in a manner that limits access to it to only those persons entitled

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under this PROTECTIVE ORDER to examine it. Counsel may furnish

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information designated CONFIDENTIAL or HIGHLY CONFIDENTIAL –

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ATTORNEYS’ EYES ONLY in written format to persons authorized under this

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PROTECTIVE ORDER to receive it.

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7.2

Unless counsel agree otherwise in writing, within sixty (60) days of

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decision of the Court, the parties, counsel for the parties, and all other persons who

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are in possession of documents designated CONFIDENTIAL or HIGHLY

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CONFIDENTIAL – ATTORNEYS’ EYES ONLY agree that they will (a) destroy

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or return to the producing party or third party all hard copy documents, other than

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the conclusion of this litigation, whether by settlement or final, non-appealable

attorney work product, containing designated Confidential Information produced

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by a party or third party; and (b) delete all electronically stored documents, other

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than attorney work product, containing designated Confidential Information

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produced by a party or third party. Notwithstanding the foregoing, the parties

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shall not have any obligation under this Protective Order to ensure the destruction

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of any copies of electronically-stored Confidential Information made by the

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automatic processes of their computer systems, including but not limited to any

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such copies that may reside on their servers and/or backup tapes.
7.3

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Notwithstanding the foregoing, counsel of record and each party shall

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be permitted to retain a file copy of all pre-trial, trial, and post-trial materials,

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depositions and deposition exhibits, and document databases. Nothing in this

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paragraph shall be construed to require any party to return or destroy work product

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or attorney client privileged communications, whether from or to outside or in-

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house counsel. Such file copies must be maintained under the conditions of

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maintaining confidentiality as set forth in Paragraph 7.1, supra.

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8.

MISCELLANEOUS PROVISIONS

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8.1

Except as otherwise set forth in Paragraphs 8.5-8.7 regarding the

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introduction and use of Confidential Information at trial and by the Court, and as

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may be required by law or legal process, the obligations of confidentiality and

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nondisclosure shall be effective and shall be respected by the parties and all

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persons in any way involved in these proceedings or to whose attention

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Confidential Information shall come unless and until otherwise ordered by the

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Court or stipulated by all parties to this action. These obligations of confidentiality

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and nondisclosure shall bind the parties through all proceedings in this action,

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including all appeals, arbitrations, and proceedings upon remand, and shall survive

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the conclusion of this action unless and until otherwise ordered by the Court, or

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until the parties to this action stipulate that designated Confidential Information

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can be disclosed.

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8.2

By entering into this PROTECTIVE ORDER, no party or third party

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waives any objections it might have to the production of documents or information

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covered by this PROTECTIVE ORDER.
8.3

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No party to this action, by entering into this PROTECTIVE ORDER,

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by designating certain information as CONFIDENTIAL or HIGHLY

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CONFIDENTIAL – ATTORNEYS’ EYES ONLY, or by acquiescing in any other

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party’s such designation, shall be deemed to have admitted or agreed that any such

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designated information is, in fact, a trade secret or other confidential research,

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development, or commercial information.
8.4

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The Court retains jurisdiction even after termination of this action to

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enforce this PROTECTIVE ORDER and to make such deletions from or

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amendments, modifications, and additions to the PROTECTIVE ORDER that the

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Court may from time to time deem appropriate. The parties hereto reserve all

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rights to apply to the Court at any time, before or after termination of this action,

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for an order modifying this PROTECTIVE ORDER or seeking further protection

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against disclosure or use of claimed Confidential Information.
8.5

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Nothing contained herein shall restrict any party from introducing

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designated Confidential Information as evidence at trial. A party may seek a

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protective order prior to trial with respect to testimony containing designated

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Confidential Information that may be offered at trial or specific documents

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containing designated Confidential Information that may be marked as exhibits at

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trial in order to maintain the continued confidentiality of such information.
8.6

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In general, court orders are available to the public. To the extent that

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a party refers to or relies upon material that is filed under seal in its pleadings, the
pleadings must request that specific information be kept confidential. Absent the

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granting of such advance request, the Court may incorporate all evidence in its

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written and oral rulings.
8.7

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In the event the case proceeds to trial, all information that was subject

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to the provisions of a protective order and that is used at trial will become public

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absent a separate court order upon motion and sufficient cause shown.

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9.

FILING OR LODGING UNDER SEAL

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9.1

If any party or third party seeks to file or lodge with the Court any

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documents or things that contain designated CONFIDENTIAL or HIGHLY

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CONFIDENTIAL – ATTORNEYS’ EYES ONLY, such materials shall be

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submitted to the Court in accordance with the procedures set forth in C.D. Cal.

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Local Rule 79-5.1 for filing documents under seal. Where one party or third party

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wishes to file or lodge any documents or things with the Court under seal, the other

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party or parties shall not unreasonably withhold agreement to such filing or

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lodging under seal. If such agreement is provided, the parties shall submit to the

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Court a stipulation and proposed order for such filing or lodging under seal. If no

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such agreement is provided, then the filing or lodging party or third party shall

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submit an application and proposed order to the Court pursuant to C.D. Cal. Local

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Rule 79-5.1.

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9.2

The person filing Confidential Information under C.D. Cal. Local

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Rule 79-5.1 shall designate to the Clerk that all or a designated portion thereof is

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subject to this PROTECTIVE ORDER and is requested to be kept under seal,

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except that upon the default of the filing party to so designate, any party may do

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so.

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10.

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Pursuant to Fed. R. Civ. P. 26(c), good cause exists for entry of this

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PROTECTIVE ORDER because the parties to this action: (1) have sought and

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expect to seek in the future the discovery of certain information in this action that

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is sensitive, private, and confidential, or that third parties required to get involved

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in discovery in this action might believe is sensitive, private, and confidential,

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including, but not limited to, (a) information concerning the amounts paid under

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and other terms in confidential contracts entered into by the parties with third

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parties, and the financial and other terms of contracts entered into by the parties

GOOD CAUSE STATEMENT

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that are competitively sensitive and that would harm the parties if such terms were

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disclosed to their competitor, (b) other information that constitutes proprietary

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information, confidential business information, information that a party or third

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party may need, for any business, employment or competitive purposes, to be

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protected from disclosure, (c) trade secrets, and/or information in which a party or

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any third party has a privacy interest, and (d) information that is subject to

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protection from disclosure, or limitation upon disclosure, under applicable law; (2)

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believe that unrestricted disclosure or dissemination of such Confidential

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Information will cause them some business, commercial, and privacy injury; (3)

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desire an efficient and practicable means to designate such information as

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CONFIDENTIAL or HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY

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and thereby help ensure its continued protection against unwarranted disclosure or

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dissemination; and (4) have agreed to such means as set forth herein.

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DATED: March 26, 2013

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/s/John E. McDermott
Honorable John E. McDermott
United States Magistrate Judge

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