Warner Bros Entertainment Inc et al v. The Global Asylum Inc

Filing 78

STIPULATED PROTECTIVE ORDER by Magistrate Judge Carla Woehrle. The parties in the above-captioned case having requested that the Court issue a protective order pursuant to Fed. R. Civ. P. 26(c) to protect the confidentiality of non-public and competitively sensitive information that may need to be disclosed in connection with discovery in this case, and the parties having stipulated to entry of this Order. 77 [SEE ORDER FOR FURTHER DETAILS] (gr)

JENNER & BLOCK LLP
Andrew J. Thomas (SBN 159533)
[e-mail]
Lisa J. Kohn (SBN 260236)
[e-mail]
633 West Fifth Street, Suite 3600
Los Angeles, CA 90071
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Plaintiffs
WARNER BROS. ENTERTAINMENT
INC., NEW LINE CINEMA LLC, NEW
LINE PRODUCTIONS, INC., METROGOLDWYN-MAYER STUDIOS INC.,
and THE SAUL ZAENTZ COMPANY

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LAW OFFICES OF SCOTT A. MEEHAN
Scott A. Meehan (SBN 139314)
2945 Townsgate Road, Suite 200
Westlake Village, CA 91361
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendant
THE GLOBAL ASYLUM, INC.

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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WARNER BROS.
ENTERTAINMENT INC., a Delaware
corporation; NEW LINE CINEMA
LLC, a Delaware limited liability
company; NEW LINE
PRODUCTIONS, INC., a California
corporation; METRO-GOLDWYNMAYER STUDIOS INC., a Delaware
corporation; and THE SAUL ZAENTZ
COMPANY, a Delaware corporation,

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v.

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Case No. 2:12-cv-09547-PSG-CW
STIPULATED PROTECTIVE
ORDER

Plaintiffs,

THE GLOBAL ASYLUM INC. (aka
The Asylum), a California corporation,

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Defendant.

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[Proposed] Stipulated Protective Order

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STIPULATED PROTECTIVE ORDER

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The parties in the above-captioned case having requested that the Court issue

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a protective order pursuant to Fed. R. Civ. P. 26(c) to protect the confidentiality of

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non-public and competitively sensitive information that may need to be disclosed

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in connection with discovery in this case, and the parties having stipulated to entry

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of this Order, and the Court having found that good cause exists:

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IT IS HEREBY ORDERED that this Protective Order pursuant to Rule 26(c)

8 of the Federal Rules of Civil Procedure be, and is hereby, entered.
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1)

This Protective Order shall be applicable to and govern all

10 depositions, documents, or electronically stored information produced in response
11 to requests for production, answers to interrogatories, responses to requests for
12 admission, and other discovery taken pursuant to the Federal Rules of Civil
13 Procedure, as well as other information hereafter furnished, directly or indirectly,
14 by or on behalf of any party or non-party in connection with this action
15 (collectively, “Discovery Materials”) that the party or non-party in good faith
16 believes comprise or reflect confidential and/or proprietary information used by it
17 in, or pertaining to, its business, which is not generally known and which the party
18 or non-party normally would not reveal to third parties or would cause third parties
19 to maintain in confidence, including without limitation proprietary, commercially
20 sensitive, or otherwise confidential financial, business, trade secret, research,
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development, technical, strategic, and/or personal information.

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2)

Discovery Materials governed by this Protective Order shall be used

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by any recipients solely for the purpose of conducting this litigation captioned

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Warner Bros. Entertainment Inc. et al. v. The Global Asylum, Inc., No. 2:12-cv-

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09547-PSG-CW (hereinafter “this litigation” or “this action”), and such

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information shall not be disclosed to anyone except as provided herein.

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3)

Any information or materials produced by any party or non-party as

28 part of discovery in this action may be designated as “Confidential” or “Highly
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[Proposed] Stipulated Protective Order

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Confidential” by such party or non-party pursuant to Paragraph 4 of this Protective

2

Order.
a)

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“Confidential Information” shall include any Discovery

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Material which the producing party or non-party reasonably believes not to be in

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the public domain and which contains proprietary, commercially sensitive, or

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otherwise confidential financial, business, trade secret, research, development,

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technical, strategic, and/or personal information.
b)

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“Highly Confidential Information” shall include financial

information, including cost, pricing, sales, revenue, profit or compensation

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information; customer, license, supplier, and vendor information; business plans;

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marketing strategies; trade secrets, as that term is defined under applicable law;

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and other information that the producing party or non-party reasonably believes is

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of a highly proprietary or competitively sensitive nature.
4)

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The designation of information or material for purposes of this

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Protective Order shall be made in the following manner by the party or non-party

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seeking protection:
a)

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In the case of documents, electronically stored information,

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interrogatory responses, responses to requests for admission, or other material

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(apart from depositions): by affixing a plainly visible confidentiality designation

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legend (“CONFIDENTIAL” or “HIGHLY CONFIDENTIAL,” as appropriate):

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(i) on each page of any document containing any confidential material; or

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(ii) physically on the outside of any media for storing electronic documents, at the

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time such documents are produced or such information is disclosed, or as soon

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thereafter as the party or non-party seeking protection becomes aware of the

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confidential nature of the information or material disclosed and sought to be

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protected hereunder. The terms “documents” and “electronically stored

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information” as used in this Protective Order, shall have the broadest meaning

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permissible under the Federal Rules of Civil Procedure and shall include, as
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[Proposed] Stipulated Protective Order

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relevant and without limitation, all “writings,” “recordings,” and “photographs” as

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defined in Rule 1001 of the Federal Rules of Evidence, and any information stored

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in or through any computer system or other electronic or optical data storage

4

device.
b)

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In the case of depositions: (i) by a statement on the record, by

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counsel, during such deposition that the entire transcript or a portion thereof shall

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be designated either “Confidential” or “Highly Confidential” hereunder; or (ii) by

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written notice of such designation sent by counsel to all parties within ten (10)

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court days after the mailing to counsel (via next business day delivery) of the

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transcript of the deposition. At or before a deposition, the deponent or his or her

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counsel, or any other counsel, acting in good faith, may invoke the provisions of

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this Protective Order in a timely manner, giving adequate warning to counsel for

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the party or non-party that testimony about to be given is deemed protected under

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this Protective Order. Whether or not so designated on the record at deposition,

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the parties shall treat all deposition testimony as “Confidential” under this

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Protective Order until the expiration of ten (10) court days after the mailing (via

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next business day delivery) to counsel of the transcript of the deposition. Unless

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specific designations of all or portions of a transcript have been made on the record

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during the proceeding, or in writing within ten (10) court days after the mailing to

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counsel (via next business day delivery) of the transcript of the deposition, any

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confidentiality is waived after the expiration of the 10-day period unless otherwise

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stipulated or ordered. The parties may modify this procedure for any particular

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deposition through agreement on the record at such deposition or otherwise by

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written stipulation, without approval of the Court.
c)

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A party or non-party furnishing documents and things to

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another party for inspection shall have the option to require that all or batches of

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documents and things be treated as confidential during inspection and to make its

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designations of particular documents and things at the time copies of documents
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[Proposed] Stipulated Protective Order

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and things are produced or furnished. A party or non-party that desires to proceed

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in this manner shall inform counsel for all parties in writing before the inspection.
5)

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“Confidential Information” may be disclosed, described,

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characterized, or otherwise communicated or made available in whole or in part

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only to the following persons:
a)

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Outside counsel in this litigation and the staff and supporting

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personnel of such attorneys, including paralegals, secretaries, clerical employees,

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and, to the extent necessary, outside copying, imaging, and trial

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consultants/presentation services, who are working on this litigation under the

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direction of such attorneys;

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b)

In-house counsel for the parties herein and their parent

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corporations, if any, who are responsible for the oversight of this litigation and the

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staff and supporting personnel of such attorneys;

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c)

The parties to this litigation;

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d)

Subject to Paragraphs 8 and 9 herein, persons who are expressly

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retained or sought to be retained by a party or a party’s counsel as consultants or

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testifying experts, provided that the disclosure of “Confidential” material to any

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persons under this subparagraph shall only be to the extent necessary to perform

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their work on this litigation.

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e)

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Subject to Paragraph 9 herein, any other persons who are

designated to receive material designated “Confidential” by order of this Court

22 after notice to the parties, or by written stipulation of the parties.

f)

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Witnesses in a deposition or other pretrial proceeding, during

24 the course of their testimony, provided that counsel for a party has a good faith
25 basis to believe that the witness has knowledge of the information or material
26 designated “Confidential” or the specific events, transactions or discussions
27 reflected in the information or material. Witnesses shown information designated
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“Confidential” shall not be allowed to retain copies.
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[Proposed] Stipulated Protective Order

g)

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Persons who authored, prepared, or received information or

material designated “Confidential” under circumstances that do not constitute a

3 violation of the Protective Order.

h)

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The Court and Court personnel, court reporters, interpreters,

5 and videographers employed in connection with this action.

6)

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“Highly Confidential” Information may be disclosed, described,

7 characterized, or otherwise communicated or made available in whole or in part
8 only to the following persons:

a)

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Outside counsel in this litigation and staff and supporting

10 personnel of such attorneys, such as paralegals, secretaries, stenographic and
11 clerical employees and contractors, and outside copying, imaging, and trial
12 consultant/presentation services, who are working on this litigation under the
13 direction of such attorneys;

b)

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In-house counsel for the parties herein who are necessary for

15 the furtherance of this litigation and staff and supporting personnel of such
16 attorneys;

c)

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Subject to Paragraphs 8 and 9 herein, persons who are expressly

18 retained or sought to be retained by a party or a party’s counsel as consultants or
19 testifying experts; provided that the disclosure of “Highly Confidential” material to
20 any persons under this subparagraph shall only be to the extent necessary to
21 perform their work on this litigation;

d)

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Subject to Paragraph 9 herein, any other persons who are

23 designated to receive material designated “Highly Confidential” by order of this
24 Court after notice to the parties, or by written stipulation of the parties.

e)

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Persons of whom testimony is to be taken during a deposition

26 or other pretrial proceeding, during the course of their testimony, provided that
27 counsel for a party has a good faith basis to believe that the witness has knowledge
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[Proposed] Stipulated Protective Order

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of the information or material designated “Highly Confidential” or the specific

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events, transactions or discussions reflected in the information or material.
f)

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Persons who authored, prepared, or received information or

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material designated “Highly Confidential” under circumstances that do not

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constitute a violation of the Protective Order.
g)

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The Court and Court personnel, court reporters, interpreters,

and videographers employed in connection with this action.
7)

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The parties retain the right to apply to the Court for an order

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restricting certain individuals from access to certain information. To accomplish

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this, counsel for a party wishing to restrict access to information shall produce the

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information (i.e., document or electronically stored information) to all counsel for

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whom there is no objection, with a request that the information not be disseminated

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to other individuals involved in this litigation pending further order of the Court.

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The moving party shall, thereafter, within five (5) court days, file the information

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under seal with the Court and identify the person (by name and title) who the

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moving party objects to seeing the information and why the moving party believes

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the information should not be received by this person(s). If the Court is inclined to

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grant the order, it will notify the aggrieved party and invite briefing before issuing

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an order.

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8)

For purposes of this Protective Order, a consultant or expert shall be

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restricted to a person who is retained or employed as a bona fide consultant or

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expert for purposes of this litigation, whether full or part time, by or at the

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direction of a party or counsel for a party. The name, business address, curriculum

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vitae (“CV”) and affiliation of each such consultant or expert must be disclosed to

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the producing party at least five (5) court days prior to such person’s review of

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material designated under this Order. The CV shall contain a list of all present

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employers/clients as well as all past employers/clients for the 36 months preceding

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the date of employment in this case. During that five-day period, counsel for the
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[Proposed] Stipulated Protective Order

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designating party shall have the opportunity to oppose the proposed disclosure.

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Any party opposing disclosure shall within such five-day period provide the other

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party with a written objection, setting forth in reasonable detail the specific

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grounds for such opposition. If no written objection is received by 5:00 p.m.,

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Pacific time, on the fifth day following the date of disclosure of the identity of the

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proposed consultant or expert, then the party seeking to disclose may do so and

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failure to object shall constitute waiver of the specific objection. However, after

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the five-day period has expired without objection, a party may still move the Court

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to allow it to object to a consultant or expert if it can show: (i) there is new,

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material information relating to the consultant or expert that was not available to

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the moving party within the five-day objection period; and (ii) had the moving

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party been aware of the information at the time, the moving party would have

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objected to the consultant or expert. Such motion shall be made within ten (10)

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court days of coming into possession of such new, material information relating to

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such consultant or expert. In the event such resolution by the Court is necessary,

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no additional confidential material shall be disclosed to the consultant or expert

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pending resolution of the issue by the Court.
9)

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Persons retained or sought to be retained as bona fide consultants or

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testifying experts, and any other persons who are designated to receive material

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designated “Confidential” by order of this Court after notice to the parties, or by

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written stipulation of the parties, shall, prior to receiving such material, be

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furnished with a copy of this Protective Order, and a copy of the Certification

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attached as Exhibit A, which the person shall read and sign, unless the Parties have

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specifically agreed that execution of the Certification is not necessary for such

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person. Counsel for the party seeking to disclose material designated under this

26 Protective Order to any such person pursuant to this paragraph shall be responsible
27 for permanently retaining the executed originals of all such Certifications. Copies
28 of any such Certifications executed by persons retained or sought to be retained as
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[Proposed] Stipulated Protective Order

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bona fide consultants or experts shall be provided to counsel for the other parties or

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affected nonparties upon request, once the consultant or expert has been disclosed

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in accordance with Paragraph 8. Copies of any such Certification executed by any

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other person shall be provided to counsel for the other parties or affected

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nonparties upon request.
10)

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The recipient of any material designated under this Order shall use

reasonable efforts to maintain the confidentiality of such information.
11)

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Any third party may obtain protection of this Protective Order by

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complying with Paragraphs 3 and 4 of this Protective Order regarding designating

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of materials under the Order. A party making a discovery request to a non-party in

11 this action shall notify that non-party that the protections of the Protective Order
12 are available to such non-party.

12)

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All exhibits, pleadings, discovery responses, documents, testimony or

14 other submissions filed with the Court pursuant to this action that have been
15 designated “Confidential” or “Highly Confidential” by any party, or any pleading
16 or memorandum purporting to reproduce, paraphrase, or otherwise disclose such
17 information designated as Confidential Information, shall be marked with the
18 legend “Confidential” and shall be filed pursuant to and in compliance with Local
19 Rule 79-5.1. If a filing under seal is requested, a written application and proposed
20 order shall be presented along with the document for filing under seal. The
21 original and judge’s copy of the document shall be sealed in separate envelopes
22 with a copy of the title page attached to the front of each envelope. The
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application shall request that the Court return the underlying document and the

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sealed application without filing to the extent the Court denies the application to

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file under seal. The party seeking to seal documents must demonstrate for each

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document or category of documents sufficient grounds to warrant placing the

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documents under seal.

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[Proposed] Stipulated Protective Order

13)

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A party receiving Discovery Materials designated under this

2

Protective Order may object to such designation in whole or in part at any time, by

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giving written notice of such objection to the producing party. Within ten (10)

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court days of receiving such written notice, the producing party shall confer

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directly (i.e., in person or by telephone) with the receiving party in good faith for

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the purpose of resolving any such objection. In conferring, the challenging party

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must explain the basis for its belief that the confidentiality designation was not

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proper and must give the designating party an opportunity to review the designated

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

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offered, to explain the basis for the chosen designation. If the objection is not

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resolved after the parties confer, then any party may request a conference with the

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Court and/or file a motion to resolve the dispute. Pending the Court’s

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determination, the information subject to dispute shall be treated as subject to the

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Protective Order. The burden of proving that information has been properly

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designated under this Protective Order is on the person or entity making the

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designation.
14)

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Nothing in this Protective Order shall preclude any party to this

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litigation or its counsel: (i) from showing a document designated under this

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Protective Order to an individual who either prepared or reviewed the document

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prior to the filing of this action; or (ii) from disclosing or using, in any lawful

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manner or for any lawful purpose, any information or documents from the party’s

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own files that the party itself has designated under this Protective Order.
15)

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Nothing in this Protective Order shall prevent disclosure beyond the

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terms of this Protective Order if the party designating material consents in writing

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to such disclosure, or if a court orders such disclosure. A party requested to

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disclose material designated under this Protective Order to a non-party pursuant to

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a validly served subpoena, civil investigative demand, discovery procedure

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permitted under the Federal Rules of Civil Procedure, or other formal discovery
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[Proposed] Stipulated Protective Order

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request shall assert an initial objection to its production to the extent permitted by

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applicable law and notify the requesting non-party of the existence of this

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Protective Order and that the material requested by the non-party has been

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designated under this Protective Order, and shall further give notice of such

5

request, by facsimile and next business day delivery, upon the party that designated

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the material within five (5) court days of receiving a formal discovery request as

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described above, or at least three (3) court days prior to the date on which such

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confidential material is to be produced to the non-party, whichever is earlier.
16)

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If a party inadvertently fails to designate material and/or information,

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it shall not be deemed a waiver in whole or in part of a party’s claim of

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confidentiality, either as to the specific information disclosed or as to any other

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information relating thereto or on the same or related subject matter. As soon as

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the receiving party is notified in writing of the inadvertent production, the

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information must be treated as if it had been timely designated under this

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Protective Order, and the receiving party must endeavor in good faith to obtain all

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copies of the document it distributed or disclosed to persons not authorized to

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access such information by Paragraphs 5 or 6 herein, as well as any copies made

18 by such persons.

17)

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Nothing contained in this Protective Order shall: (i) constitute an

20 admission or waiver of any claim or defense by any party; (ii) affect the right of
21 any party to make any objection, claim any privilege, or otherwise contest any
22 request for production of documents, electronically stored information,
23 interrogatory, request for admission, subpoena, or question at a deposition or to
24 seek further relief or protective order from the Court as permitted by the Federal
25 Rules of Civil Procedure; (iii) constitute a waiver by any party of its right to object
26 to or otherwise contest any confidentiality designation by any party or non-party
27 consistent with the terms of this Protective Order and the Federal Rules of Civil
28 Procedure; (iv) affect the right of any party to object to the authenticity or
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[Proposed] Stipulated Protective Order

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admissibility of any document, testimony, or other evidence subject to this

2

Protective Order; or (v) prevent the parties to this Protective Order from agreeing

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in writing or on the record during a deposition or hearing in this action to alter or

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waive the provisions or protections provided for herein with respect to any

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particular information or material with written or on the record consent of the party

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disclosing such information.
18)

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This Protective Order shall not be construed to apply to any

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information that: (i) is available to the public other than through a breach of this

9

Protective Order or other duty of confidentiality; (ii) a receiving party can

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demonstrate was already known to the receiving party at the time of disclosure and

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was not subject to conditions of confidentiality; or (iii) a receiving party can

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demonstrate was developed by that party independently of any disclosure by a

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designating party or non-party.
19)

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This Protective Order shall not apply to the treatment to be given

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during proceedings in court at any hearing or trial in this litigation to Discovery

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Materials designated as Confidential or Highly Confidential. The parties, any

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party in interest, and/or the witnesses, may move the Court to seal any court

18

proceeding for reasons consistent with this Protective Order, and any such sealing

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or confidential treatment at hearing or trial shall be subject to subsequent Order of

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this Court.
20)

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Within sixty (60) calendar days after the final termination of litigation

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between the parties (including any appeals or petitions for rehearing or review), all

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material designated under this Protective Order and all copies thereof (including

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summaries and excerpts) shall be either returned to the party that produced it or

25

destroyed and a certification of destruction supplied to the producing party;

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provided, however, that for each party, counsel who is entitled access to such

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designated material under Paragraphs 5 or 6 may retain complete and unredacted

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copies of its work product that contains designated material as well as pleadings
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[Proposed] Stipulated Protective Order

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and papers filed with the Court or served on the other party. Reference to

2

designated materials (including such materials in work product or pleadings) shall

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be made only in the event of further proceedings or litigation between the parties, a

4

dispute over such counsel’s performance, a dispute over the use or dissemination

5

of material designated under this Protective Order, or, subject to the provisions of

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Paragraph 15 of this Protective Order, as required by law. Such retained copies of

7 pleadings and papers shall be maintained in a file accessible only by properly
8 authorized counsel under the provisions of, and bound by, this Protective Order.
9 This Protective Order shall survive the final termination of this litigation with
10 respect to any such retained confidential material. The Court is specifically
11 exempted from any return or destruction requirements contemplated by this
12 provision.

21)

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Inadvertent production of any document produced in response to

14 discovery requests in this action by any party or non-party, that a party or non15 party later claims should have been withheld on grounds of a privilege, including
16 the attorney-client privilege or attorney work product doctrine (collectively
17 referred to hereinafter as an “Inadvertently Produced Privileged Document”) will
18 not be deemed to waive any privilege or work product protection. A party or non19 party may request the return of any document that it inadvertently produced by
20 identifying the Inadvertently Produced Privileged Document and stating the basis
21 for withholding such document from production. If a party or non-party requests
22 the return, pursuant to this paragraph, of such an Inadvertently Produced Privileged
23 Document then in the custody of one or more parties, the possessing parties shall
24 within fifteen (15) court days destroy or return to the requesting party or non-party
25 the Inadvertently Produced Privileged Document and all copies thereof and shall
26 make reasonable efforts to expunge from any other document or material
27 information solely derived from the Inadvertently Produced Privileged Document.
28 A party may move the Court for an order compelling production of the document,
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[Proposed] Stipulated Protective Order

1

but said party may not assert as a basis for the entering of such an order the fact or

2

circumstances of the inadvertent production. Nothing in this Protective Order shall

3

preclude a party from arguing that the production of the allegedly Inadvertently

4

Produced Privileged Document was not inadvertent or that conduct other than the

5

alleged inadvertent production in this litigation constitutes a waiver.
22)

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Unless the parties otherwise agree, any dispute concerning the

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application of this Protective Order shall be heard pursuant to the rules of the

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Court. The provisions of this Order may be modified at any time by stipulation of

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all parties and with the approval of the Court. A Party may apply to the Court for

10

modification of this Order pursuant to a regularly-noticed motion.

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IT IS SO ORDERED.

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Dated: July 10, 2013

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____________________________________
The Hon. Carla M. Woehrle
United States Magistrate Judge

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[Proposed] Stipulated Protective Order

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IT IS SO STIPULATED.
Respectfully submitted,

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DATED: July 10, 2013

JENNER & BLOCK LLP

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By: /s/Andrew J. Thomas
Andrew J. Thomas

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.

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Attorneys for Plaintiffs
Warner Bros. Entertainment Inc., New Line Cinema
LLC, New Line Productions, Inc., Metro-GoldwynMayer Studios Inc., and The Saul Zaentz Company

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DATED: July 10, 2013

LAW OFFICES OF SCOTT A. MEEHAN

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By: /s/Scott A. Meehan
Scott A. Meehan

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.

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Attorneys for Defendant
The Global Asylum, Inc.

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[Proposed] Stipulated Protective Order

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EXHIBIT A

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CERTIFICATION
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I, _________________________________, certify that I have read the Stipulated
Protective Order (the “Order”) entered in Warner Bros. Entertainment Inc. et al. v.
The Global Asylum, Inc., No. 2:12-cv-09547-PSG-CW, U.S. District Court for the
Central District of California, on _________________, 2013, and that I understand
the terms, conditions, and restrictions it imposes on any person given access to
Discovery Materials (as that term is defined in the Order). I recognize that I am
bound by the terms of that Order, and I agree to comply with those terms. I will
not disclose Discovery Materials to anyone other than persons specifically
authorized by the Order and agree to return all such materials that come into my
possession to counsel from whom I received such materials.

11

I consent to be subject to the personal jurisdiction of the U.S. District Court for the
12 Central District of California with respect to any proceedings relative to the
enforcement of the Order, including any proceeding related to contempt of Court.
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I declare under penalty of perjury that the foregoing is true and correct.

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Executed on _______________ ___, 20___, at _______________________.

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______________________________________
(Signature)

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______________________________________
(Print Name)

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______________________________________
(Address)

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______________________________________
(Phone)

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25

______________________________________
(Employer/Business)

26
27

________________________________________
(Job Title/Description)

28

15
[Proposed] Stipulated Protective Order