Gonzales & Gonzales Bonds and Insurance Agency Inc v. Action Immigration Bonds and Insurance Services Inc et al

Filing 38

PROTECTIVE ORDER by Magistrate Judge Michael R. Wilner. The parties Stipulation for Protective Order is approved and in effect as modified by the Court. NOTE: CHANGES HAVE BEEN MADE TO THIS DOCUMENT. (See Order for details) re Stipulation for Protective Order 37 (vm)

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RICK D. NAVARRETTE (CA Bar No. 122653)
[e-mail]
T. MATTHEW HANSEN (CA Bar No. 231057)
[e-mail]
ALVARADOSMITH
NOTE: CHANGES HAVE BEEN
A Professional Corporation
MADE TO THIS DOCUMENT
633 W. Fifth Street, Suite 1100
Los Angeles, CA 90071
Tel: [phone]
¶ 7.c.
Fax: [phone]

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JOSEPH R. DAWSON (Pro Hac Vice)
[e-mail]
LAW OFFICES OF JOSEPH R. DAWSON, P.A.
107 Southwest Sixth Street
Fort Lauderdale, FL 33301
Telephone: [phone]
Facsimile: [phone]

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A LVARADO S MITH
A P ROFESSI ONAL C ORPORATI ON
L OS A NGELES

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Attorneys for Defendants
Action Immigration Bonds and Insurance
Services, Inc., Action International
Insurance, Inc. and Bankers Insurance
Company

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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JUDGE:

Plaintiff,

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CASE NO.: 2:13-cv-06997-PA-MRW

GONZALES & GONZALES BONDS
AND INSURANCE AGENCY, INC., a
California Corporation,

Hon. Percy Anderson

DISCOVERY MATTER

v.

STIPULATION FOR PROTECTIVE
ORDER

ACTION IMMIGRATION BONDS AND
INSURANCE SERVICES, INC., a
Florida Corporation, ACTION
INTERNATIONAL INSURANCE, INC.,
a Florida Corporation, and BANKERS
INSURANCE COMPANY, a Florida
Corporation,
Defendant.

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I.

PURPOSE AND LIMITATIONS
WHEREAS disclosure and discovery activity in this action is likely to involve

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production of confidential, proprietary, or private information for which special

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protection from public disclosure and from use for any purpose other than

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prosecuting, defending, or attempting to settle this litigation (the “Litigation”) may be

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warranted. Accordingly, Defendants Action Immigration Bonds and Insurance

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Services, Inc., Action International Insurance, Inc., and Bankers Insurance Company

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(collectively, “Defendants”), and Plaintiff Gonzales & Gonzales Bonds and Insurance

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Agency, Inc. (“Plaintiff”) (“Plaintiff” and “Defendants” may be referred to as a
“Party” or as the “Parties”), through their respective attorneys of record, agree and

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stipulate to and petition the Court to enter the following Stipulated Protective Order.

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The Parties acknowledge that this Order does not confer blanket protections on all

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disclosures or responses to discovery that is not otherwise discloseable, and that the

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protection it affords from public disclosure and use extends only to the information or

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items that are entitled to confidential treatment under applicable legal principles. The

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Parties further acknowledge that the Federal Rules of Civil Procedure and Local

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Central District Rule 79-5 shall set forth the procedures that must be followed when a

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Party seeks permission from the Court to file material under seal.

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Accordingly, IT IS HEREBY ORDERED that the terms and conditions of this
Order shall govern the handling of discovery materials in the Litigation:
This Protective Order shall govern and be applicable to the handling of

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documents, depositions, deposition exhibits, interrogatory responses, responses to

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request for admissions, responses to request for production of documents, and all

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other discovery or materials contemplated under the Federal Rules of Civil Procedure

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which are designated as containing confidential Material, as that term is defined

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herein, and is furnished to any Party by any Party in connection with this Litigation.

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This Protective Order has been agreed to by the Parties to facilitate discovery and the

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production of relevant evidence in this litigation. Neither the entry of this Protective
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Order, nor the designation of any information or document as confidential Material, as

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that term is defined herein, nor the failure to make such designation, shall constitute

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evidence with respect to any issue in this litigation.

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II.

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DEFINITIONS
1.

The term “Challenging Party” shall mean and include a Party that

challenges the designation of information or items under this Order.
2.

The term “Confidential Information” shall mean and include information

contained or disclosed in any materials, including documents, portions of documents,

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answers to interrogatories, responses to requests for admissions, deposition testimony,

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and depositions, including data, summaries, and compilations derived therefrom that a

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Party believes in good faith to be a trade secret or other confidential research,

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development, or commercial information, as such terms are used in Rule 26(c)(1)(G)

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of the Federal Rules of Civil Procedure and any applicable case law interpreting Rule

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26(c)(1)(G) or the former Rule 26(c)(7).

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3.

The term “Confidential – Attorneys’/Experts’ Eyes Only” shall mean and

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include all information (regardless of how it is generated, stored or maintained) or

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tangible things that the Designating Party asserts in good faith (1) to be a trade secret

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or other confidential research, development, or commercial information, as such terms

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are used in Rule 26(c)(1)(G) of the Federal Rules of Civil Procedure and any

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applicable case law interpreting Rule 26(c)(1)(G) or the former Rule 26(c)(7), and (2)

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may only be disclosed to those listed in Section IV.6.d., below.

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4.

The term “counsel” shall mean outside counsel of record, and other

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attorneys, paralegals, secretaries, and other support staff employed in the law firms

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identified below: AlvaradoSmith, APC, Roxborough, Pomerance, Nye & Adreani,

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LLP, and the Law Offices of Joseph R. Dawson, P.A. The term “counsel” shall not

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include attorneys who are employees of a Party to this action, or are affiliated with a

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law firm which has appeared on behalf of that Party.

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5.

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The term “Designating Party” shall mean and include a Party that

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designates information or items that it produces in disclosures or in response to

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discovery, and has identified as either “Confidential” or “Confidential –

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Attorneys’/Experts’ Eyes Only.”
6.

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The terms “Disclosure or Discovery Material” shall mean and include all

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items or information, regardless of the medium or manner in which it is generated,

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stored, or maintained (including, among other things, testimony, transcripts, and

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tangible things), that are produced or generated in disclosures or response to discovery

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in this matter.

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7.

The term “Expert” shall mean and include a person with specialized

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knowledge or experience in a matter pertinent to the litigation who has been retained

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by a Party or its counsel to serve as an expert witness or as a consultant in this action.
8.

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The term “Producing Party” shall mean and include a Party that produces

Disclosure or Discovery Material in this action.
9.

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The term “Professional Vendors” shall mean and include all persons or

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entities that provide litigation support services (e.g., photocopying, videotaping,

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translating, preparing exhibits or demonstrations, and organizing, storing, or retrieving

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data in any form or medium) and their employees and subcontractors.
10.

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The term “Protected Material” shall mean and include any and all

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Disclosure or Discovery Material that is designated as “Confidential” or “Confidential

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- Attorneys’/Experts’ Eyes Only.”
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The term “Receiving Party” shall mean and include a Party that receives

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Disclosure or Discovery Material from a Producing Party.

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III.

SCOPE

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The protections conferred by this Stipulation and Order do not cover the

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following information: (a) any information that is in the public domain at the time of

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disclosure to a Receiving Party or becomes part of the public domain after its

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disclosure to a Receiving Party as a result of publication not involving a violation of
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this Order, including becoming part of the public record through trial or otherwise;

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and (b) any information known to the Receiving Party prior to the disclosure or

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obtained by the Receiving Party after the disclosure from a source who obtained the

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information lawfully and under no obligation of confidentiality to the Designating

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Party.

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IV.

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GENERAL RULES
Designating Material for Protection. A Party that designates information or

items for protection under this Order must take care to limit any such designation to

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specific material that qualifies under the appropriate standards. The Designating Party

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shall 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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included within the ambit of this Order. If it comes to the Designating Party’s

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attention that information or items that are designated for protection do not qualify for

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protection, that Designating Party must promptly notify the Receiving Party that it is

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withdrawing the mistaken designation.

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1.

Manner and Timing of Designations. Except as otherwise provided in

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this Order, or as otherwise stipulated or ordered, Disclosure or Discovery Material that

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qualifies for protection under this Order must be clearly so designated before the

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material is disclosed or produced.

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2.

Designation in conformity with this Order requires:
a.

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

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documents, but excluding transcripts of depositions or other pretrial proceedings), that

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the Producing Party affix the legend “Confidential” or “Confidential –

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Attorneys’/Experts’ Eyes Only” to each page that contains protected material. If only

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a portion or portions of the material on a page qualifies for protection, the Producing

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

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markings in the margins).
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b.

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for testimony given in deposition or in other pretrial proceedings,

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that the Designating Party identify on the record, before the close of the deposition,

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hearing, or other proceeding, all protected testimony. When it is impractical to

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identify 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 Party

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that sponsors, offers, or gives the testimony may invoke on the record (before the

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deposition or proceeding is concluded) a right to have up to 20 days from receipt of

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the transcript to identify the specific portions of the testimony as to which protection

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is sought. Only those portions of the testimony that are appropriately designated for
protection within the 20 days from receipt of the transcript shall be covered by the

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provisions of this Stipulated Protective Order. Pages of transcribed deposition

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testimony or exhibits to depositions that reveal Protected Material must be separately

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bound by the court reporter and may not be disclosed to anyone except as permitted

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under this Stipulated Protective Order. Additionally, the Designating Party shall have

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the right to exclude from attendance at said deposition, during such time as the

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Confidential Information is to be disclosed, any person other than the deponent,

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counsel (including their staff and associates), and the court reporter.
c.

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for information produced in some form other than documentary

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

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

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the legend “Confidential” or “Confidential - Attorneys’/Experts’ Eyes Only.” If only

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a portion or portions of the information or item warrant protection, the Producing

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Party, to the extent practicable, shall identify the protected portion or portions.

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3.

All Confidential Information designated as “Confidential” or

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“Confidential - Attorneys’/Experts’ Eyes Only” shall not be disclosed by the receiving

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Party to anyone other than those persons designated herein and shall be handled in the

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manner set forth in this Protective Order and, in any event, shall not be used for any

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purpose other than in connection with this litigation, unless and until such designation

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is removed either by agreement of the Parties, or by order of the Court.
4.

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With respect to material designated “Confidential” or “Confidential -

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Attorneys’/Experts’ Eyes Only,” any person indicated on the document to be its

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originator, author or a recipient of a copy thereof, may be shown the same.
5.

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All information which has been designated as “Confidential -

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Attorneys’/Experts’ Eyes Only” by the Producing or Designating Party, and any and

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all reproductions thereof, shall be retained in the custody of the counsel for the

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Receiving Party, except that independent experts authorized to view such information
under the terms of this Protective Order may retain custody of copies such as are

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necessary for their participation in this litigation.
6.

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ACCESS TO AND USE OF PROTECTED MATERIAL
a.

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Basic Principles. A Receiving Party may use Protected Material

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that is disclosed or produced by another Party in connection with this case only for

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prosecuting, defending, or attempting to settle this litigation. Such Protected Material

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may be disclosed only to the categories of persons and under the conditions described

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in this Order. When the litigation has been terminated, a Receiving Party must

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comply with the provisions of section 20 below (FINAL DISPOSITION).
b.

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Protected Material must be stored and maintained by a Receiving

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

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persons authorized under this Order.
c.

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Disclosure of “Confidential” Information or Items. Unless

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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” only

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to:
i.

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the Receiving Party’s Counsel of Record in this action, as

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

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disclose the information for this litigation;
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ii.

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the officers, directors, and employees of the Receiving Party

to whom disclosure is reasonably necessary for this litigation;

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iii.

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

whom disclosure is reasonably necessary for this litigation;

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iv.

the court and its personnel;

v.

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court reporters and their staff, professional jury or trial

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consultants, mock jurors, and Professional Vendors;

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vi.

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during their depositions, witnesses in the action to whom

disclosure is reasonably necessary; and

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vii.

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the author or recipient of a document containing the

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information or a custodian or other person who otherwise possessed or knew the

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information.

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d.

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Disclosure of “Confidential - Attorneys’/Experts’ Eyes Only”

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Information or Items. Unless otherwise ordered by the court or permitted in writing

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by the Designating Party, Protected Material designated “Confidential -

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Attorneys’/Experts’ Eyes Only” may only be disclosed to:
i.

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the Receiving Party’s Counsel of Record in this action, as

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

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disclose the information for this litigation;

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ii.

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

whom disclosure is reasonably necessary for this litigation;
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iii.

the court and its personnel; and

iv.

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the author or recipient of a document containing the

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information or a custodian or other person who otherwise possessed or knew the

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information.

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7.

a.

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CHALLENGING CONFIDENTIALITY DESIGNATIONS
Timing of Challenges. Any Party may challenge a designation of

confidentiality at any time. A Party does not waive its right to challenge a
confidentiality designation by electing not to mount a challenge immediately after the

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original designation is disclosed.
b.

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Meet and Confer. The Challenging Party shall initiate the dispute

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resolution process by providing written notice of the designations it is challenging and

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describe the basis for its challenge. The Parties shall attempt to resolve each

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challenge in good faith and must begin the process by conferring directly (in voice to

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voice dialogue; other forms of communication are not sufficient) within 7 days of the

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date of service of notice. In conferring, the Challenging Party should explain the basis

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for its belief that the confidentiality designations were not proper and must give the

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Designating Party an opportunity to review the designated material, to reconsider the

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

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for the chosen designation.

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c.

Judicial Intervention. If the Parties cannot resolve a challenge

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without court intervention, the Designating Party shall file and serve a motion that

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complies in full with the joint discovery motion practice under Local Rule 37 (and

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in compliance with Civil Local Rule 79-5, if applicable) within 21 days of the initial

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notice of challenge or any later date mutually agreed to in writing by the Challenging

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Party and Designating Party. Each such motion must be accompanied by a declaration

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affirming that the movant has complied with the meet and confer requirements
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imposed in the preceding paragraph. Failure by the Designating Party to make such a

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motion including the required declaration within the applicable time period, unless

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excused by the Court, shall automatically waive the confidentiality designation for the

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challenged designations. In addition, the Challenging Party may file a motion

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challenging a confidentiality designation at any time if there is good cause for doing

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so, including a challenge to the designation of a deposition transcript or any portions

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thereof. Any motion brought pursuant to this provision must be accompanied by a

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competent declaration affirming that the movant has complied with the meet and

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confer requirements imposed by the preceding paragraph.

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8.

Unless the Designating Party has waived the confidentiality designation

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by failing to file a motion to retain confidentiality as described above, all Parties shall

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

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under the Designating Party’s designation until the court rules on the challenge.

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9.

Nothing herein shall prejudice the right of any Party to object to the

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production of any discovery material on the grounds that the material is protected as

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privileged or as attorney work product.

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10.

Nothing in this Protective Order shall bar counsel from rendering advice

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to their clients with respect to this litigation and, in the course thereof, relying upon

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any information designated as “Confidential - Attorneys’/Experts’ Eyes Only,”

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provided that the specific contents of the information shall not be disclosed.

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11.

This Protective Order shall be without prejudice to the right of any Party

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to oppose production of any information for lack of relevance or any other ground

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other than the mere presence of Confidential Information. The existence of this

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Protective Order shall not be used by any Party as a basis for discovery that is

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otherwise improper under the Federal Rules of Civil Procedure.

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12.

Nothing herein shall be construed to prevent disclosure of Confidential

Information if such disclosure is required by law or by order of the Court.

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13.

The inadvertent failure to designate Confidential Information as

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“Confidential” or “Confidential – Attorneys’/Experts’ Eyes Only” does not constitute

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a waiver of such claim and may be remedied by prompt supplemental written notice

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upon discovery of the inadvertent disclosure, with the effect that such Confidential

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Information will be subject to the protections of this Protective Order. Upon timely

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correction of a designation, the Receiving Party must make reasonable efforts to

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

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14.

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

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litigation that compels disclosure of any information or items designated in this action

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as “Confidential” or “Confidential - Attorneys’/Experts’ Eyes Only,” that Party must:
a.

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promptly notify in writing the Designating Party. Such notification

shall include a copy of the subpoena or court order;
b.

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promptly notify in writing the party who caused the subpoena or

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

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

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copy of this Stipulated Protective Order; and
c.

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cooperate with respect to all reasonable procedures sought to be

pursued by the Designating Party whose Protected Material may be affected.
15.

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

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

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action as “Confidential” or “Confidential - Attorneys’/Experts’ Eyes Only” before a

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determination by the court from which the subpoena or order issued, unless the Party

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has obtained the Designating Party’s permission. The Designating Party shall bear the

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burden and expense of seeking protection in that court of its confidential material –

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and nothing in these provisions should be construed as authorizing or encouraging a

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

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16.

Confidential Information shall not be disclosed to any outside experts or

consultants who are current employees of a direct competitor of any of the Parties, or
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affiliated entities, named in the Litigation. With respect to outside experts or

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consultants who were employed by a direct competitor of any of the Parties named in

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the Litigation within one (1) year from the date of this Protective Order, Confidential

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Material may be shared with those experts or consultants only after counsel for the

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opposing Parties in this Litigation are given at least twenty (20) days prior written

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notice of the identity of the expert or consultant to whom such Confidential

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Information is to be disclosed (including his or her name, address, current job title and

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the names of any direct competitors by which he has been employed), are afforded an

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opportunity to object to the disclosure of the Confidential Information, and a
resolution to any such objection has been reached. Notwithstanding the above

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paragraph 6, Confidential Information may be provided to experts or consultants only

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for the purpose of aiding, assisting, or allowing such expert or consultant to prepare a

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written opinion, to prepare to testify, or to assist counsel for a party in this Litigation.

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17.

Without written permission from the Producing Party or a court order, a

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Party may not file in the public record in this action any Confidential Information.

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The Parties shall comply with Local Rule 79-5 when seeking to file Confidential

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Information under seal. If a Receiving Party’s request to file Protected Material under

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seal pursuant to Civil Local Rule 79-5 is denied by the court, then the Receiving Party

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may file the information in the public record unless otherwise instructed by the court.

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18.

Agreeing to be bound by this Protective Order, agreeing to, producing or

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receiving Confidential Information, or otherwise complying with the terms of this

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Order shall not:
a.

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Prejudice in any way the rights of the Parties to object to the

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production of documents they consider not subject to discovery, or operate as an

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admission by any Party that the restrictions and procedures set forth herein constitute

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adequate protection for any particular information deemed by any Party to be

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Confidential Information;

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b.

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Prejudice in any way the rights of any Party to object to the

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authenticity or admissibility into evidence of any document, testimony or other

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evidence subject to this Order;
c.

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Prejudice in any way the rights of a Party to seek a determination

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by the Court whether any Confidential Information should be subject to the terms of

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this Order;
d.

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protective order relating to any purportedly confidential information; or
e.

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Prejudice in any way the rights of a Party to petition the Court for a

Prevent a Disclosing Party from authorizing disclosure of its own

Confidential Information to any Party
19.

Use of Protected Material at Trial. Any use of Protected Material at trial

shall be governed by a separate agreement or order.
20.

FINAL DISPOSITION
a.

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Final disposition shall be deemed to be the later of (1) dismissal of

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all claims and defenses in this action, with or without prejudice; and (2) final

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judgment herein after the completion and exhaustion of all appeals, rehearings,

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remands, trials, or reviews of this action, including the time limits for filing any

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motions or applications for extension of time pursuant to applicable law.
b.

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Within 60 days after the final disposition each Receiving Party

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must destroy all Protected Material. Notwithstanding this provision, Counsel are

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entitled to retain an archival copy of all pleadings, motion papers, trial, deposition,

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and hearing transcripts, legal memoranda, correspondence, deposition and trial

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exhibits, expert reports, attorney work product, and consultant and expert work

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product, even if such materials contain Protected Material.

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21.

Transmission by email is acceptable for all notification purposes herein.

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22.

The recipient of any Confidential Information that is provided under this

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Protective Order shall maintain such information in a reasonably secure and safe

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manner that ensures that access is limited to the persons authorized under this Order.
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23.

This Protective Order may be modified by agreement of the Parties,

subject to approval by the Court.
24.

The Court may modify the terms and conditions of this Protective Order

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for good cause, or in the interest of justice, or on its own order at any time in these

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proceedings. The Parties prefer that the Court provide them with notice of the Court’s

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intent to modify the Protective Order and the content of those modifications, prior to

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entry of such an order.

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IT IS SO STIPULATED:

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Dated: September 10, 2014

Dated: September 10, 2014

ROXBOROUGH, POMERANCE,
NYE & ADREANI, LLP

ALVARADOSMITH
A Professional Corporation

/s/ Gary A. Nye
GARY A. NYE
DAVID R. GINSBURG
Attorneys for Plaintiff
Gonzales & Gonzales Bonds and
Insurance Agency, Inc.

/s/ Rick D. Navarrette
RICK D. NAVARRETTE
T. MATTHEW HANSEN
Attorneys for Defendants
Action Immigration Bonds and
Insurance Services, Inc., Action
International Insurance, Inc. and
Bankers Insurance Company

A LVARADO S MITH
A P ROFESSI ONAL C ORPORATI ON
L OS A NGELES

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3945160.2 -- L706.1

STIPULATION FOR PROTECTIVE ORDER

[PROPOSED] ORDER

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The parties’ Stipulation for Protective Order is approved and in effect as
modified by the Court.

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IT IS SO ORDERED.

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Dated: September 11, 2014

__________________________
Hon. Michael R. Wilner
United States Magistrate Judge

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A LVARADO S MITH
A P ROFESSI ONAL C ORPORATI ON
L OS A NGELES

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3945160.2 -- L706.1

STIPULATION FOR PROTECTIVE ORDER

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CERTIFICATE OF SERVICE
I hereby certify that that on this 10th day of September, 2014, a true and correct
copy of the foregoing STIPULATION FOR PROTECTIVE ORDER was
electronically filed with the Clerk of the Court using the CM/ECF system which will
send notification of such filing to the following:

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A LVARADO S MITH
A P ROFESSI ONAL C ORPORATI ON
L OS A NGELES

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Rick D. Navarrette
[e-mail]
T. Matthew Hansen
[e-mail]
Alvarado Smith, A Professional Corporation
633 W. Fifth Street, Suite 1100
Los Angeles, CA 90071
Joseph R. Dawson (Pro Hac Vice)
[e-mail]
Law Offices of Joseph R. Dawson, P.A.
107 Southwest Sixth Street
Fort Lauderdale, FL 33301
Attorneys for Defendants
Action Immigration Bonds and Insurance Services, Inc.,
Action International Insurance, Inc.
and Bankers Insurance Company

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s/ Elia Ramirez

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3945160.2 -- L706.1

STIPULATION FOR PROTECTIVE ORDER