Federal Trade Commission v. Bunzai Media Group, Inc. et al

Filing 329

PROTECTIVE ORDER 328 by Magistrate Judge Paul L. Abrams. (es)

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UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION

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FEDERAL TRADE COMMISSION,

Case No. CV 15-4527-GW (PLAx)

Plaintiff,

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v.

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PROTECTIVE ORDER

BUNZAI MEDIA GROUP, INC.,
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Defendants.
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Having considered Plaintiff Federal Trade Commission, Defendants Alon

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Nottea, Roi Reuveni, Doron Nottea, Motti Nottea, Igor Latsanovski, CalEnergy,
Inc., Alan Argaman, Paul Medina, Secured Merchants LLC, and Relief Defendant
Chargeback Armor Inc.’s stipulation for a protective order pursuant to Fed. R.
Civ. P. 26(c), IT IS HEREBY ORDERED:
1.

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“Sensitive Personal Information” means any (a) Social Security

number; (b) sensitive health-related data including medical records; (c) biometric
(PROPOSED) PROTECTIVE ORDER

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identifier; or (d) any one or more of the following when combined with an

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individual’s name, address, or phone number: (i) date of birth, (ii) driver’s license

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identification number, (iv) passport number, (v) an individual’s financial

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institution account number, or (vi) an individual’s credit or debit card number.

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or other state identification number, or a foreign equivalent, (iii) military

2. SENSITIVE PERSONAL INFORMATION MAY ONLY BE DISCLOSED TO:
a.

the Court and court personnel;

b.

the parties’ outside counsel and designated employees only to

the extent necessary to assist in the litigation;
c.

experts and contractors consulted or retained by the parties or

counsel, and their employees, provided that they agree in writing to abide
by this protective order or execute FTC Form X33-Nondisclosure

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Agreement for Contractors;

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Sensitive Personal Information;

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d.

any person who had prior access to the Sensitive Personal

Information or participated in a communication that is the subject of the

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witnesses and their counsel, provided that they agree in writing

to abide by this protective order;
f.

the individual defendants.

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3.

Disclosure of Sensitive Personal Information to any person described

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in Paragraph 2 shall be only for the purposes of the preparation and hearing of this

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proceedings, therefrom, and for no other purpose whatsoever.

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proceeding, or any appeal, or any other matters in connection with these

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Sensitive Personal Information shall be redacted before filing or filed

with a motion to seal the material.
9.

At the conclusion of this case, any consultant or other person retained

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8 to assist counsel in the preparation of this action shall destroy or return all
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9 Sensitive Personal Information. All Sensitive Personal Information held by the
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13 parties shall be destroyed or returned to the designee, except that the FTC shall
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11 retain, return, or destroy Sensitive Personal Information in accordance with Rule
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12 4.12 of the FTC’s Rules of Practice.
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10. This Order continues to govern Sensitive Personal Information after
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14 conclusion of the case absent further order of the Court.
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11. Nothing set forth herein shall change, amend, or modify the terms of
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21 any prior orders of this Court, including orders concerning Sensitive Personal
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17 Information.
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IT IS SO ORDERED.
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25 Dated: February 8, 2016
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________________________
The Honorable Paul L. Abrams
United States Magistrate Judge

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