James Scott Lowe vs. International Alliance of Theatrical Stage Employees Local 33 et al.

Filing 55

STIPULATED PROTECTIVE ORDER by Magistrate Judge Jean P. Rosenbluth re Stipulation for Protective Order 54 . (See Order for details) [Note Changes Made By The Court] (bem)

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NOTE: CHANGES
Brandon S. Reif (SBN 214706)
Gabriel Z. Reynoso (SBN 234027)
Richard P. Tricker (SBN 101460) 
WINGET SPADAFORA & SCHWARTZBERG LLP
1900 Avenue of the Stars, Suite 450
Los Angeles, CA 90067
Telephone: [phone]
Facsimile: 310.836.4801

M ADE BY THE COURT

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Attorneys for Defendant
ZENITH AMERICAN SOLUTIONS, INC.

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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JAMES SCOTT LOWE, et al.

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Plaintiffs,
vs.
INTERNATIONAL ALLIANCE
OF THEATRICAL STAGE
EMPLOYEES LOCAL 33, et al.,
Defendants.

Case No. 2:15-CV-04650-RGK
(JPRx)
Assigned for all purposes to Honorable
R. Gary Klausner
STIPULATED PROTECTIVE
ORDER

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STIPULATED PROTECTIVE ORDER

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WHERAS, this action is likely to involve production of confidential,

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proprietary and private information, including but not limited to financial

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information, proprietary contracts and business information, and other

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commercial information, for which special protection from public disclosure

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is warranted;

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WHEREAS, the parties, without waiving the privacy, confidentiality,

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sensitivity or proprietary nature of such information, wish to have access to

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such material for the sole purpose of prosecuting, defending and attempting

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to resolve this action;

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WHERAS, such confidential and proprietary materials and

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information consist of, among other things, confidential business or

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financial information, information regarding confidential business practices,

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or other confidential commercial information (including information

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implicating privacy rights of third parties), information otherwise generally

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unavailable to the public, or which may be privileged or otherwise protected

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from disclosure under state or federal statutes, court rules, case decisions, or

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common law, the disclosure of which could result in irreparable harm to the

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parties;

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WHEREAS, the parties wish to expedite the flow of information, to

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facilitate the prompt resolution of disputes over confidentiality of discovery

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materials, to adequately protect information the parties are entitled to keep

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confidential, to ensure that the parties are permitted reasonable necessary

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uses of such material in preparation for and in conduct of trial, to address

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their handling at the end of the litigation, and serve the ends of justice;

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WHEREAS, the parties hereby acknowledge that the proposed

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Stipulated Protective Order does not confer blanket protections on all

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disclosures or responses to discovery and that the protection it affords from

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-1STIPULATED PROTECTIVE ORDER

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public disclosure and use extends only to the limited information or items

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that are entitled to confidential treatment under the applicable legal

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principles; and

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WHEREAS, the parties acknowledge that the proposed Stipulated

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Protective Order does not entitle them to file confidential information under

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seal; rather, Civil Local Rule 79-5 sets forth the procedures that must be

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followed and the standards that will be applied when a Party seeks

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permission from the court to file material under seal.

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NOW, THEREFORE, the parties hereby stipulate as follows:

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1.

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1.1. Action: Shall refer to and mean the above-captioned action,

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DEFINITIONS

including any subsequent counterclaims or cross-claims.
1.2. Challenging Party: Shall refer to and mean a Party or Non-Party

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that challenges the designation of information or items under this

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Order.

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1.3. “CONFIDENTIAL” Information or Items: Shall refer to and

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mean information (regardless of how it is generated, stored or

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maintained) or tangible things that qualify for protection under

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Federal Rule of Civil Procedure 26(c).

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1.4. Counsel: Shall refer to and mean Outside Counsel of Record
and House Counsel (as well as their support staff).

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1.5. Designating Party: Shall refer to and mean a Party or Non-Party

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that designates information or items that it produces in disclosures

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or in responses to discovery as “CONFIDENTIAL.”

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1.6. Disclosure or Discovery Material: Shall refer to and mean all

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items or information, regardless of the medium or manner in which

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it is generated, stored, or maintained (including, among other

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things, testimony, transcripts, documents, electronic data, and

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tangible things), that are produced, generated or uncovered during

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depositions, in responses to discovery requests propounded in this

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matter, or any other proceedings in this Action.

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1.7. Expert: Shall refer to and mean a person with specialized

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knowledge or expertise in a matter pertinent to the Action who has

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been retained by a Party or its counsel to serve as an expert

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witness or as a consultant in this Action.

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1.8. House Counsel: Shall refer to and mean attorneys who are

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employees or a Party to this Action; House Counsel shall not

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include Outside Counsel of Record or any other outside counsel.

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1.9. Non-Party: Shall refer to and mean any natural person,

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partnership, corporation, association, or other legal entity not

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named as a Party to this Action.

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1.10. Outside Counsel of Record: Shall refer to and mean attorneys

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who are not employees of a Party to this Action but are retained to

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represent or advise a Party to this Action and have appeared in this

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Action on behalf of that Party or are affiliated with or cooperating

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with a law firm which has appeared on behalf of that Party, and

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includes support staff.

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1.11. Party: Shall refer to and mean any Party to this Action,

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including all of its officers, directors, employees, consultants,

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retained experts, House Counsel (and their support staffs) and

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Outside Counsel of Record (and their support staffs).

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1.12. Producing Party: Shall refer to and mean a Party or Non-Party

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that produces Disclosure or Discovery Material in this Action.

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1.13. Professional Vendors: Shall refer to and mean persons or

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

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photocopying, videotaping, translating, preparing exhibits or

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demonstrations, and organizing, storing or retrieving data in any

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form or medium) and their employees and subcontractors.

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1.14. Protected Material: Shall refer to and mean any Disclosure or

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Discovery Material that is designated as “CONFIDENTIAL.”

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1.15. Receiving Party: Shall refer to and mean a Party that receives
Disclosure or Discovery Material from a Producing Party.

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2.

SCOPE

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The protections conferred by this Stipulated Protective Order cover

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not only Protected Material (as defined above), but also (1) any information

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copied or extracted from Protected Material; (2) all copies, excerpts,

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summaries, or compilations of Protected Material; and (3) any testimony,

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conversations or presentations by the Parties or their Counsel that might

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reveal Protected Material. Any use of Protected Material at trial shall be

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governed by the orders of the trial judge. This Order does not govern the

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use of Protected Material at trial.

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3.

DURATION

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Even after final disposition of this litigation, the confidentiality

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obligations imposed by this Order shall remain in effect until a Designating

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Party agrees otherwise in writing or a court order otherwise directs. Final

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disposition shall be deemed to be the later of (1) dismissal of all claims and

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defenses in this Action, with or without prejudice; and (2) final judgment

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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

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any motions or applications for extension of time pursuant to applicable

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law.

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4.

DESIGNATING PROTECTED MATERIAL

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4.1. Exercise of Restraint and Care in Designating Material for

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Protection. Each Party or Non-Party that designates information

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

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such designation to specific material that qualifies under the

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appropriate standards. The Designating Party must designate for

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

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or written communications that qualify so that other portions of

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the material, documents, items, or communications for which

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protection is not warranted are not swept unjustifiably within the

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ambit of this Order.

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4.2. Mass, indiscriminate, or routinized designations are prohibited.

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Designations that are shown to be clearly unjustified or that have

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been made for an improper purpose (e.g., to unnecessarily

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encumber the case development process or to impose unnecessary

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expenses and burdens on other parties) may expose the

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Designating Party to sanctions. If it comes to a Designating

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Party’s attention that information or items that it designated for

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protection do not qualify for protection, that Designating Party

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must promptly notify all other Parties that it is withdrawing the

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inapplicable designation.

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4.3. Manner and Timing of Designations. Except as otherwise

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provided in this Order (e.g., see second paragraph of section 4.3(a)

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below), or as otherwise stipulated or ordered , Disclosure or

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Discovery Material that qualifies for protection under this Order

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must be clearly so designated before the material is disclosed or

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produced. Designation in conformity with this Order requires:

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(a)

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

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electronic documents, but excluding transcripts or depositions or

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other pretrial or trial proceedings), that the Producing Party

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affix at a minimum, the legend “CONFIDENTIAL” (hereinafter

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“CONFIDENTIAL legend”), to each page that contains

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protected material. If only a portion or portions of the material

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on a page qualifies for protection, the Producing Party also must

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clearly identify the protected portion(s) (e.g., by making

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appropriate markings in the margins). A Party or Non-Party that

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makes original documents available for inspection need not

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designate them for protection until after the inspecting Party has

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indicated which documents it would like copied and produced.

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During the inspection and before the designation, all of the

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material made available for inspection shall be deemed

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“CONFIDENTIAL.” After the inspecting Party has identified

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the documents it wants copied and produced, the Producing

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Party must determine which documents, or portions thereof,

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qualify for protection under this Order. Then, before producing

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the specified documents, the Producing Party must affix the

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CONFIDENTIAL legend to each page that contains Protected

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

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qualifies for protection, the Producing Party also must clearly

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identify the protected portion(s) (e.g., by making appropriate

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markings in the margins).

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(b)

for testimony given in deposition, that the Designating

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Party identify and designate Protected Material as such on the

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record and before the close of the deposition or promptly

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afterwards.

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(c)

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documentary and for any other tangible items, that the

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Producing Party affix in a prominent place on the exterior of the

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container or containers in which the information is stored the

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CONFIDENTIAL legend. If only a portion or portions of the

for information produced in some form other than

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information warrants protection, the Producing Party, to the

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extent practicable, shall identify the protected portion(s).

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4.4. Inadvertent Failures to Designate. If timely corrected, an

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inadvertent failure to designate qualified information or items does

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not, standing alone, waive the Designating Party’s right to secure

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protection under this Order for such material. Upon timely

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correction of a designation, the Receiving Party must make

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reasonable efforts to ensure that the material is treated in

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accordance with the provisions of this Order.

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5.

CHALLENGING CONFIDENTIALITY DESIGNATIONS

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5.1. Timing of Challenges. Any Party or Non-Party may challenge a

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designation of confidentiality at any time that is consistent with the Court’s

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Scheduling Order.

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5.2. Meet and Confer. The Challenging Party shall initiate the

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dispute resolution process under Local Rule 37.1 et seq.

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5.3. The Burden of Persuasion in Any Such Challenge Proceeding

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Shall Be on the Designating Party. Frivolous challenges, and

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those made for an improper purpose (e.g., to harass or impose

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unnecessary expenses and burdens on a Designating Party) may

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expose the Challenging Party to sanctions. Unless the Designating

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Party has waived or withdrawn the confidentiality designation, all

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parties shall continue to afford the material in question the level of

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protection to which it is entitled under the Designating Party’s

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designation until the Court rules on the challenge.

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6.

ACCESS AND USE OF PROTECTED MATERIAL

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6.1. Basic Principles. A Receiving Party may use Protected Material

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that is disclosed or produced by another Party or by a Non-Party in

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connection with this Action only for purposes of prosecuting,

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defending, or attempting to settle this Action. Such Protected

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Material may be disclosed only to the categories of persons and

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under the conditions described in this Order. When the Action has

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been terminated, a Receiving Party must comply with the

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provisions of section 12 below (FINAL DISPOSITION).

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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

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is limited to the persons authorized under this Order.

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6.2. Disclosure of “CONFIDENTIAL” Information or Items. Unless

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otherwise ordered by the court or permitted in writing by the

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Designating Party, a Receiving Party may disclose any information

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or item designated “CONFIDENTIAL” only to:

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(a) the Receiving Party’s Outside Counsel of Record in

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this Action, as well as employees of said Outside Counsel of

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Record to whom it is reasonably necessary to disclose the

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information for this Action;

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(b) the officers, directors, and employees (including House

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Counsel) of the Receiving Party to whom disclosure is deemed

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reasonably necessary for prosecution and defense of this Action;

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(c) Experts (as defined in this Order) of the Receiving

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Party to whom disclosure is reasonably necessary for this Action

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and who have signed the “Acknowledgment and Agreement to

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Be Bound” (Exhibit A);

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(d) the court and its personnel, in camera or under seal;

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(e) court reporters and their staff;

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(f) professional jury or trial consultants, mock jurors, and

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Professional Vendors to whom disclosure is reasonably

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necessary for this Action and who have signed the

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“Acknowledgment and Agreement to Be Bound” (Exhibit A);

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(g) the author or recipient of a document containing the

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information or a custodian or other person who otherwise

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possessed or knew the information;

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(h) during their depositions, witnesses, and attorneys for

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witnesses, in the Action to whom disclosure is reasonably

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necessary provided: (1) the deposing Party requests that the

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witness sign the form attached as Exhibit A hereto; and (2) they

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will not be permitted to keep any confidential information

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unless they sign the “Acknowledgement and Agreement to Be

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Bound” (Exhibit A), unless otherwise agreed by the Designating

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Party or ordered by the court. Pages of transcribed deposition

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testimony or exhibits to depositions that reveal Protected

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Material may be separately bound by the court reporter and may

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not be disclosed to anyone except as permitted under this

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Stipulated Protected Order; and
(i) any mediator or settlement officer, and their supporting

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personnel, mutually agreed upon by any of the Parties engaged

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in settlement discussions.

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7.

PROTECTED MATERIAL SUBPOENAED OR ORDERED
PRODUCED IN OTHER LITIGATION

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

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this Action as “CONFIDENTIAL,” that Party must:

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(a)

promptly notify in writing the Designating Party. Such

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notification shall include a copy of the subpoena or court order;

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(b)

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

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of the material covered by the subpoena or order is subject to

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this Stipulated Protective Order. Such notification shall include

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a copy of this Stipulated Protective Order; and

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(c)

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to be pursued by the Designating Party whose Protected Material

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may be affected. If the Designating Party timely seeks a

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protective order, the Party served with the subpoena or court

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order shall not produce any information designated in this action

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as “CONFIDENTIAL” before a determination by the court from

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which the subpoena or order issued, unless the Party has

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obtained the Designating Party’s permission or the Court so

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orders. The Designating Party shall bear the burden and

promptly notify in writing the party who caused the

cooperate with respect to all reasonable procedures sought

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expense of seeking protection in that court of its confidential

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material and nothing in these provisions should be construed as

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authorizing or encouraging a Receiving Party in this Action to

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disobey a lawful directive from another court.

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8.

A NON-PARTY‘S PROTECTED MATERIAL SOUGHT TO BE

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PRODUCED IN THIS LITIGATION

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(a)

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applicable to information produced by a Non-Party in this

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Action and designated as “CONFIDENTIAL.” Such

The terms of this Stipulated Protective Order are

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information produced by Non-Parties in connection with this

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litigation is protected by the remedies and relief provided by this

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Stipulated Protective Order. Nothing in these provisions should

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be construed as prohibiting a Non-Party from seeking additional

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protections.

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(b) In the event that a Party is required, by a valid discovery

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request, to produce a Non-Party’s confidential information in its

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possession, and the Party is subject to an agreement with the

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Non-Party not to produce the Non-Party’s confidential

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information, then the Party shall:

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(1) promptly notify in writing the Requesting Party and the Non-Party

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that some or all of the information requested is subject to a confidentiality

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agreement with a Non-Party;

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(2) promptly provide the Non-Party with a copy of the Stipulated

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Protective Order in this Action, the relevant discovery request(s), and a

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reasonably specific description of the information requested; and

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(3)

make the information requested available for inspection by the

Non-Party, if requested.

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(c) If the Non-Party fails to seek a protective order from this

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Court within 14 days of receiving the notice and accompanying

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information, the Receiving Party may produce the Non-Party’s

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confidential information responsive to the discovery request. If

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the Non-Party timely seeks a protective order, the Receiving

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Party shall not produce any information in its possession or

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control that is subject to the confidentiality agreement with the

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Non-Party before a determination by the court. Absent a court

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order to the contrary, the Non-Party shall bear the burden and

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expense of seeking protection in this Court of its Protected

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Material.

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9.

MATERIAL

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UNAUTHORIZED DISCLOSURE OF PROTECTED

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

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disclosed Protected Material to any person or in any circumstance not

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authorized under this Stipulated Protective Order, the Receiving Party must

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immediately (a) notify in writing the Designating Party of the unauthorized

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disclosures, (b) use its best efforts to retrieve all unauthorized copies of the

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Protected Material, (c) inform the person or persons to whom unauthorized

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disclosures were made of all the terms of the this Order, and, if appropriate,

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(d) request such person or persons to execute the “Acknowledgment and

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Agreement to Be Bound” that is attached hereto as Exhibit A.

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10.

INADVERTENT PRODUCTION OF PRIVILEDGED OR
OTHERWISE PROTECTED MATERIAL

When a Producing Party gives notice to Receiving Parties that certain

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inadvertently produced material is subject to a claim of privilege or other

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protection, the obligations of the Receiving Parties are those set forth in

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Federal Rule of Civil Procedure 26(b)(5)(B). This provision is not intended

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to modify whatever procedure may be established in an e-discovery order

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that provides for production without prior privilege review. Pursuant to

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Federal Rule of Evidence 502(d) and (e), the parties agree that the attorney-

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client privilege or work product protection is not waived by inadvertent

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disclosure connected with the Action, and that the provisions of Federal

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Rule of Evidence 502 apply in this Action and in all proceedings in any

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other federal or state court.

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11.

MISCELLANEOUS

11.1 Right to Further Relief. Nothing in this Stipulated Protective

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Order abridges the right of any person to seek its modification by the Court

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in the future.

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11.2 Right to Assert Other Objections. By stipulating to the entry of

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this Stipulated Protective Order, no Party waives any right it otherwise

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would have to object to disclosing or producing any information or item on

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any ground not addressed in this Stipulated Protective Order. Similarly, no

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Party waives any right to object on any ground to use in evidence of any of

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the material covered by this Stipulated Protective Order.

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11.3 The use, disclosure, or production by the Parties of Protected

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Material pursuant to this Stipulated Protective Order shall not be deemed to

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concede the relevancy, competency or admissibility of any document or of

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any matter set forth therein, and is not intended to be a waiver of any

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privilege.

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11.4 Filing Protected Material. A Party that seeks to file under seal

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any Protected Material must comply with Civil Local Rule 79-5. Protected

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Material may only be filed under seal pursuant to a court order authorizing

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the sealing of the specific Protected Material at issue. If a Party’s request to

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file Protected Material under seal is denied by the court, then the Receiving

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Party may file the information in the public record unless otherwise

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instructed by the court. If any Party hereto files with the Court any

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Protected Material or any document that contains, incorporates, reproduces,

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excerpts or discloses the contents of Protected Material, or the substance

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thereof, its confidential nature shall be disclosed on the first page of such

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document and it shall be filed with the Court under seal for in camera

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review.

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11.5 The protections conferred by this Stipulated Protective Order

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cover not only Protected Material, but also any information copied or

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extracted therefrom, as well as copies, excerpts, summaries, or compilations

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thereof, plus testimony, conversations, or presentations by parties or counsel

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to or in Court or in other settings that might reveal Protected Material and

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the information contained therein.

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11.6 The protections of this Stipulated Protective Order shall apply
retroactively to Protected Material produced by any Party prior to its entry.
11.7 Without written permission from the Designating Party or a

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court order secured after appropriate notice to all interested persons, a Party

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may not file in the public record in this Action any Protected Material.

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11.8 By stipulating to the entry of this Stipulated Protective Order,

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no Party waives any right it otherwise would have to object to disclosing or

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

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

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evidentiary objections to the materials covered by this Stipulated Protective

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Order.

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12.

FINAL DISPOSITION

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After the final disposition of this Action, as defined in paragraph 4,

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within 60 days of a written request by the Designating Party, each Receiving

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Party must return all Protected Material to the Producing Party or destroy

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such material. As used in this subdivision, “all Protected Material” includes

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all copies, abstracts, compilations, summaries, and any other format

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reproducing or capturing any of the Protected Material. Whether the

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Protected Material is returned or destroyed, the Receiving Party must submit

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

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entity, to the Designating Party) by the 60-day deadline that (1) identifies

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(by category, where appropriate), all the Protected Material that was

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returned or destroyed and (2) affirms that the Receiving Party has not

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retained any copies, abstracts, compilations, summaries or any other format

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reproducing or capturing any of the Protected Material. Notwithstanding

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

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pleadings, motion papers, trial, deposition and hearing transcripts, legal

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memoranda, correspondence, deposition and trial exhibits, expert reports,

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attorney work product, and consultant and expert work product, even if such

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materials contain Protected Material. Any such archival copies that contain

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or constitute Protected Material remain subject to this Stipulated Protective

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Order as set forth in Section 3.
13.

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Any violation of this Order may be punished by any and all

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appropriate measures, including, without limitation, contempt

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proceedings and/or monetary sanctions.

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///

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///

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IT IS SO STIPULATED, THROUGH COUNSEL OF RECCORD

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BUTTERFIELD SCHECHTER LLP

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Dated: January 8, 2016

By:

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/s/
Marc S. Schechter
Corey F. Schechter
Paul D. Woodard
Attorneys for Plaintiffs

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WINGET SPADAFORA &
SCHWARTZBERG LLP

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Dated: January 8, 2016

By:

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/s/
Brandon S. Reif
Gabriel Z. Reynoso
Richard P. Tricker
Attorneys for Defendant
Zenith American Solutions, Inc.

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TRUCKER HUSS, APC

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Dated: January 8, 2016

By:

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I.A.T.S.E. Local 33 Section 401(k) Plan
Administrative Committee; Board Of
Trustees Of The I.A.T.S.E. Local 33 Section
401(k) Plan; Jay V. Barnett; Steven E.
Berkowitz; David K. Green; Faith Raiguel;
Seth A. Stevelman; Lee Zeidman; Darrell
Aranda; Jane E. Leslie; David Dawson;
Gregory Santana; Rosemary C. Phillips; and
William Ford, Sr.

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/s/
R. Bradford Huss

IT IS SO ORDERED.

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Dated: January 8, 2016

By:
Hon. Jean P. Rosenbluth
U.S. Magistrate Judge

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EXHIBIT A

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ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

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I, ______________________________________ [print or type full name], of

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_____________________________________ [print or type full address], declare

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under penalty of perjury that I have read in its entirety and understand the

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Stipulated Protective Order that was issued by the United States District Court for

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the Central District of California and entered in the case of Lowe, et al. v.

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International Alliance of Theatrical Stage Employees Local 33, et al., Case No.

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2:15-CV-04650-RGK (JPRx). I agree to comply with and to be bound by all the

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terms of the Stipulated Protective Order and I understand and acknowledge that

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failure to so comply could expose me to sanctions and punishment in the nature of

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contempt. I solemnly promise that I will not disclose in any manner any

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information or item that is subject to the Stipulated Protective Order to any person

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or entity except in strict compliance with the provisions of the Stipulated

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Protective Order.

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I further agree to submit to the jurisdiction of the United States District Court for

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the Central District of California for the purpose of enforcing the terms of the

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Stipulated Protective Order, even if such enforcement proceedings occur after

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termination of the Action.

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Date: ___________________________________________

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City and State where sworn and signed:

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__________________________________________

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Printed Name: _____________________________________________

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Signature: ________________________________________________

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-1STIPULATED PROTECTIVE ORDER