Gold Value International Textile, Inc. v. Gypsy 05, Inc. et al

Filing 20

PROTECTIVE ORDER by Magistrate Judge Patrick J. Walsh. re Stipulation for Protective Order 19 (sbou)

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Pamela Koslyn (State Bar # 120605)
[e-mail]
LAW OFFICE OF PAMELA KOSLYN
5757 Wilshire Blvd., Penthouse 20
Los Angeles, California 90036
Telephone: [phone]
Fax:
[phone]
Attorneys for Defendants GYPSY 05, Inc.,
THE TJX COMPANIES, INC., EMINENT, INC.
and AMAZON.COM.INC.

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

LAW OFFICE OF PAMELA KOSLYN
5757 WILSHIRE BOULEVARD, PENTHOUSE 20
LOS ANGELES, CALIFORNIA 90036
[phone]

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Case No 2:15-cv-06928 (PJW)

GOLD VALUE INTERNATIONAL
TEXTILE, INC. a California
corporation, individually and doing
business as “FIESTA FABRIC,”

STIPULATED PROTECTIVE ORDER

Plaintiff,

Complaint served: September 17, 2015

v.
GYPSY 05, INC., a California
corporation; THE TJX COMPANIES,
INC. a Delaware corporation,
individually and doing business as
Marshalls; EMINENT, INC.,
individually and doing business as
“Revolve Clothing” and
“www.revolveclothing.com”;
AMAZON.COM.INC., A Delaware
Corporation; and DOES 1-10,
inclusive,
Defendants.

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STIPULATED PROTECTIVE ORDER

2:15-CV-06928 (PJW)

In connection with the production of confidential documents and

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other confidential information in this action, Plaintiff Gold Value International

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Textile, Inc. , a California corporation, individually and doing business as

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“FIESTA FABRIC,” (“Plaintiff”) on one hand, and Defendants (1) Gypsy 05, Inc.,

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a CA corporation; (2) The TJX Companies, Inc. a DE corporation, individually and

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doing business as “Marshalls”; (3) Eminent, Inc., a DE corporation, individually

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and doing business as Revolve clothing and www.revolveclothing.com; and

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(4)Amazon.com, Inc., a DE corporation (Defendants collectively, (“Defendants”),

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through their respective counsel (all parties collectively, the “Parties” or
individually, “Party”), hereby enter into this Stipulated Protective Order for

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LAW OFFICE OF PAMELA KOSLYN
5757 WILSHIRE BOULEVARD, PENTHOUSE 20
LOS ANGELES, CALIFORNIA 90036
[phone]

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Confidential Treatment of Documents or Information (the “Stipulated Protective

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Order”).

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GOOD CAUSE STATEMENT
The Court may enter a protective order upon a showing of good cause.

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Phillips v. G.M. Corp., 307 F.3d 1206, 1209 (9th Cir. 2002) (Rule 26(c)). Here,

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there is good cause for the entry of this protective order.

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This instant action is one for copyright infringement. The Parties’

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disclosures pursuant to Rule 26, and the Parties’ discovery requests will involve

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production of documents relating to the subject fabric designs, including the

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creation, manufacture, marketing, advertising, selling, distributing, exporting, and

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accounting for sales of Plaintiff’s products and of Defendants’ products which

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Plaintiff alleges infringe on Plaintiff’s designs. There will also be business-

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sensitive information such as insurance policies and indemnity agreements. This

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information —if not made public—is the type of information that a business would

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treat as confidential and proprietary, therefore meriting entry of this protective

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order to protect against the unnecessary disclosure of same outside the context of

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this litigation. To the extent the information is sensitive vis-à-vis the parties
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STIPULATED PROTECTIVE ORDER

2:15-CV-06928 (PJW)

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themselves because they are in a competitive posture, a higher level of

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confidentiality (i.e., “Attorneys Eyes Only”) is merited to protect against

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unnecessary disclosure of confidential information as between the parties.
PURPOSE OF THIS PROTECTIVE ORDER

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1.

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The purpose of this Stipulated Protective Order is to provide a means

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for limiting access to and use and disclosure of Confidential Documents or

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Information that are produced in this action. Any unauthorized disclosure of

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Confidential Documents or Information in violation of this Order may be subject to

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discipline by the contempt powers of this Court.

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LAW OFFICE OF PAMELA KOSLYN
5757 WILSHIRE BOULEVARD, PENTHOUSE 20
LOS ANGELES, CALIFORNIA 90036
[phone]

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2.

DEFINITION OF “CONFIDENTIAL DOCUMENTS OR

INFORMATION”
“Confidential Documents or Information” are all Documents or

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Information that (a) have been produced by any Party; and (b) have been properly

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designated as “Confidential” or “Confidential-Attorney’s Eyes Only” pursuant to

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paragraph 3, below.

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3.

DESIGNATION OF “CONFIDENTIAL DOCUMENTS OR

INFORMATION”
The Parties may designate such documents or information as

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“Confidential” or “Confidential-Attorney’s Eyes Only” in accordance with the

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following procedures:

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A.

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Criteria for Classification
(1)“Confidential” Documents or Information

Any Party may designate documents or information as “Confidential”

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if it has a reasonable good faith belief that the disclosure of said documents or

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information absent the protections of this order will have the effect of causing

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harm to the producing party’s competitive position or privacy interests because the

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documents or information embody (a) confidential accounting records including

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purchase orders, invoices, balance sheets, profit and loss statements, cash flow
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STIPULATED PROTECTIVE ORDER

2:15-CV-06928 (PJW)

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statements, bank records, expense reports (including invoices, receipts, and

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checks), payments, agreements, licenses, and sub-licenses; (b) customer lists; (c)

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sensitive personal information including social security numbers and other

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identifying information; and (d) proprietary marketing plans.

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(2)“Confidential-Attorney’s Eyes Only” Documents

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or Information
The designation “Confidential-Attorney’s Eyes Only” will be limited

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to such documents, materials or other things that any Party believes, in good faith,

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contain information, the disclosure of which is likely to cause severe harm to its

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competitive position, or which materials meet the definition of a trade secret set

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LAW OFFICE OF PAMELA KOSLYN
5757 WILSHIRE BOULEVARD, PENTHOUSE 20
LOS ANGELES, CALIFORNIA 90036
[phone]

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forth in section §3426.1(d) of the California Civil Code or other applicable trade

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secret statutes. This limitation is to be applied strictly.
B.

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Time of Designation

Unless otherwise agreed between counsel for the Parties, the

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designation of Confidential Documents or Information will be made at the time of

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the production of documents or information.
C.

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The designation of Confidential Documents or Information will be

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Manner of Designation

made in the following manner:
1.

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For documents, by placing the notation

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“Confidential” or “Confidential-Attorney’s Eyes Only” on each page of such

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document;

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2.

For tangible items, including any documents or

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information produced on magnetic disks or other computer related media, and

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including clothing samples, by placing the notation “Confidential” or

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“Confidential-Attorney’s Eyes Only” on the object and, if applicable, on the

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container thereof or if such are not practicable, as otherwise agreed by the Parties.

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In the event either Party generates any “hard copy” or printout from any
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STIPULATED PROTECTIVE ORDER

2:15-CV-06928 (PJW)

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“Confidential Material,” that Party must immediately stamp each page

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“Confidential” or “Confidential-Attorney’s Eyes Only,” and the hard copy or

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printout will be treated as “Confidential Information pursuant to this Stipulated

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Protective Order.”
3.

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For deposition testimony, by noting on the record

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that information is “Confidential” or “Confidential-Attorneys’ Eyes Only” at the

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time the deposition is taking place.

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D.

Retroactive Designation
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Inadvertent production of any Confidential

Documents or Information without a designation of confidentiality will not be

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LAW OFFICE OF PAMELA KOSLYN
5757 WILSHIRE BOULEVARD, PENTHOUSE 20
LOS ANGELES, CALIFORNIA 90036
[phone]

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deemed to waive a later claim as to confidentiality or privilege, or prevent the Party

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claiming said confidentiality from re-designating such documents or information as

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“Confidential” or “Confidential-Attorney’s Eyes Only” promptly after discovery of

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the inadvertent production and written notice to each other party.

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2.

Within ten (10) business days after production or

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deposition testimony, any Party may retroactively designate (or withdraw a

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designation) of Confidential Documents or Information under paragraphs 3(B) and

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(C) above, regarding any material that it has produced, provided however, that

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such retroactive designation (or withdrawal) will be in accordance with the terms

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of this Order. Such retroactive designation (or withdrawal) will be accomplished

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by notifying counsel for each non-designating Party in writing of such retroactive

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designation (or withdrawal). Upon receipt of any such written re-designation,

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counsel (i) will not make any further disclosure or communication of such

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retroactively designated material except as provided for in this Order; (ii) will take

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reasonable steps to notify all persons known to have possession of any

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retroactively designated material of the effect of such re-designation under this

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Order; and (iii) will take reasonable steps to procure all copies of such retroactively

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designated material from any persons known to have possession of any such
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STIPULATED PROTECTIVE ORDER

2:15-CV-06928 (PJW)

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retroactively designated material who are not entitled to receipt under this Order.
E.

Resolution of Disputes Regarding Designation

If any Party, at any time, wishes to have the “Confidential” or

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“Confidential-Attorney’s Eyes Only” designation of any particular Confidential

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Documents or Information removed or changed, that Party will first request in

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writing that the Party having made the designation at issue change its designation.

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Thereafter, the Parties will make good faith efforts to resolve the dispute.

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If the designating Party refuses to agree to remove or change the
designation, then the Party requesting that the designation be changed will request
the Court for a decision by submitting a Joint Stipulation pursuant to Local Rule

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LAW OFFICE OF PAMELA KOSLYN
5757 WILSHIRE BOULEVARD, PENTHOUSE 20
LOS ANGELES, CALIFORNIA 90036
[phone]

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37. At all times during the process of challenging a designation, the Parties will

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treat the designated material as originally designated until a change is agreed upon

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or the motion is decided by the Court.

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F.

Filing Confidential Material Under Seal

If any Party wants to file any material designated “Confidential,” or

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“Confidential-Attorney’s Eyes Only” under seal, then such Party will file a

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stipulation or ex parte application requesting it in compliance with Civil Local

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Rule 79-5. Material may only be filed under seal pursuant to a Court order

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authorizing the sealing of the material at issue. If a Party's request to file the

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material at issue under seal is denied by the Court, then a Party may file the

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information in the public record unless otherwise instructed by the Court.

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G.

Designation of Third Party Documents

Documents and/or information produced by a third party in response

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to a subpoena or during deposition in the course of this litigation may involve

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receipt of information, documents, things or testimony which include, contain or

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comprise protected information that may or may not be appropriate for

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“Confidential-Attorneys’ Eyes Only” or “Confidential” designation under this

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Order. Unless otherwise agreed in writing between counsel for the parties,
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STIPULATED PROTECTIVE ORDER

2:15-CV-06928 (PJW)

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documents and information so produced by a third party will be treated as follows:

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First of all, all such documents and information will automatically be deemed to be

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and will be treated as “Confidential-Attorneys’ Eyes Only” for five business days

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following their actual receipt by both counsel for Plaintiffs and counsel for

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Defendants in this action, in order to enable each such counsel to determine

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whether in their view any protected information is embodied therein. If no

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designation of the information as “Confidential” or “Confidential-Attorneys’ Eyes

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Only” by the Designating Party is received by the non-Designating Parties within

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five business days after said production, then the information will not be protected
by this Protective Order except pursuant to subsequent designation by a party

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LAW OFFICE OF PAMELA KOSLYN
5757 WILSHIRE BOULEVARD, PENTHOUSE 20
LOS ANGELES, CALIFORNIA 90036
[phone]

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hereto or pursuant to a subsequent agreement of the parties or Court order; if

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however a written designation of “Confidential” or “Confidential-Attorneys’ Eyes

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Only” is made by a Designating Party and is received by the non-Designating

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Parties within five business days after said production of documents or information

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by the non-party, then the information will be subject to this Protective Order and

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will be deemed to be “Confidential” or “Confidential-Attorneys’ Eyes Only” (as

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requested by the Designating Party); provided, however, that the designation may

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be challenged in the manner set forth in Section 3. E, supra.

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Lastly, to the extent third party documents or information contains

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information that is confidential and/or proprietary to the third party, said third party

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can avail itself of the protections set forth in this Order and designate documents

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and/or information it products accordingly by executing this Order and agreeing to

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be bound by its terms.

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4.

PERSONS TO WHOM CONFIDENTIAL DOCUMENTS

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OR INFORMATION MAY BE DISCLOSED

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A.

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as “Confidential”

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Disclosure of Documents or Information Designated

Documents or Information designated as “Confidential” may be
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STIPULATED PROTECTIVE ORDER

2:15-CV-06928 (PJW)

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disclosed and copies may be provided only to:

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Counsel of record;

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2.

Expert witnesses or consultants retained by the Parties or their

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respective counsel in connection with this action who have complied with

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paragraph 4(D), below;

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LAW OFFICE OF PAMELA KOSLYN
5757 WILSHIRE BOULEVARD, PENTHOUSE 20
LOS ANGELES, CALIFORNIA 90036
[phone]

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3.

Court reporting services and court reporters as may be reasonably

necessary in connection with the preparation or conduct of this action;
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This Court and its personnel, or any other tribunal of competent

jurisdiction having involvement in this matter and its personnel; and
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Any mediator or arbitrator or settlement conference neutral selected

by the Parties or by the Court to mediate or to try to settle or arbitrate this action.
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Representatives of the Parties.
B.

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Disclosure of Documents or Information Designated

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As “Confidential-Attorney’s Eyes Only”

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Confidential Documents or Information designated as “Confidential-

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Attorney’s Eyes Only” may be disclosed and copies may be provided only to:

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1.

Counsel of record;

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2.

Expert witnesses or consultants retained by the Parties or their

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respective counsel in connection with this action who have complied with

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paragraph 4(D), below;

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3.

This Court and its personnel, or any other tribunal of competent

jurisdiction having involvement in this matter and its personnel; and
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Any mediator or arbitrator or settlement conference neutral

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selected by the Parties or by the Court to mediate or to try to settle or arbitrate this

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action.

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C.

Additional Authorized Disclosure of Documents or

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Information Designated as “Confidential” or

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“Confidential Attorney’s Eyes Only”
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STIPULATED PROTECTIVE ORDER

2:15-CV-06928 (PJW)

Notwithstanding anything to the contrary in paragraphs 4(A) or 4(B)

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above, particular Confidential Documents or Information that have been designated

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as “Confidential” or “Confidential-Attorney’s Eyes Only” may be disclosed and

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copies may be provided:

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1.

To Persons who are explicitly named on the document as the authors

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or addressees or to persons who may be shown to be an author or recipient or

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intended recipient of any particular document;

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LAW OFFICE OF PAMELA KOSLYN
5757 WILSHIRE BOULEVARD, PENTHOUSE 20
LOS ANGELES, CALIFORNIA 90036
[phone]

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2.

To any other persons with the prior written consent of the designating

Party; and
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To any other persons with the prior authorization of this Court or any

other tribunal of competent jurisdiction having involvement in this matter.
4.

If a document designated as “Confidential” or “Confidential-

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Attorney’s Eyes Only” refers to the conduct or affairs of a potential witness, the

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Party’s counsel of record may discuss such conduct or affairs with such person

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without revealing the existence of the document, or its authors or source.

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D.

Disclosure to Experts or Consultants

Prior to disclosing or providing copies of any Confidential

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Documents or Information to any expert or consultant pursuant to paragraphs 4(A)

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or 4(B), above, the disclosing Party will first obtain the agreement of the expert,

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consultant or anyone else to whom such disclosure will be made to be bound by the

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terms of this Stipulated Protective Order as set forth in the attached

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“Acknowledgment and Agreement To Be Bound.” Specifically, the expert or

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consultant will acknowledge that, during the course of his or her retention, the

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expert or consultant may have access to, and become acquainted with Confidential

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Documents or Information, which are regularly used in the operation of the

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businesses of the designating Party or which have been prepared for use in the

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case, and in which the designating Party has an expectation of confidentiality. The

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expert or consultant will agree not to disclose such Confidential Documents or
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STIPULATED PROTECTIVE ORDER

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Information, directly or indirectly, to any person or entity not subject to this

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Stipulated Protective Order or use them in any way outside the specific scope of

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his/her retention as an expert witness in this action, or at any time thereafter.
E.

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Return of Confidential Documents or Information by
Experts and Consultants

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Confidential Documents or Information disclosed to any expert or

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consultant may be retained by such expert or consultant provided that such expert

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or consultant subsequently destroys any and all copies of such Confidential

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Documents or Information upon the termination of their engagement.
5.

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USE OF CONFIDENTIAL DOCUMENTS OR

LAW OFFICE OF PAMELA KOSLYN
5757 WILSHIRE BOULEVARD, PENTHOUSE 20
LOS ANGELES, CALIFORNIA 90036
[phone]

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INFORMATION

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A.

Generally

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Use of Confidential Documents or Information

Confidential Documents or Information will only be used by the Parties,

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their respective agents, and any other persons to whom such Confidential

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Documents or Information may be disclosed pursuant to this Stipulated Protective

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Order: (1) in this action; (2) as otherwise compelled by lawful process (provided

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the designating Party is given a reasonable notice to object); or (3) as otherwise

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required by law. Notwithstanding the foregoing, nothing in this Stipulated

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Protective Order will prevent or limit the designating Party from disclosing

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Confidential Documents or Information they so designate.
B.

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Conduct of this Action

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Use of Confidential Documents or Information in the

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Confidential Documents or Information may be used by counsel for

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the non-designating Party in good faith in connection with investigating this action,

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provided that the Confidential Documents or Information are protected pursuant to

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the terms and conditions of this Stipulated Protective Order.

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2.

The terms of this Stipulated Protective Order do not apply to evidence
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STIPULATED PROTECTIVE ORDER

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presented at court proceedings and/or trial in this matter. Any protective measures

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relating to Confidential Documents or Information should be taken up with the

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judicial officer conducting the particular proceeding at the appropriate time.

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3.

If any Party seeks to file pleadings or other documents with this Court

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that contains any other Party’s Confidential Documents or Information, it may do

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so only if: (a) reasonably necessary to the proceeding; and (b) the filing Party

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informs the designating Party of such filing concurrently with the filing of such

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documents with the Court.

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6.

TESTIMONY, OR INFORMATION

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Upon written request after the final conclusion of this action, the

LAW OFFICE OF PAMELA KOSLYN
5757 WILSHIRE BOULEVARD, PENTHOUSE 20
LOS ANGELES, CALIFORNIA 90036
[phone]

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RETURN OF CONFIDENTIAL DOCUMENTS,

Parties will:
A.

Return to each other Party or destroy any and all Confidential

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Documents or Information of that Party so designated by that Party and all copies

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thereof in its possession, custody and control, except that one set of such

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Confidential Documents or Information may be retained by counsel for archival

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purposes;

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B.

Ensure that all Confidential Documents or Information in the

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possession, custody or control of any permitted parties or third parties are returned

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to the designating Party; and

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C.

Destroy all notes, memoranda or other documents (collectively

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“Notes”) that contain excerpts from any of the Confidential Documents or

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Information, except that one such set of Notes may be retained by counsel for

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archival purposes. Notwithstanding the foregoing, attorney work product, attorney-

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client communications, and information derived from Confidential Documents or

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Information may be retained by each non-designating Party and its counsel.

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7.

PUBLIC DOCUMENTS

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None of the restrictions set forth in this Stipulated Protective Order
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STIPULATED PROTECTIVE ORDER

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will apply to any documents or other information that become public knowledge by

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means not in violation of the provisions of this Stipulated Protective Order.

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Nothing in this Stipulated Protective Order will prevent any Party from using any

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information that it properly possessed prior to receipt of any Confidential

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Documents or Information from the designating Party or that is discovered

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independently by the non-designating Party. Unless otherwise agreed by the Parties

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involved, the terms for the treatment of Confidential Documents or Information

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pursuant to the Stipulated Protective Order will be effective only upon the entry of

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this Stipulated Protective Order.
8.

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LAW OFFICE OF PAMELA KOSLYN
5757 WILSHIRE BOULEVARD, PENTHOUSE 20
LOS ANGELES, CALIFORNIA 90036
[phone]

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NO PROBATIVE VALUE

This Stipulated Protective Order will not aggregate or diminish any

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contractual, statutory or other legal obligation or right of any Party or other person

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with respect to any Confidential Documents or Information. The fact that

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information is designated “Confidential” or “Confidential-Attorney’s Eyes Only”

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under the Stipulated Protective Order will not be deemed to be determinative of

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what a trier of fact may determine to be confidential or proprietary. This Stipulated

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Protective Order will be without prejudice to the right of any Party to bring

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information before this Court, regardless of (a) whether any particular material is

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or is not Confidential, or (b) whether any particular information or material is or is

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not entitled to a greater or lesser degree of protection under the terms of this

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Stipulated Protective Order, provided that in doing so, the Party complies with the

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procedures set forth herein. The fact that any information is disclosed, used, or

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produced in any proceeding in this action will not be offered in any other action or

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proceeding before this or any other Court, agency or tribunal as evidence of or

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concerning whether or not such information is admissible, confidential or

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proprietary.
NO IMPLIED WAIVER OF ADMISSION

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9.

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No Party will be obligated to challenge the proprietary of any
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designation of “Confidential” or “Confidential Attorney’s Eyes Only”

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information, and the failure to do so will not constitute a waiver or otherwise

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preclude a subsequent challenge to the designation.
10.

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MODIFICATION OF THIS STIPULATED PROTECTIVE
ORDER

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The Parties hereto may modify the terms of this Stipulated Protective

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Order by further stipulation. However, no modification by the Parties will have the

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force or effect of a court order unless the Court approves the modification. Any

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Party may seek an order of this Court to modify the terms of this Stipulated
Protective Order. Any motion seeking such modification must be served upon all

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LAW OFFICE OF PAMELA KOSLYN
5757 WILSHIRE BOULEVARD, PENTHOUSE 20
LOS ANGELES, CALIFORNIA 90036
[phone]

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counsel of record and filed in accordance with this Court’s filing procedures.

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11.

EXECUTION AND COUNTERPARTS

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This Stipulated Protective Order may be executed in one or more

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counterparts, each of which will be deemed to be an original, but all of which

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together will constitute one and the same instrument. Facsimile signatures will be

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binding upon the Parties hereto and may be submitted and considered as originals.
The filing attorney attests that all signatories listed, and on whose

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behalf the filing is submitted, concur in the filing’s content and have authorized the

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filing.

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SO STIPULATED.

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Date: March 3, 2016

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LESNICK PRINCE & PAPPAS LLP
MICHAEL E. PAPPAS
DAVID S. ALVERSON
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STIPULATED PROTECTIVE ORDER

2:15-CV-06928 (PJW)

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By:

/s/ Michael E. Pappas
Michael E. Pappas
Attorneys for Plaintiff

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Date: March 3, 2016

LAW OFFICE OF PAMELA KOSLYN
PAMELA KOSLYN

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By:

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/s/ Pamela Koslyn
Pamela Koslyn
Attorneys for Defendants

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LAW OFFICE OF PAMELA KOSLYN
5757 WILSHIRE BOULEVARD, PENTHOUSE 20
LOS ANGELES, CALIFORNIA 90036
[phone]

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IT IS SO ORDERED.

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Date: March 9, 2016

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___________________________________
The Honorable Patrick J. Walsh
UNITED STATES MAGISTRATE JUDGE

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ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
I hereby acknowledge that I may receive information designated as

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“Confidential” and/or as “Confidential-Attorneys’ Eyes Only” from counsel to a

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party to this action. I hereby certify my understanding that such information will be

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provided to me pursuant to the terms and restrictions of the Stipulated Protective

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Order that has been entered by the Court; that I have been given a copy of, and

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have read and understand, such Stipulated Protective Order; that I agree to be
bound by the terms thereof; and that I irrevocably submit to the personal

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LAW OFFICE OF PAMELA KOSLYN
5757 WILSHIRE BOULEVARD, PENTHOUSE 20
LOS ANGELES, CALIFORNIA 90036
[phone]

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jurisdiction of the Court in connection with any proceeding to enforce the

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Stipulated Protective Order Re: Confidentiality that may involve me.

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ACKNOWLEDGED AND AGREED:

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Name:______________________________

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Address:____________________________

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Employer:___________________________

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Title:_______________________________

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Dated:______________________________

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STIPULATED PROTECTIVE ORDER

2:15-CV-06928 (PJW)