Edmond E Aslan et al v. Ferrari North America, Inc. et al

Filing 44

PROTECTIVE ORDER by Magistrate Judge Suzanne H. Segal, re Stipulated Protective Order 43 . (mr)

1 JAMES J. YUKEVICH(SBN 159896)
~~yu~kevich(a~yukelaw.com
2 CRISTINAIVI. CIMINELLI(SBN 206201)
cciminelli yukelaw.com
3' JEFFREY . CALIGIURI(SBN 273908)
~ Jc~~a~~- i auri yukelaw.com
1
YUK~IC ~ CAVANAUGH
4
355 S. Grand Avenue,.l5th Floor
Los Angeles, California 90071-1560
5
Telephone: [phone]
6. Facsimile: 213 362-7788
71 Attorneys for Defendant
FERRARI NORTH AMERICA,INC.
81
9

UNITED STATES DISTRICT COURT

10

CENTRAL DISTRICT OF CALIFORNIA,WESTERN DIVISION

11
121, EDMOND E. ASLAN and EILEEN
MICHAELIAN,
13
Plaintiffs,
14.
vs.
15
FERRARI NORTH AMERICA,INC., a
16! Delaware cor~ poration, ZF TRW
Automotive Holding Corporation a
Michigan Corporation, and DOES 117
100, inclusive,
18
Defendants.
19

CASE NO. 2:16-cv-2574-AB(SSx)
STIPULATED PROTECTIVE
ORDER
[Discovery Document: Referred to
Magistrate Judge Suzanne H. Segal]

20
IT IS HEREBY STIPULATED by and between the undersigned parties, by

21

22 and through their respective counsel of record, as follows:
23
24

I•

PURPOSES AND LIMITATIONS
Discovery in this Action is likely to involve the production of confidential,

25 proprietary, or private information for which special protection from public
26 disclosure and from use for any purpose other than the prosecution or defense ofthis
27 litigation may be warranted. Accordingly, the Parties hereby stipulate to and
petition the Court to enter the following Stipulated Protective Order (hereinafter,
2;16-CV-2574-AB(SSx)

1663351.1 / 72-5 l2

S'1IPULA`l'ED PKOT'ECTIVE ORDER

1 "Order").
2 II.

GOOD CAUSE

3

This Action is likely to involve trade secrets, customer lists, customer

4 communications, and other valuable research, development, commercial, financial,
5 technical, and/or proprietary information for which special protection from public
6 disclosure and from use for any purpose other than prosecution or defense of this
7 Action is warranted. Such confidential and proprietary materials and information
S consist of, among other things, confidential business or financial information
9 (including information implicating the privacy rights ofthird parties), information
10 regarding the Parties' confidential business practices, and/or the Parties' confidential
11 research, development, design, manufacturing, and commercial information, which
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decisions, or common law. Accordingly, to expedite the flow of information

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confidentiality of discovery materials, to adequately protect information that the

17~ Parties are entitled to keep confidential, to ensure the Parties are permitted
18 reasonable necessary uses of such material in preparation for and in the conduct of
19 trial, to address their handling at the end ofthe litigation, and to serve the ends of
20 justice, a protective order for such information is justified in this matter. It is the
21 intent of the Parties that information will not be designated as confidential for
22 tactical reasons and that nothing be so designated without a good faith belief that it
23 has been maintained in a confidential, non-public manner, and there is good cause
24 why it should not be part ofthe public record ofthis case.
25 III.

DEFINITIONS

26

A.

Action: the above-captioned litigation, Edmond E. Aslan and Eileen

27 ~ Michaelian v. Fe~raNi North America, Inc., et al., United States District Court,
28 Central District of California, Case No. 2:16-cv-2574-AB(SSx).
1663351.1 / 72-5 l2

2
STIPULATED PROTECTIVE ORDER

2:16-cv-2574-AB(SSx)

1

B.

Challen~in~ Party: a Party or Nan-Party that challenges the

2 ~ designation of information or items under this Order.
3

C.

"CONFIDENTIAL"Information or Items: information or tangible

4 things (regardless of how the information or things are generated, stored, or
5 maintained) that qualify far protection under Federal Rule of Civil Procedure 26(c),
6 ~ and as specified, supra, in the Good Cause Statement.
7

D.

Counsel Counsel ofRecord and House Counsel, and their respective
:

8 ~ support staffs.
9

E.

Counsel of Record: attorneys who are not employees of a Paz-ty to this

10 Action but are retained to represent or advise a Party to this Action and have
11 appeared in this Action on behalf ofthat Party or axe at'filiated with a law firm
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12 which has appeared on behalf of that Party, and their respective support staffs.

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Designating Party: a Party or Non-Party that designates information or

items that it produces in disclosures or in responses to discovery as

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Disclosure or Discovery Material: all items or information, regardless

17 ofthe medium or manner in which it is generated, stored, or maintained (including,
18 but not limited to, testimony, transcripts, and tangible things), that are produced or
19 generated in disclosures or responses to discovery in this Action.
20

H.

Expert: a person with specialized knowledge or experience in a matter

21 pertinent to the litigation who has been retained by a Party or its Counsel to serve as
22 an expert witness or as a consultant in this Action.
23

I.

House Counsel: attorneys who are employees of a Party to this Action,

24 House Counsel does not include Counsel of Record or any other outside counsel,
25

J.

Non-Party: any natural person, partnership, corporation, association,

26 or other legal entity not named as a Party to this Action.
27

K.

Party or Parties: any party or parties to this Action, including all of

28 their officers, directors, employees, consultants, retained experts, and Counsel of
2:16-cv-2574-AB(SSx)

1663351.1 / 72-512

STIPULATED PROTECTIVE ORDER

1 Record, and their respective support staff.
2

L.

Producing Party: a Party or Non-Party that produces Disclosure or

3 Discovery Material in this Action.
4

M.

Professional Vendors: persons or entities that provide litigation

5 support services (including photocopying, videotaping, translating, preparing
6 exhibits or demonstrations, and organizing, storing, or retrieving data in any form or
7 medium)and their employees and subcontractors.
81

N.

Protected Material: any Disclosure or Discovery Material that is

9 designated as "CONFIDENTIAL."
10

O.

Receiving Party: a Party that receives Disclosure or Discovery

11 ~ Material from a Producing Party.
12 IV.

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The protections conferred by this Order cover not only Protected Material (as

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that might reveal Protected Material.
Any use of Protected Material at trial shall be governed by the orders ofthe

18

19 trial judge. This Order does not govern the use of Protected Material at trial.
20 1 V.

DURATION

21

Even after the final disposition of this Action, the confidentiality obligations

22 imposed by this Order shall remain in effect until a Designating Party agrees
23 otherwise in writing or a court order otherwise directs. Final disposition shall be
24 deemed to be the later of(1)dismissal of all claims and defenses in this Action, with
25 or without prejudice; and (2)final judgment herein after the completion and
26 exhaustion of all appeals, rehearing, remands, trials, or reviews of this Action,
27 including tk~e time limits for filing any motions or applications for extension oftime
28 pursuant to applicable law.
1663351.] /72-512

4
STIPULATED PROTECTIVE ORDER

2:16-cv-2574-AB(SSx)

1 II VI.

DESIGNATING PROTECTED MATERIAL

2

A.

3

Except as otherwise provided in this Order (see, e.g., second paragraph of

Manner and Timing of Designation

4 ~~ Section VT(A)(1), infra), or as otherwise stipulated or ordered, Disclosure or
5 ~~ Discovery Material that qualifies for protection under this Order must be clearly so
6 ~~ designated before the material is disclosed or produced.
7

Designation in conformity with this Order requires:
1.

8

For information in documentary farm (e.g., paper or other

9 electronic documents, but excluding transcripts of depositions ar other pretrial or
10 trial proceedings), the Producing Party shall affix at a minimum, the legend
11 "CONFIDENTIAL" to each page that contains protected material. If only a portion
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12 or portions ofthe material on a page qualifies for protection, the Producing;Party
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A Party or Non-Party that makes original documents available for inspection
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17 ~ which documents it would like copied and produced. During the inspection and
18 ~ before the designation, all ofthe material made available for inspection shall be
19 ~ deemed "CONFIDENTIAL." After the inspecting Party has identified the
20 ~ documents it wants copied and produced, the Producing Party must determine which
21 documents, or portions thereof, qualify for protection under this Order. Then,
22 II before producing the specified documents,the Producing Party must affix the legend
23 "CONFIDENTIAL" to each page that contains Protected Material. If only a portion
24 or portions of the material on a page qualifies for protection, the Producing Party
25 also must clearly identify the protected portions (e.g., by making appropriate
26 markings in the margins).
For testimony given in depositions, the Designating Party shall
28 identify the Disclosure or Discovery Material on the record, before the close of the
2.

27

2:16-cv-2574-A B(SSx)

1663351.1 / 72-512

STIPULATED PROTECTIVE ORDER

11 ~ VIII. ACCESS TO AND USE OF PROTECTED MATERIAL
Basic Principles

2

A.

3

A Receiving Party may use Protected Material that is disclosed or produced

4 by another Party or by a Non-Party in connection with this Action only for
5 prosecuting, defending, or attenripting to settle this Action. Such Protected Material
6 may be disclosed only to the categories of persons and under the conditions
7 described in this Order. When the Action has been terminated, a Receiving Party
8 must comply with the provisions of Section XIV, infra.
9

Protected Material must be stored and maintained by a Receiving Party at a

10 ~ location and in a secure manner that ensures that access is limited to the persons
11 authorized under this Order.
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Unless otherwise ordered by the Court or permitted in writing by the

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Disclosure of ~~CONFIDENTIAL" Information or Items

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or item
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The Receiving Party's Counsel of Record in this Action, as well as
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employees of said Counsel of Record to whom it is reasonably

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necessary to disclose the information for this Action;

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2.

The officers, directors, and employees (including House Counsel) of

20

the Receiving Party to whom disclosure is reasonably necessary for this

21

Action;

22

3.

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

23

disclosure is reasonably necessary for this Action and who have signed

24

the "Acknowledgement and Agreement to be Bound"(E~ibit A),

25

provided that no disclosure shall be made to any Expert who is (i) an

26

employee of a direct business competitor of the Designating Party; or

27

(ii} employed by a direct business competitor ofthe Designating Party

28

and who directly participates in design, manufacturing, marketing, ox
]663351,l / 72-512

~
STIPULATED PROTECTIVE ORDER

2:16-cv-2574-AB(SSx)

service activities of direct business competitors;

1
2

4.

The Court and its personnel;

3

5.

Court reporters and their staff;

4

6.

Professional Vendors to whom disclosure is reasonably necessary for

5

this Action and who have signed the "Acknowledgement and

6

Agreement to be Bound"(E~ibit A);

7

7.

The author or recipient of a document containing the information or a

8

custodian or other person who otherwise possessed or knew ofthe

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information; and

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8.

Any mediator or settlement officer, and their supporting personnel,

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mutually agreed upon by any of the Parties engaged in settlement

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discussions.

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IX. PROTECTED MATERIAL SUBPOENAED OR ORDERED
PRODUCED IN OTHER LITIGATION

If a Party is served with a subpoena or a court order issued in other litigation
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17 "CONFIDENTIAL" that Party must:
18

1.

shall include a copy ofthe subpoena or court order;

19
20

Promptly notify in writing the Designating Party. Such notification

2.

Promptly notify in writing the party who caused the subpoena or order

21

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

22

by the subpoena ox order is subject to this Order. Such notification

23

shall include a copy ofthis Stipulated Protective Order; and

24

3.

Cooperate with respect to all reasonable procedures sought to be

25

pursued by the Designating Party whose Protected Material may be

26

affected.

If the Designating Party timely seeks a protective order, the Party served with
28 the subpoena or court order shall not produce any information designated in this

27

1663351 ,1 / 72-512

g
STIPULATED PROTECTIVE ORDER

2:16-cv-2574-AB(SSx)

1 action as "CONFIDENTIAL" before a determination by the court from which the
2 subpoena or order issued, unless the Party has obtained the Designating Party's
3 permission. The Designating Party shall bear the burden and expense of seeking
4 protection in that court of its confidential material and nothing in these provisions
5 should be construed as authorizing or encouraging a Receiving Party in this Action
6 to disobey a lawful directive from another court.
7 X.

ANON-PARTY'S PROTECTED MATERIAL SOUGHT TO BE

8

PRODUCED IN THIS LITIGATION

9

The terms ofthis Order are applicable to information produced by a Non-

10 Party in this Action and designated as "CONFIDENTIAL." Such information
11 produced by Non-Parties in connection with this Action is protected by the remedies
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12 and relief provided by this Order, Nothing in these provisions should be construed
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In the event that a Party is required, by a valid discovery request, to produce a
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~6 I agreement with the Non-Party not to produce the Non-Party's confidential

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17 information, then the Party shall:
18

1.

Promptly notify in writing the Requesting Party and the Non-Party that

19

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

20

agreement with allon-Party;

21

2.

Promptly provide the Non-Party with a copy of this Order, the relevant

22

discovery request(s), and reasonably specific description ofthe

23

information requested; and

24

3.

Party, if requested.

2S
26

Make the information requested available for inspection by the Non-

Ifthe Non-Party fails to seek a protective order from this Court within

27 II fourteen (14) days of receiving the notice and accompanying information, the
2g II Receiving Party may produce the Non-Party's confidential information responsive
1663351.1 / 72-512

9
PROTECTIVE ORDER
STIPULATED

2:16-cv-2574-AB(SSx)

1 to the discovery request. If the Non-Party timely seelcs a protective order, the
2 Receiving Party shall not produce any information in its possession or control that is
3 subject to the confidentiality agreement with the Non-Party before a determination
4 by the Court. Absent a court order to the contrary, the Non-Party shall bear the
5 burden and expense of seeking protection in this Court of its Protected Material.
6 XI.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

7

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

8 Protected Material to any person or in any circumstance not authorized under this
9 Order, the Receiving Party must immediately (a)notify in writing the Designating
10 Party ofthe unauthorized disclosures;(b)use its best efforts to retrieve all
11 unauthorized copies of Protected Material;(c)inform the person or persons to whom
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12 unauthorized disclosures were made of all the terms of this Order; and (d)request
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s 15 XII. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
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PROTECTED MATERIAL

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When a Producing Party gives notice to Receiving Parties that certain
18 inadvertently produced material is subject to a claim of privilege or other protection,
19 the obligations ofthe'Receiving Parties are those set forth in Federal Rule of Civil
17

20 Procedure 26(b)(5)(B). This provision is not intended to modify whatever
21 procedure may be established in an e-discovery order that provides for production
22 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and
23 (e), insofar as the Parties reach an agreement on the effect of disclosure of a
24 communication or information covered by the attorney-client privilege or work
25 product protection, the Parties may incorporate their agreement in the stipulated
26 protective order submitted to the Court.
27 ///
28 ///
2:16-cv-2574-AB(SSx)

1663351.1 / 72-512

STIPULATED PROTECTIVE ORDER

~i XIII. MISCELLANEOUS
Right to Further Relief

2

A.

3

Nothing in this Order abridges the right of any person to seek its modification

4 by the Court in the future.
Right to Assert Other Objections

5

B.

6

By stipulating to the entry of this Protective Order no Party waives any right

7 it otherwise would have to object to disclosing or producing any information or item
8 on any ground not addressed in this Order. Similarly, no Party waives any right to
9 object on any ground to use in evidence of any of the material covered by this
10 Order.
Filing Protected Material

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A Party that seeks to file under seal any Protected Material must comply with

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X16 is denied by the Court, then the Receiving Party may file the information in the
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17 public record unless otherwise instructed by the Court.
18 ~ XIV. FINAL DISPOSITION
19

After the final disposition of this Action, as defined in Section V,supra,

20 within sixty(60)days of a written request by the Designating Party, each Receiving
21 Party must return all Protected Material to the Producing Party or destroy such
22 material. As used in this subdivision,"all Protected Material" includes all copies,
23 abstracts, compilations, summaries, and any other format reproducing or capturing
24 any of the Protected Material. Whether the Protected Material is returned or
25 destroyed,the Receiving Party must submit a written certification to the Producing
26 Party (and, if not the same person or entity, to the Designating Party) by the sixty
27 (60) day deadline that(1)identifies(by category, where appropriate) all the
28 Protected Material that was returned or destroyed, and (2) affirms that the Receiving
1663351.1 / 72-512

11
STIPULATED PROTECTIVE ORDER

2:16-cv-2s7~-AB(ssx)

1 Party has not retained any copies, abstracts, compilations, summaries, or any other
2 format reproducing or capturing any ofthe Protected Material.
3 XV. VIOLATION OF THIS ORDER
4

Any violation ofthis Order may be punished by any and all appropriate

5 measures including, without limitation, contempt proceedings or monetary
6 sanctions.
7

IT IS SO STIPULATED.
,2017

8 DATED:
9

YUKEVICH ~ CAVANAUGH

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M. Ciminelli
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Jeffrey W. Caligiuri
Attorneys for Defendant
FERRARI NORTH AMERICA,INC.

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2017
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DANIELS,FINE,ISRAEL,
SCHONBUCH ~LEBOVI'

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"
~fd~e Lebovits
Ashl y ~L. Arnett
Attorneys for Plaintiffs EDMOND E.
ASLAN and EILEEN MICHAELIAN

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FOR GOOD CAUSE SHOWING,IT IS SO ORDERED.

23 I,
24 ~ DATED:

MAY 18, 2017

251
/S/

261

Hon. Suzanne H. Segal
United States Magistrate Judge

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1663351.1 / 72-512

12

STIPULATED PROTECTIVE ORDER

2:16-CV-2574-AB(SSX)

1

EXHIBIT A

2

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3
,individually and on behalf of my

I,

4

declare under

5 agents and employers,

6 penalty of perjury that I have read in its entirety and understand the Stipulated
7 Protective Order that was issued by the United States District Court for the Central
8 ~ District of California in the case ofEdmond E. Allan and Eileen Michaelian v.
9 Ferrari Noah America, Inc., et al., United States District Court, Central District of
10 California, Case No. 2:16-cv-2574-AB(SSx).
I hereby agree to comply with and to be bound by all the terms ofthis

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12 Stipulated Protective Order. I understand and acknowledge that failure to so comply
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compliance with the provisions ofthis Order.
I further agree to submit to the jurisdiction of the United States District Court

18

19 for the Central District of California for the purpose of enforcing the terms of this
20 Stipulated Protective Order, even if such enforcement proceedings occur after the
21 ~ termination of this action. I hereby appoint
as my California agent for service of

22 lof

23 process in connection with this action or any proceedings related to the enforcement
24 i of this Stipulated Protective Order.
25

DATE:

26

CITY AND STATE:

27

PRINTED NAME:

28

SIGNATURE:
2:16-cv-2574-AB(SSx)

1663351.1 / 72-512

STIPULATED PROTECTIVE ORDER

PROOF OF SERVICE
2 STATE OF CALIFORNIA,COUNTY OF LOS ANGELES
At the time of service, I was over 18 years of age and not a party.to this
action. I am employed in the County of Los An eles, State of California. My
4 business address is 355 South Grand Avenue, Fi~eenth Floor, Los Angeles, CA
90071-1560.
5
On May 17, 2017,I served true copies of the following document s)
6 described as STIPULATED PROTECTIVE ORDER on the intereste parties in
this action as follows:
7
SEE ATTACHED SERVICE LIST
8
BY CM/ECF for parties that are CM/ECF participants. Service is being made
9 electronically on.those parties on the attached list that are registered users of the
Court's Electronic Case Filing System.
10
I declare under penalty of perjury under the laws of the United States of
America that the foregoing is true and correct and that I am employed in the office
11
of a member of the bar of this Court at whose direction the service was made.
12
Executed on May 17, 2017, at Los An eles, California.
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1663351.1 / 72-512

2:16-cv-2574-AB Sx)
(S
STIPULATED PROTECTIVE ORDER