Nichelle Gooden v. Total Safety U.S., Inc. et al

Filing 18

STIPULATED PROTECTIVE ORDER by Magistrate Judge Alicia G. Rosenberg. re Stipulation for Protective Order 17 . NOTE CHANGES MADE BY THE COURT. (See Order for Further Details) (kl)

Case 2:16-cv-05620-VAP-AGR Document 17-1 Filed 03/13/17 Page 1 of 14 Page ID #:210
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JOSEPH A. SCHWACHTER,Bar No.10812
ischwachter(a~littler.com
kcha man(c~littler.comkcha [e-mail]

LIT~EI~MENDELS~N,P.C.
333 Bush Street 34th Floor
San Francisco, ~A 94104
Telephone:[phone]
Facsunile:[phone]

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Attorneys for Defendant
TOTAL SAFETY U.S.,INC.

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SCOTT CUMIVIINGS
scottna.cummin~sandfranck.com
LEE FR.ANCK
lee cummin sandfianck.com
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1025 W 190 St. Suite 200
Gardena, CA 90248
Phone: [phone]
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Facsimi e: 10)295-2180

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Attorneys for Plaintiff
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iCHELLE GOODEN

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iJNITED STATES DISTRICT COURT
IS

CENTRAL DISTRICT OF CALIFORrIIA

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IVICHELLE GOODEN,

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Plaintiff,

CASE NO. 2:16-CV-05620-VAP-AGR
ASSIGNED TO HON. VIRGII~]IA A.
PHILLIPS

vs.

TOTAL SAFETY U.S.,INC.
LEROY JOHNSON,and DOSS 1 to
100,inclusive,
Defendants.

STIPIULATEI~ PROTECTIVE
OI~IDEyt
Date:
Time:
Dept.:
Judge:

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Case 2:16-cv-05620-VAP-AGR Document 17-1 Filed 03/13/17 Page 2 of 14 Page ID #:211

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P~JRPOSES AND LIlVIITATIONS
Disclosure and discovery activity in this action are likely to involve
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production of confidential, proprietary, or private information for which special )
protection from public disclosure and from use for any purpose other than prosecuting
this litigation may be warranted Accordingly, the parties hereby stipulate to and
petition the court to enter the following Stipulated Protective Order. The parties
acknowledge that this Order does not confer blanket protections on all disclosures or
responses to discovery and that the protection it affords from public disclosure and use
extends only to the limited information or items th~.t are entitled to confidential
treatment under the applicable legal prianciples. The parties further acknowledge, as set

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orth in Section 12.3, below,that this Stipulated Protective Order does not entitle them
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to file confidential information under seal; Civil Local Rule 79-5 sets forth the

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procedures that must be followed and the standards that will be applied when a party

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seeks permission from the count to file material under seal.

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DEFINI7CI()1VS

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Challenging.Party:

a Party or Non-Party that challenges the

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designation ofinformation or items under this Order.

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"CONFIDENTIAY,"•Information.or Items:, information (regardless
ofhow it is generated,stored or maintained)or tangible.things that qualify for protection
under Federal Rule of Civil Procedure 26(c).

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Counsel(without qualifier): Outside Counsel ofRecord and House

Counsel(as well as their support staffl.
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Designating Party: a~Party orNon-Party that designates information

or items as "CONFIDENTIAL.','
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Disclosure or .Discovery Material:

all items or information,

regardless of the medium or manner in which it' is generated, stored, or maintained

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Case 2:16-cv-05620-VAP-AGR Document 17-1 Filed 03/13/17 Page 3 of 14 Page ID #:212
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(including, among other things, testimony, transcripts, and tangible things), that are
produced or generated in disclosures or responses to discovery in this matter.
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Expert: ~ a person with specialized knowledge or experience in a

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matter pertinent to the litigation who has been retained by a Party or its counsel to serve

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as an expert witness or as a consultant in this action.
2.11 Producing Party: a Party or Non-Party that produces Disclosure or

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Discovery Material in this action.

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support services (e.g., photocopying, videotaping, translating, preparing exhibits or

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demonstrations, and organizing,storing, or retrieving data in any form or medium)and

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2.12 Professional Vendors: persons or entities that provide litigation

their employees and subcontractors.

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2.13 Protected Material: any Disclosure or Discovery Material that is

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designated as"CONFIDENTIAL" and that is produced by a party to this litigation or a

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Non-Party that received the Disclosure or Discovery Material through anon-public or

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unlawful manner.
2.14 Receiving Party: a Party that receives Disclosure or Discovery

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Material from a Producing Party.

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3.

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The protections conferred by this Stipulation and Order cover not only

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Protected Material(as defined above), but also(1)any information copied ox extracted

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from Protected Material;(2)all copies, excerpts, or compilations ofProtected Material;

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and (3) any testimony, or presentations by Parties or their Counsel that might reveal

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Protected Material. However, the protections conferred by this Stipulation and Order

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do not cover the following information:(a)any information that is in the public domain

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at the time of disclosure to a Receiving Party or becomes part ofthe public domain after

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its disclosure to a Receiving Party as a result ofpublication not involving a violation of

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this Order, including becoming part ofthe public record through trial or otherwise; and

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ORDER

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Case 2:16-cv-05620-VAP-AGR Document 17-1 Filed 03/13/17 Page 4 of 14 Page ID #:213

(b)any information known to the Receiving Party prior to the disclosure or obtained by
2 the Receiving Party after the disclosure from a source who obtained the information
3 lawfully. Any- use of Protected Material at trial shall be governed by a separate
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agreement or order.

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Even after final disposition ofthis litigation,the confidentiality obligations

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imposed by this Order shall remain in effect_until a Designating Party agrees otherwise

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in writing or a court order otherwise directs. Final disposition shall be deemed to be the

DURATIOI~

9 ~' later of
(1)dismissal of all claims and defenses in this action, with or without prejudice;
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and (2) final judgment herein after the completion and exhaustion of all appeals,

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rehearings,remands,trials, or reviews ofthis action, including the time limits for filing

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any motions or applications for extension oftime pursuant to applicable law.

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DESIGNATING PltO'I'~CTEY)1VIATERTAT,

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5.1

Exercise of Restraint and Care in Designating Material for

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Protection. Each Party or Non-Party that designates information or items for protection

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under this Order must take care to limit any such designation to specific material that

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qualifies under the appropriate standards. The Designating Party must designate for

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

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communications that qualify — so that other portions ofthe material, documents, items,
or communications for which protection is not warranted are not swept unjustifiably

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within the ambit ofthis Order.

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Mass, indiscriminate, or routinized designations are prohibited.

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Designations that axe shown to be clearly unjustified or that have been made for an

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improper purpose (e.g., to unnecessarily encumber or retard the case development

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process or to impose unnecessary expenses and burdens on other parties) expose the

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Designating Party to sanctions.

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Case 2:16-cv-05620-VAP-AGR Document 17-1 Filed 03/13/17 Page 5 of 14 Page ID #:214

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Ifit comes to a Designating Party's attention that information or items that

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it designated for protection do not qualify for protection,that Designating Party must

3 1 promptly notify all other Parties that it is withdrawing the mistaken designation.
5.2

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Manner and Timing ofDesignations. Except as otherwise provided

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in this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise

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stipulated or ordered, Disclosure or Discovery Material that qualifies for protection

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under this Order must be clearly so designated before the material is disclosed or

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produced.

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Designation in conformity with this Order requires:

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

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documents, but excluding transcripts of depositions or other pretrial or trial

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proceedings), that the Producing Party affix the legend "CONFIDENTIAL" to each

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page that contains protected material. If only a portion or portions ofthe material on a

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page qualifies for protection, the Producing Party also must clearly identify the

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protected portions)(e.g., by making appropriate markings in the margins).

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or
f inspection need not designate them for protection until after the inspecting Pa1-ty has

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indicated which material it would like copied and produced. During the inspection and

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A Party or Non-Part;!that makes original documents or materials available

before the designation, all ofthe material made available for inspection shall be deemed

CONFYDENTIAL." After the inspecting Party has identified the documents it wants
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copied and produced,the Producing Party must deternune which documents,or portions
thereof, qualify for protection under this Order. Then, before producing the specified

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documents,the Producing Party must affix the"CONFIDENTIAL"legend to each page

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that contains Protected Material. If only a.portion or portions ofthe material on a page

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qualifies for protection, the Producing Party also must clearly identify the protected

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portions)(e.g., by making appropriai:e markings.in the margins).

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(b) for testimony given in deposition

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~uac~ae~that the Designating Party identify on the record, before the close ofthe
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all protected testimony.

deposition,

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( for information produced in some form other than documentary and
c)

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f any other tangible items,that the Producing Pariy affix in a prominent place on the
or

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

7 ' legend "CONFIDENTIAL." If only a portion or portions of the information or item
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warrant protection, the Producing Party, to the extent practicable, shall identify the

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protected portion(s).
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Tnad~ertent Failures, to Designate. If timely corrected (within 14

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days of production), an inadvertent failure to designate qualified information or items

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does not, standing alone, waive the Designating Party's right to secwre protection under

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this Order for such material. Upon timely correction of a designation, the Receiving

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Party must make reasonable efforts to assure that the material is treated in accordance

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with the provisions ofthis Order.
5.4

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Designation by Receiving Party. IfReceiving Party determines that

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material produced by Producing Party includes Protected Material that was not obtained

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by the Producing Party after the disclosure from a source who obtained the information

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lawfully,then Receiving Party may designate those documents as confidential by giving

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notice to Producing Party within thirty (30) days of production or thirty (30) days of

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signing ofthis order, whichever is later.

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C~ALLIEIiTGING CONFIDENT~AALIT'S~ I)ESIGNA'TIOI~TS
6.1 Timing of Challenges. Any Party or Non-Party may challenge a

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designation ofconfidentiality at any time that is consistent with the Court's Scheduling

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Order.

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6.2 Meet and Confer. The Challenging Party shall initiate the dispute
resolution process under Local Rule 37.1 et seq.

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S Bush Streel
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30tl~ Floor
pn Frawicm,CA 9J1W
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Case 2:16-cv-05620-VAP-AGR Document 17-1 Filed 03/13/17 Page 7 of 14 Page ID #:216

6.3

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The burden of persuasion in any such challenge proceeding shall be

on the Designating Party.Frivolous challenges,and those made for an improper purpose

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e.g., to harass or impose unnecessary expenses and burdens on other parties) may
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expose the Challenging Party to sanctions. Unless the Designating Party has waived the

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confidentiality designation by failing to file a motion to retain confidentiality as

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described above, all parties shall continue to afford the material in question the level of

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protection to which it is entitled under the Producing Party's designation until the court

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rules on the challenge.

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ACCESS TO AND USE OF PROTECTED MA'TE~[AL

to

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Basic Principles. A Receiving Party may use Protected Material that

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is disclosed or produced by another Party ox by allon-Party in connection with this case

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

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

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

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comply with the provisions ofsection 13 below(FINAL DISPOSITIOI~.

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

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a location and in a secure mariner that ensures that access is limited to the persons

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authorized under this Order.

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Disclosure of "CONFIDENTIAL" Information or Items. Unless

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othei~uise ordered by the court or permitted in writing by the Designating Party, a

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Receiving Party may disclose any information or item designated "CONFIDENTIAL"

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only to:

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(a) the Receiving Party's Outside Counsel ofRecord in this action, as well

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as employees of said Outside Counsel ofRecord to whom it is reasonably necessary to

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disclose the information for this litigation;

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( the officers, directors, and employees (including House Counsel) of
b)
the Receiving Party to whom disclosure is reasonably necessary for this litigation;

Case 2:16-cv-05620-VAP-AGR Document 17-1 Filed 03/13/17 Page 8 of 14 Page ID #:217

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

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disclosure is. reasonably necessary for this litigation and who have signed the

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Aclrnowledgment and Agreement to Be Bound"(Exhibit A);
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( the court and its personnel;
d)

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( court reporters and their staff, professional jury or trial consultants,
e)

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mock jurors, and Professional Vendors to whom disclosure is reasonably necessary for

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this litigation and who have signed the"Acknowledgment and Agreementto Be Bound"

Exhibit A);
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(~ during their depositions, witnesses in the action to whom disclosure is

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reasonably necessary and who have signed the"Acknowledgment and Agreement to Be

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Bound" (Exhibit A), unless otherwise agreed by the Designating Party or ordered by

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the court. Pages of transcribed deposition testimony or exhibits to depositions that
~ marked by the court reporter and
reveal Protected Material must be separately

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may not be disclosed to anyone except as permitted under this Stipulated Protective

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Order.

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(g) the author or recipient of a document containing the information or a
custodian or other person who otherwise.possessed or knew the information.
( any mediator or settlement officer, and their supporting personnel,
h)

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mutually agreed upon by any ofthe parties engaged in settlement discussions.

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PRO~'~CTED MA'B'ERl[~L ~TJ~POEN~D ~R OI2DER~I~
PRODUCED IN OT~R ]LYTIGATgOIV
If a Party is served with a subpoena or a court order issued in other
litigation that compels disclosure of any information or items designated in this action

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as"CONFIDENTIAL," that Party must:
( promptly notify iri writing the Designating Pariy. Such notification
a)
shall include a copy ofthe subpoena or court order;
( promptly notify in writing the party who caused the subpoena or order
b)
to issue in the other litigation that some or all ofthe material covered by the subpoena

Case 2:16-cv-05620-VAP-AGR Document 17-1 Filed 03/13/17 Page 9 of 14 Page ID #:218

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or order is subject to this Protective Order. Such notification shall include a copy o£this

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Stipulated Protective Order; and

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( cooperate with respect to all reasonable procedures sought to be
c)

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pursued by the Designating Party whose Protected Material maybe affected.
Ifthe Designating Party timely seeks a protective order within 14 days,the

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Party served with the subpoena or court order shall not produce any information

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designated in this action as "CONFIDENTIAL" before a determination by the court

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from which the subpoena or order issued, unless the Party has obtained the Designating
Pariy's permission. The Designating Party shall bear the burden and expense ofseeking

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protection in that court of its confidential material —and nothing in these provisions
should be construed as 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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. A I~tON-PAR~'~'S PROTECTED MATERIAIL SOUG~T'TO
BE PI~OI)UC~I)IN THIS LITIGA~'IOl~T
( The terms of this Order are applicable to information produced by a
a)
Non-Party in this action and designated as "CONFIDENTIAL." Such information
produced by Non-Parties in connection with this litigation is protected by the remedies
and relief provided by this Order. Nothing in these provisions should be construed as
prohibiting allon-Party from seeking additional protections.
( In the event that a Pariy is required, by a valid discovery request, to
b)
produce allon-Party's confidential information in its possession, and the Party is
subject to an explicit agreement with the Non-Party not to produce the Non-Party's
confidential information,then the Party shall:
( notify in writing the Requesting Party within 7 business days oftheir
1)
request. Such notification shall include a copy of explicit agreement between the
Producing Party and Non-Party and include written verification of the Non-Party's
assent to the agreement; and notify the Non-Party that some or all of the information
requested is subject to a confidentiality agreement;

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3
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341h Floor
an Farclxa.G141101
415./J3.1990

Case 2:16-cv-05620-VAP-AGR Document 17-1 Filed 03/13/17 Page 10 of 14 Page ID
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(2)

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promptly provide the Non-Party with a copy of the Stipulated

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

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specific description of the information requested; and,
(3) make the information requested available for inspection by the Non-

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Party.

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

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court within 14 days of receiving the notice and accompanying information, the

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Receiving Party must produce the Non-Party's confidential information responsive to

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the discovery request. If the Non-Party timely seeks a protective order, the Receiving

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Party shall not produce any information in its possession or control that is subject to the

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confidentiality agreement with the Non-Party before a determination by the court.

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Absent a court order to the contrary, the Non-Party shall bear the burden and expense

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of seeking protection in this court of its Protected Material.

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(d)

The identities, locations, and contact information of any Non-Party

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l
ikely to have witnessed events likely to prove or disprove the allegations made in the

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Parties' complaints and answers shall not be Designated as Protected Material.

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9.0. ~A~JTB[OR~ZED ~YSC~OSVRE O]E Pi20'~.']EC°I'~ID
l
YIC~'I'~RIAL
I a Receiving Party learns that, by inadvertence or otherwise, it has
f
disclosed Protected Material to any person or in any circumstance not authorized under
this Stipulated Protective Order, the Receiving Party must immediately (a) notify in
writing the Designating Party of the unauthorized disclosures, (b) use its best efforts to
retrieve all unauthorized copies of the Protected Material, (c) inform the person or
persons to whom unauthorized disclosures were made of all the terms pf this Order, and
(d) request such person or persons to execute the "Acknowledgment and Agreement to
Be Bound" that is attached hereto as E~ibit A.

Case 2:16-cv-05620-VAP-AGR Document 17-1 Filed 03/13/17 Page 11 of 14 Page ID
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11. ~iA]DVERTENT PROI)UC'TI~IV O~ PRIVII~EGEgD OR
07C]~EI~WI~E PRO'~ECTED MA.TERIA.L
When a Producing Party gives notice to Receiving Parties that certain
inadvertently produced material is subject to a claim of privilege or other protection,
the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
may be established in an e-discovery order that provides for production without prior
.privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
parties reach an agreement on the effect of disclosure of a communication or
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nformation covered by the attorney-client privilege or work product protection, the
parties may incorporate their agreement in the stipulated protective order submitted to

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the court.
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12.

NdISCEL]LANEOUS

12.1 Right to Further Relief. Nothing in this Order abridges the right of
any person to seek its modification by the court in the future.
12.2 Right to Assert Other Objections. By stipulating to the entry of this
Protective Order no Party waives any right it otherwise would have to object to
disclosing or producing any information or item on any ground not addressed in this
Stipulated Protective Order. Similarly, no Party waives any right to object on any
ground to use in evidence of any of the material covered by this Protective Order.
12.3 Filing Protected Material. A Party that seeks to file under seal any
Protected Material must comply with Civil Local Rule 79-5. Protected Material may
only be filed under seal pursuant to a court order authorizing the sealing of the specific
Protected Material at issue. If a Receiving Parly's request to file Protected Material
under seal pursuant to Civil Local Rule is denied by the court, then the Receiving Party
may file the information in the public record unless otherwise instructed by the court.

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' ►1ENOFJ.SON, P.G
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3J3 gush SVael
310 Floor
tinRangaco, CA 9fI06
4tSlXilB4o

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Case 2:16-cv-05620-VAP-AGR Document 17-1 Filed 03/13/17 Page 12 of 14 Page ID
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13. ~'~TAYl1)TSPOSITIOIV
Within 60 days after the final disposition of this action, as defined in

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paragraph 4, each Receiving Party must return all Protected Material to the Producing
Party or destroy such material. As used in this subdivision, "all Protected Material"

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

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reproducing or capturing any ofthe Protected Material. Whether the Protected Material

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is returned or destroyed, the Receiving Party must submit a written certification to the

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8 ' Producing Party (and, if not the same person or entity, to the Designating Party) by the
9 60 day deadline that affirms that the Receiving Party has not retained any copies,
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the Protected Material. Notwithstanding this provision, Counsel are entitled to retain an

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archival copy of all pleadings, motion papers, txial, deposition, and hearing transcripts,

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

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work product, and consultant and expert work product, even if such materials contain

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Protected Material. Any such archival copies that contain or constitute Protected

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Material remain subject to this Protective Order as set forth in Section 4(DUR.ATIOI~.

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abstracts, compilations,summaries or any other format reproducing or capturing any of

measures including, without limitation, contempt proceedings and/or monetary

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sanctions.

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

IT IS SO STIPULATED,THROUGH COUNSEL OF RECORD.

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DATED:~

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7NFloor
3
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415~33.19l0

LITTLER MENDELSON,P.C.
Attorneys for Defendant

TOTAL SAFETY U.S.,INC.

Case 2:16-cv-05620-VAP-AGR Document 17-1 Filed 03/13/17 Page 13 of 14 Page ID
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DATED: January ~4 ,2017

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STEVENS & MCMILLAN
Attorneys for Plaintiff
MICHELLE GOODEN

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PURSUANT TO STIPULATION,IT IS SO ORDERED.

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DATED: 3 2~ 2D I ~

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United States Distri

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n

agistrate J ge

Case 2:16-cv-05620-VAP-AGR Document 17-1 Filed 03/13/17 Page 14 of 14 Page ID
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:223

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ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

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[print or type full name], of

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[
print or type full address], declare under penalty ofperjury that I

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have read in its entirety and understand the Stipulated Protective Order that was issued

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by the United States District Court for the Northern District of California on [date] in

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[insert formal name of the case and the number and initials

assigned to it by the court]. I agree to comply with and to be bound by all the terms of

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this Stipulated Protective Order and I understand and acknowledge that failure to so

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comply could expose me to sanctions and punishment in the nature of contempt. I

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solemnly promise that I will not disclose in any manner any information or item that is

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subject to this Stipulated Protective Order to any person or entity except in strict

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compliance with the provisions ofthis Order.

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X further agree to submit to the jurisdiction of the United States District

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Court for the Central District of California for the purpose ofenforcing the terms ofthis

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Stipulated Protective Order, even if such enforcement proceedings occur after

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termination ofthis action.
I hereby appoint

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[print or type full name]
[print or type full address and

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of

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telephone number] as my California agent for service ofprocess in connection with this

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action or any proceedings related to enforcement ofthis Stipulated Protective Order.

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Date:

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City and State where sworn and signed:

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Printed name:

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Signature:

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Firmwide:145274590.1 070157.1010

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