Homesite Insurance Company of the Midwest et al v. Gree Electric Appliances, Inc. of Zhuhai et al

Filing 78

PROTECTIVE ORDER by Magistrate Judge Jacqueline Chooljian re Stipulation for Protective Order, 75 (dml)

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Nathan M. Dooley (SBN 224331)
E-mail: [e-mail]
Elliott R. Feldman (Pro Hac Vice)
E-mail: [e-mail]
William N. Clark, Jr. (Pro Hac Vice)
E-mail: [e-mail]
COZEN O'CONNOR
601 S. Figueroa Street
Suite 3700
Los Angeles, CA 90017
Telephone: [phone]
Toll Free Phone: [phone]
Facsimile: 213.892.7999
Attorneys for Plaintiffs
Homesite Insurance Company of the Midwest,
American Strategic Insurance Corporation,
Milbank Insurance Company, Meridian
Security Insurance Company, Liberty Insurance
Corporation, The First Liberty Insurance
Corporation, Safeco Insurance Company of
Illinois, Safeco Insurance Company of Indiana,
American States Insurance Company, Safeco
Insurance Company of America, Liberty
Mutual Fire Insurance Company, State Auto
Property and Casualty Insurance Company,
Homesite Insurance Company, LM General
Insurance Company and New York Central
Mutual Insurance Company
UNITED STATES DISTRICT COURT
FOR THE CENTRAL DISTRICT OF CALIFORNIA

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HOMESITE INSURANCE COMPANY ) Case No.: 2:16-cv-6769 ODW (JCx)
OF THE MIDWEST, et al,
) (Honorable Otis D. Wright II)
)
Plaintiffs,
) STIPULATED PROTECTIVE
)ORDER
vs.
)
) Pretrial Conf. Date: November 19, 2018
GREE USA, INC., GREE ELECTRIC
) Discovery Cutoff: August 27, 2018
APPLIANCES, INC. OF ZHUHAI,
) Trial:
December 11, 2018
HONG KONG GREE ELECTRIC
)
APPLIANCE SALES, LTD., and MJC
)
AMERICA, LTD.
)
)
Defendants.
)
)
)
)
)
)
)

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1. A. PURPOSES AND LIMITATIONS

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As the parties have represented that discovery in this action is likely to involve

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production of confidential, proprietary, or private information for which special

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protection from public disclosure and from use for any purpose other than prosecuting

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this litigation may be warranted, this Court enters the following Protective Order.

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This Order does not confer blanket protections on all disclosures or responses to

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discovery. The protection it affords from public disclosure and use extends only to

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the limited information or items that are entitled to confidential treatment under the

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applicable legal principles. Further, as set forth in Section 12.3, below, this Protective

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Order does not entitle the parties to file confidential information under seal. Rather,

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when the parties seek permission from the court to file material under seal, the parties

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must comply with Civil Local Rule 79-5 and with any pertinent orders of the assigned

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District Judge and Magistrate Judge.

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B.

GOOD CAUSE STATEMENT

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In light of the nature of the claims and allegations in this case and the parties’

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representations that discovery in this case will involve the production of confidential

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records, and in order to expedite the flow of information, to facilitate the prompt

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resolution of disputes over confidentiality of discovery materials, to adequately

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protect information the parties are entitled to keep confidential, to ensure that the

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parties are permitted reasonable necessary uses of such material in connection with

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this action, to address their handling of such material at the end of the litigation, and to

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serve the ends of justice, a protective order for such information is justified in this

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matter. The parties shall not designate any information/documents as confidential

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without a good faith belief that such information/documents have been maintained in a

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confidential, non-public manner, and that there is good cause or a compelling reason

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why it should not be part of the public record of this case.

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//

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//
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2. DEFINITIONS
1.

Action: The instant action: Homesite Insurance Company of the

Midwest, et al. v. Gree USA, Inc., et al., Case No.: 2:16-cv-6769.
2.

Challenging Party: a Party or Non-Party that challenges the designation

of information or items under this Order.
3.

“CONFIDENTIAL” Information or Items: information (regardless of

how it is generated, stored or maintained) or tangible things that qualify for protection
under Federal Rule of Civil Procedure 26(c), and as specified above in the Good
Cause Statement.
4.

“HIGHLY CONFIDENTIAL -- ATTORNEYS’ EYES ONLY”

Information or Items: extremely sensitive “CONFIDENTIAL” Information or Items,
the disclosure of which to another Party or Non-Party would create a substantial risk
of serious harm that could not be avoided by less restrictive means.
5.

Counsel: Outside Counsel of Record and House Counsel (as well as their

support staff).
6.

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

items that it produces in disclosures or in responses to discovery as
“CONFIDENTIAL” or “HIGHLY CONFIDENTIAL -- ATTORNEYS’ EYES
ONLY.”
7.

Disclosure or Discovery Material: all items or information, regardless of

the medium or manner in which it is generated, stored, or maintained (including,
among other things, testimony, transcripts, and tangible things), that are produced or
generated in disclosures or responses to discovery in this matter.
8.

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

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

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9.

House Counsel: attorneys who are employees of a party to this Action.

House Counsel does not include Outside Counsel of Record or any other outside
counsel.
10.

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

other legal entity not named as a Party to this action.
11.

Outside Counsel of Record: attorneys who are not employees of a party

to this Action but are retained to represent or advise a party to this Action and have
appeared in this Action on behalf of that party or are affiliated with a law firm which
has appeared on behalf of that party, and includes support staff.
12.

Party: any party to this Action, including all of its officers, directors,

employees, consultants, retained experts, and Outside Counsel of Record (and their
support staffs).
13.

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

Discovery Material in this Action.
14.

Professional Vendors: persons or entities that provide litigation support

services (e.g., photocopying, videotaping, translating, preparing exhibits or
demonstrations, and organizing, storing, or retrieving data in any form or medium)
and their employees and subcontractors.
15.

Protected Material: any Disclosure or Discovery Material that is

designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL -- ATTORNEYS’
EYES ONLY.”
16.

Receiving Party: a Party that receives Disclosure or Discovery Material

from a Producing Party.

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3. SCOPE

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

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defined above), but also (1) any information copied or extracted from Protected

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Material; (2) all copies, excerpts, summaries, or compilations of Protected Material;
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and (3) any deposition testimony, conversations, or presentations by Parties or their
Counsel that might reveal Protected Material, other than during a court hearing or at
trial.
Any use of Protected Material during a court hearing or at trial shall be
governed by the orders of the presiding judge. This Order does not govern the use of
Protected Material during a court hearing or at trial.

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4. DURATION

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Even after final disposition of this litigation, the confidentiality obligations

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imposed by this Order shall remain in effect until a Designating Party agrees

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

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deemed to be the later of (1) dismissal of all claims and defenses in this Action, with

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or without prejudice; and (2) final judgment herein after the completion and

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exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action,

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including the time limits for filing any motions or applications for extension of time

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pursuant to applicable law.

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5. DESIGNATING PROTECTED MATERIAL

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5.1

Exercise of Restraint and Care in Designating Material for Protection.

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Each Party or Non-Party that designates information or items for protection under this

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

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

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only those parts of material, documents, items, or oral or written communications that

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qualify so that other portions of the material, documents, items, or communications

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for which protection is not warranted are not swept unjustifiably within the ambit of

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this Order.

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Mass, indiscriminate, or routinized designations are prohibited. Designations

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that are shown to be clearly unjustified or that have been made for an improper

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purpose (e.g., to unnecessarily encumber the case development process or to impose
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unnecessary expenses and burdens on other parties) may expose the Designating Party
to sanctions.
If it comes to a Designating Party’s attention that information or items that it
designated for protection do not qualify for protection, that Designating Party must
promptly notify all other Parties that it is withdrawing the inapplicable designation.
5.2

Manner and Timing of Designations. Except as otherwise provided in

this Order (see, e.g., second paragraph of Section 5.2(a) below), or as otherwise
stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
under this Order must be clearly so designated before the material is disclosed or
produced.
Designation in conformity with this Order requires:
a)

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

documents, but excluding transcripts of depositions), that the Producing Party affix at
a minimum, the legend “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL -ATTORNEYS’ EYES ONLY” to each page that contains protected material. If only a
portion or portions of the material on a page qualifies for protection, the Producing
Party also must clearly identify the protected portion(s) (e.g., by making appropriate
markings in the margins).
A Party or Non-Party that makes original documents available for inspection
need not designate them for protection until after the inspecting Party has indicated
which documents it would like copied and produced. During the inspection and before
the designation, all of the material made available for inspection shall be deemed
“CONFIDENTIAL.” After the inspecting Party has identified the documents it wants
copied and produced, the Producing Party must determine which documents, or
portions thereof, qualify for protection under this Order. Then, before producing the
specified documents, the Producing Party must affix the “CONFIDENTIAL”, or
“HIGHLY CONFIDENTIAL -- ATTORNEYS’ EYES ONLY” legend to each page
that contains Protected Material. If only a portion or portions of the material on a
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page qualifies for protection, the Producing Party also must clearly identify the
protected portion(s) (e.g., by making appropriate markings in the margins).

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b)

identifies on the record, before the close of the deposition as protected testimony.

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for testimony given in depositions that the Designating Party

c)

for information produced in some form other than documentary

and for any other tangible items, that the Producing Party affix in a prominent place
on the exterior of the container or containers in which the information is stored the
legend “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL -- ATTORNEYS’ EYES
ONLY.” If only a portion or portions of the information warrants protection, the
Producing Party, to the extent practicable, shall identify the protected portion(s).
5.3

Inadvertent Failures to Designate. If timely corrected, an inadvertent

failure to designate qualified information or items does not, standing alone, waive the
Designating Party’s right to secure protection under this Order for such material.
Upon timely correction of a designation, the Receiving Party must make reasonable
efforts to assure that the material is treated in accordance with the provisions of this
Order.

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6.

CHALLENGING CONFIDENTIALITY DESIGNATIONS

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6.1

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

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

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Scheduling Order.

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6.2

Meet and Confer. The Challenging Party shall initiate the dispute

resolution process under Local Rule 37-1 et seq.
6.3

The burden of persuasion in any such challenge proceeding shall be on

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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

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or withdrawn the confidentiality designation, all parties shall continue to afford the
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material in question the level of protection to which it is entitled under the Producing
Party’s designation until the Court rules on the challenge.

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7.

ACCESS TO AND USE OF PROTECTED MATERIAL

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7.1

Basic Principles. A Receiving Party may use Protected Material that is

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disclosed or produced by another Party or by a Non-Party in connection with this

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

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

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conditions described in this Order. When the Action has been terminated, a Receiving

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Party must comply with the provisions of Section 13 below.
Protected Material must be stored and maintained by a Receiving Party at a

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

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authorized under this Order.

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7.2

Disclosure of “CONFIDENTIAL” Information or Items. Unless

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otherwise 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 of Record in this Action, as

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well as employees of said Outside Counsel of Record to whom it is reasonably

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necessary to disclose the information for this Action;

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b)

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

of the Receiving Party to whom disclosure is reasonably necessary for this Action;
c)

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

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disclosure is reasonably necessary for this Action and who have signed the

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

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d)

the court and its personnel;

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e)

reasonably necessary for this Action and who have signed the “Acknowledgment and
Agreement to Be Bound” (Exhibit A);

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f)

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

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h)

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during their depositions, witnesses, and attorneys for witnesses, in

the Action to whom disclosure is reasonably necessary provided: (1) the deposing
party requests that the witness sign the “Acknowledgment and Agreement to Be
Bound” (Exhibit A); and (2) they will not be permitted to keep any confidential
information unless they sign the “Acknowledgment and Agreement to Be Bound”
(Exhibit A), unless otherwise agreed by the Designating Party or ordered by the court.
Pages of transcribed deposition testimony or exhibits to depositions that reveal
Protected Material may be separately bound by the court reporter and may not be
disclosed to anyone except as permitted under this Protective Order; and

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the author or recipient of a document containing the information or

a custodian or other person who otherwise possessed or knew the information;

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professional jury or trial consultants, mock jurors, and Professional

Vendors to whom disclosure is reasonably necessary for this Action and who have

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private court reporters and their staff to whom disclosure is

i)

any mediator or settlement officer, and their supporting personnel,

mutually agreed upon by any of the parties engaged in settlement discussions.
7.3

Disclosure of “HIGHLY CONFIDENTIAL -- ATTORNEYS’ EYES

ONLY” Information or Items. Unless otherwise ordered by the court or permitted in
writing by the Designating Party, a Receiving Party may disclose any information or
item designated “CONFIDENTIAL” only to:
a)

the Receiving Party’s Outside Counsel of Record in this Action, as

well as employees of said Outside Counsel of Record to whom it is reasonably
necessary to disclose the information for this Action;

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b)

disclosure is reasonably necessary for this Action and who have signed the
“Acknowledgment and Agreement to Be Bound” (Exhibit A);

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c)

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Agreement to Be Bound” (Exhibit A);
e)

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

the author or recipient of a document containing the information or

a custodian or other person who otherwise possessed or knew the information; and

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professional jury or trial consultants, mock jurors, and Professional

Vendors to whom disclosure is reasonably necessary for this Action and who have

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private court reporters and their staff to whom disclosure is

reasonably necessary for this Action and who have signed the “Acknowledgment and

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the court and its personnel;

d)

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

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any mediator or settlement officer, and their supporting personnel,

mutually agreed upon by any of the parties engaged in settlement discussions.

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8.

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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that compels disclosure of any information or items designated in this Action as

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“CONFIDENTIAL” or “HIGHLY CONFIDENTIAL -- ATTORNEYS’ EYES

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ONLY,” that Party must:

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a)

promptly notify in writing the Designating Party. Such notification

shall include a copy of the subpoena or court order unless prohibited by law;
b)

promptly notify in writing the party who caused the subpoena or

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

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subpoena or order is subject to this Protective Order. Such notification shall include a

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copy of this Protective Order; and

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c)

cooperate with respect to all reasonable procedures sought to be

pursued by the Designating Party whose Protected Material may be affected.
If the Designating Party timely seeks a protective order, the Party served with
the subpoena or court order shall not produce any information designated in this
action as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL -- ATTORNEYS’
EYES ONLY” before a determination by the court from which the subpoena or order
issued, unless the Party has obtained the Designating Party’s permission, or unless
otherwise required by the law or court order. The Designating Party shall bear the
burden and expense of seeking 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 disobey a lawful directive from another court.

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9.

A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

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PRODUCED IN THIS LITIGATION

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a)

The terms of this Order are applicable to information produced by

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a Non-Party in this Action and designated as “CONFIDENTIAL” or “HIGHLY

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CONFIDENTIAL -- ATTORNEYS’ EYES ONLY.” Such information produced by

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Non-Parties in connection with this litigation is protected by the remedies and relief

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provided by this Order. Nothing in these provisions should be construed as

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prohibiting a Non-Party from seeking additional protections.

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b)

In the event that a Party is required, by a valid discovery request,

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to produce a Non-Party’s confidential information in its possession, and the Party is

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subject to an agreement with the Non-Party not to produce the Non-Party’s

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confidential information, then the Party shall:

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(1)

promptly notify in writing the Requesting Party and the

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

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agreement with a Non-Party;

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(2)

Protective Order in this Action, the relevant discovery request(s), and a reasonably
specific description of the information requested; and

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(3)

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make the information requested available for inspection by

the Non-Party, if requested.

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promptly provide the Non-Party with a copy of the

c)

If a Non-Party represented by counsel fails to commence the

process called for by Local Rules 45-1 and 37-1, et seq. within 14 days of receiving
the notice and accompanying information or fails contemporaneously to notify the
Receiving Party that it has done so, the Receiving Party may produce the Non-Party’s
confidential information responsive to the discovery request. If an unrepresented
Non-Party fails to seek a protective order from this court within 14 days of receiving
the notice and accompanying information, the Receiving Party may produce the NonParty’s confidential information responsive to the discovery request. If the Non-Party
timely seeks a protective order, the Receiving Party shall not produce any information
in its possession or control that is subject to the confidentiality agreement with the
Non-Party before a determination by the court unless otherwise required by the law or
court order. Absent a court order to the contrary, the Non-Party shall bear the burden
and expense of seeking protection in this court of its Protected Material.
10.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
Protected Material to any person or in any circumstance not authorized under this
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 of this Order, and (d)
request such person or persons to execute the “Acknowledgment and Agreement to Be
Bound” (Exhibit A).

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INADVERTENT PRODUCTION OF PRIVILEGED OR
OTHERWISE PROTECTED MATERIAL

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
information covered by the attorney-client privilege or work product protection, the
parties may incorporate their agreement into this Protective Order.

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12.

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12.1 Right to Further Relief. Nothing in this Order abridges the right of any

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MISCELLANEOUS

person to seek its modification by the Court in the future.
12.2 Right to Assert Other Objections. No Party waives any right it otherwise

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

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ground not addressed in this Protective Order. Similarly, no Party waives any right to

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object on any ground to use in evidence of any of the material covered by this

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Protective Order.

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

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

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orders of the assigned District Judge and Magistrate Judge. Protected Material may

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only be filed under seal pursuant to a court order authorizing the sealing of the

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specific Protected Material at issue. If a Party’s request to file Protected Material

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under seal is denied by the court, then the Receiving Party may file the information in

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the public record unless otherwise instructed by the court.

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13.

FINAL DISPOSITION

After the final disposition of this Action, as defined in Section 4, within 60 days
of a written request by the Designating Party, each Receiving Party must return all
Protected Material to the Producing Party or destroy such material. As used in this
subdivision, “all Protected Material” includes all copies, abstracts, compilations,
summaries, and any other format reproducing or capturing any of the Protected
Material. Whether the Protected Material is returned or destroyed, the Receiving
Party must submit a written certification to the Producing Party (and, if not the same
person or entity, to the Designating Party) by the 60 day deadline that (1) identifies
(by category, where appropriate) all the Protected Material that was returned or
destroyed and (2) affirms that the Receiving Party has not retained any copies,
abstracts, compilations, summaries or any other format reproducing or capturing any
of the Protected Material. Notwithstanding this provision, Counsel are entitled to
retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing
transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
reports, attorney work product, and consultant and expert work product, even if such
materials contain Protected Material. Any such archival copies that contain or
constitute Protected Material remain subject to this Protective Order as set forth in
Section 4.
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Any violation of this Order may be punished by any and all appropriate

measures including, without limitation, contempt proceedings and/or monetary
sanctions.
IT IS SO STIPULATED

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DATED: 10/16/17
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HINSHAW & CULBERTSON LLP

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By

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-/S/David I. Dalby
Gregg D. Minkin (PHV)

Attorneys for Defendants
GREE USA, INC., GREE ELECTRIC
APPLIANCES, INC. OF ZHUHAI,
HONG KONG GREE ELECTRICAL
APPLIANCE SALES, LTD.|
AND MJC AMERICA, LTD.

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DATED: 10/16/17

COZEN O’CONNOR

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By
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-/S/Nathan M. Dooley
William N. Clark, Jr. (PHV)
Attorneys for Plaintiffs

IT IS SO ORDERED
DATED: October 16, 2017

/s/
Honorable Jacqueline Chooljian
United States Magistrate Judge

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EXHIBIT A

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ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

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

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_________________ [print or type full address], declare under penalty of perjury that

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

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United States District Court for the Central District of California on October 16, 2017

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in the case of Homesite Insurance Company of the Midwest, et al. v. Gree USA, Inc.,
et al., Case No.: 2:16-cv-6769. I agree to comply with and to be bound by all the
terms of this 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
solemnly promise that I will not disclose in any manner any information or item that is
subject to this Protective Order to any person or entity except in strict compliance with
the provisions of this Order.
I further agree to submit to the jurisdiction of the United States District Court

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

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Protective Order, even if such enforcement proceedings occur after termination of this

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action. I hereby appoint __________________________ [print or type full name] of

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_______________________________________ [print or type full address and

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telephone number] as my California agent for service of process in connection with

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this action or any proceedings related to enforcement of this 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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