Creative Care, Inc. v. Connecticut General Life Insurance Company et al
Filing
65
STIPULATED PROTECTIVE ORDER by Magistrate Judge Alicia G. Rosenberg. re Stipulation for Protective Order 64 . (See Order for Further Details) (kl)
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UNITED STATES DISTRICT COURT
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CENTRAL DISTRICT OF CALIFORNIA
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CREATIVE CARE, INC.,
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Plaintiff,
v.
CONNECTICUT GENERAL LIFE
INSURANCE COMPANY, CIGNA
HEALTH CORPORATION, and DOES 1
through 20, Inclusive,
Case No. 2:16-cv-09056-DMG-AGR
Assigned to: Hon. Dolly M. Gee
Magistrate: Hon. Alicia G. Rosenberg
DISCOVERY MATTER
STIPULATED PROTECTIVE
ORDER
Defendants.
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STIPULATED PROTECTIVE ORDER
(Case No. 2:16-cv-09056-DMG-AGR)
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1.
BACKGROUND
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A. PURPOSES AND LIMITATIONS
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Discovery in this action is likely to involve production of confidential
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commercial, proprietary, or other sensitive, private information, including protected
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health information,1 for which special protection from public disclosure and from use
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for any purpose other than prosecuting this litigation may be warranted. Accordingly,
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the parties hereby stipulate to and petition the Court to enter the following Stipulated
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Protective Order. The parties acknowledge that this Order does not confer blanket
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protections on all disclosures or responses to discovery and that the protection it
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affords from public disclosure and use extends only to the limited information or
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items that are entitled to confidential treatment under the applicable legal principles.
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The parties further acknowledge, as set forth in Section 12.3, below, that this
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Stipulated Protective Order does not entitle them to file confidential information under
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seal; Civil Local Rule 79-5 sets forth the procedures that must be followed and the
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standards that will be applied when a party seeks permission from the court to file
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material under seal.
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B. GOOD CAUSE STATEMENT
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This action is likely to involve protected patient information and sensitive,
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proprietary business information and trade secrets for which special protection from
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public disclosure and from use for any purpose other than prosecution of this action is
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warranted. Such confidential and proprietary materials and information consist of,
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among other things, patient medical information protected under HIPAA, confidential
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business or financial information, information regarding confidential business
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practices, or other confidential commercial information (including information
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implicating privacy rights of third parties), information otherwise generally
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unavailable to the public, or which may be privileged or otherwise protected from
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This Order is a HIPAA-compliant “qualified protective order” pursuant to 45 C.F.R.
§ 164.512(e)(1)(ii),(v).
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STIPULATED PROTECTIVE ORDER
(Case No. 2:16-cv-09056-DMG-AGR)
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disclosure under state or federal statutes, court rules, case decisions, or common law.
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Accordingly, to expedite the flow of information, to facilitate the prompt resolution of
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disputes over confidentiality of discovery materials, to adequately protect information
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the parties are entitled to keep confidential, to ensure that the parties are permitted
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reasonable necessary uses of such material in preparation for and in the conduct of
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trial, to address their handling at the end of the litigation, and serve the ends of justice,
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a protective order for such information is justified in this matter. It is the intent of the
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parties that information will not be designated as confidential for tactical reasons and
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that nothing be so designated without a good faith belief that it has been maintained in
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a confidential, non-public manner, and there is good cause why it should not be part of
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the public record of this case.
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2.
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DEFINITIONS
2.1
Action: Creative Care, Inc. v. Connecticut General Life Ins. Co. et al.,
Case No. 2:16-cv-09056-DMG-AGR (C.D. Cal.).
2.2
Challenging Party: a Party or Non-Party that challenges the designation
of information or items under this Order.
2.3
“CONFIDENTIAL” Information or Items: information (regardless of
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how it is generated, stored or maintained) or tangible things that qualify for protection
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under Federal Rule of Civil Procedure 26(c), and as specified above in the Good
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Cause Statement.
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2.4
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Counsel: Outside Counsel of Record and In-House Counsel (as well as
their support staff).
2.5
Designating Party: a Party or Non-Party that designates information or
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items that it produces in disclosures or in responses to discovery as
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“CONFIDENTIAL.”
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2.6
Disclosure or Discovery Material: all items or information, regardless of
the medium or manner in which it is generated, stored, or maintained (including,
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STIPULATED PROTECTIVE ORDER
(Case No. 2:16-cv-09056-DMG-AGR)
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among other things, testimony, transcripts, and tangible things), that are produced or
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generated in disclosures or responses to discovery in this matter.
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2.7
Expert: a person with specialized knowledge or experience in a matter
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pertinent to the litigation who has been retained by a Party or its counsel to serve as an
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expert witness in this Action. Unless specifically agreed upon by the Parties, the term
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“Expert” does not include consultants, or individuals associated with lobbying firms,
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trade groups, advocacy groups, or other similar organizations.
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2.8
In-House Counsel: attorneys who are employees of a party to this Action.
In-House Counsel does not include Outside Counsel of Record or any other outside
counsel.
2.9
Non-Party: any natural person, partnership, corporation, association, or
other legal entity not named as a Party to this action.
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2.10 Outside Counsel of Record: attorneys who are not employees of a party
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to this Action but are retained to represent or advise a party to this Action and have
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appeared in this Action on behalf of that party or are affiliated with a law firm which
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has appeared on behalf of that party, and includes support staff.
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2.11 Party: any party to this Action.
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2.12 Producing Party: a Party or Non-Party that produces Disclosure or
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Discovery Material in this Action.
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2.13 Professional Vendors: persons or entities that provide litigation support
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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)
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and their employees and subcontractors. Unless specifically agreed upon by the
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Parties, the term “Professional Vendors” does not include consultants, or individuals
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associated with lobbying firms, trade groups, advocacy groups, or other similar
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organizations.
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2.14 Protected Material: any Disclosure or Discovery Material that is
designated as “CONFIDENTIAL.”
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STIPULATED PROTECTIVE ORDER
(Case No. 2:16-cv-09056-DMG-AGR)
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2.15 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 Stipulation and Order cover not only
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Protected Material (as defined above), but also (1) any information copied or extracted
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from Protected Material; (2) all copies, excerpts, summaries, or compilations of
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Protected Material; and (3) any testimony, conversations, or presentations by Parties
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or their Counsel that might reveal Protected Material.
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Any use of Protected Material at trial shall be governed by the orders of the trial
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judge. This Order does not govern the use of Protected Material 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.
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DESIGNATING PROTECTED MATERIAL
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
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STIPULATED PROTECTIVE ORDER
(Case No. 2:16-cv-09056-DMG-AGR)
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communications
for
which
protection
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is
not
warranted
are
not
swept
unjustifiably within the ambit of 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
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to sanctions.
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If it comes to a Designating Party’s attention that information or items that it
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designated for protection do not qualify for protection, that Designating Party must
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promptly notify all other Parties that it is withdrawing the inapplicable designation.
5.2
Manner and Timing of Designations. Except as otherwise provided in
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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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(a) for information in documentary form (e.g., paper or electronic
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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 at a minimum, the legend
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“CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
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contains protected material. If only a portion or portions of the material on a page
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qualifies for protection, the Producing Party also must clearly identify the protected
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portion(s) (e.g., by making appropriate markings in the margins).
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A Party or Non-Party that makes original documents available for inspection
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need not designate them for protection until after the inspecting Party has indicated
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which documents it would like copied and produced. During the inspection and before
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the designation, all of the material made available for inspection shall be deemed
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“CONFIDENTIAL.” After the inspecting Party has identified the documents
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STIPULATED PROTECTIVE ORDER
(Case No. 2:16-cv-09056-DMG-AGR)
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it wants copied and produced, the Producing Party must determine which documents,
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or portions thereof, qualify for protection under this Order. Then, before producing the
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specified documents, the Producing Party must affix the “CONFIDENTIAL legend”
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to each page that contains Protected Material. If only a portion or portions of the
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material on a page qualifies for protection, the Producing Party also must clearly
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identify the protected portion(s) (e.g., by making appropriate markings in the
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margins).
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(b) for testimony given in depositions that the Designating Party identify the
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Disclosure or Discovery Material on the record, before the close of the deposition all
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protected testimony.
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(c) for information produced in some form other than documentary and for
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any other tangible items, that the Producing Party affix in a prominent place on the
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exterior of the container or containers in which the information is stored the legend
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“CONFIDENTIAL.” If only a portion or portions of the information warrants
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protection, the Producing Party, to the extent practicable, shall identify the protected
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portion(s).
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5.3
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designate qualified information or items does not, standing alone, waive the
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Designating Party’s right to secure protection under this Order for such material.
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Upon timely correction of a designation, the Receiving Party must make reasonable
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efforts to assure that the material is treated in accordance with the provisions of this
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Order.
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6.
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Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to
CHALLENGING CONFIDENTIALITY DESIGNATIONS
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.
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STIPULATED PROTECTIVE ORDER
(Case No. 2:16-cv-09056-DMG-AGR)
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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 or
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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
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Party’s designation until the Court rules on the challenge.
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7.
ACCESS TO AND USE OF PROTECTED MATERIAL
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 (FINAL DISPOSITION).
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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 well
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as employees of said Outside Counsel of Record to whom it is reasonably necessary to
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disclose the information for this Action;
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(b)
the officers, directors, and employees (including In-House Counsel) of
the Receiving Party to whom disclosure is reasonably necessary for this Action;
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STIPULATED PROTECTIVE ORDER
(Case No. 2:16-cv-09056-DMG-AGR)
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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 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)
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(f) Professional Vendors to whom disclosure is reasonably necessary for
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this Action and who have signed the “Acknowledgment and Agreement to Be Bound”
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(Exhibit A);
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(g)
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court reporters and their staff;
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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(h) during their depositions, witnesses ,and attorneys for witnesses, in the
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Action to whom disclosure is reasonably necessary provided: (1) the deposing party
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requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will
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not be permitted to keep any confidential information unless they sign the
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“Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed
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by the Designating Party or ordered by the court. Pages of transcribed deposition
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testimony or exhibits to depositions that reveal Protected Material may be separately
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bound by the court reporter and may not be disclosed to anyone except as permitted
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under this Stipulated Protective Order; and
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(i)
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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Other than the limited individuals and entities identified in subsections (a)
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through (i) of this Section 7.2, a Receiving Party may not disclose any item designated
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“CONFIDENTIAL” or information contained therein to any other person or entity
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including, inter alia attorneys, law firms, lobbying firms, insurance companies,
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healthcare providers, patients, consultants, trade groups, advocacy groups or other
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associations.
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STIPULATED PROTECTIVE ORDER
(Case No. 2:16-cv-09056-DMG-AGR)
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8.
PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN
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OTHER LITIGATION
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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,” 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;
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(b)
promptly notify in writing the party who caused the subpoena or order to
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issue in the other litigation that some or all of the material covered by the subpoena or
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order is subject to this Protective Order. Such notification shall include a copy of this
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Stipulated 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.
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If the Designating Party timely seeks a protective order, the Party served with
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the subpoena or court order shall not produce any information designated in this
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action as “CONFIDENTIAL” before a determination by the court from which the
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subpoena or order issued, unless the Party has obtained the Designating Party’s
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permission. The Designating Party shall bear the burden and expense of seeking
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protection in that court of its confidential material and nothing in these provisions
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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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9.
A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED
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IN THIS LITIGATION
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(a)
The terms of this Order are applicable to information produced by a Non-
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Party in this Action and designated as “CONFIDENTIAL.” Such information
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produced by Non-Parties in connection with this litigation is protected by the
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remedies and relief provided by this Order. Nothing in these provisions should be
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construed as prohibiting a Non-Party from seeking additional protections.
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STIPULATED PROTECTIVE ORDER
(Case No. 2:16-cv-09056-DMG-AGR)
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(b)
In the event that a Party is required, by a valid discovery request, to
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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 Non-Party
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that some or all of the information requested is subject to a confidentiality agreement
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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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promptly provide the Non-Party with a copy of the Stipulated
(3)
make the information requested available for inspection by the
Non-Party, if requested.
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(c)
If the Non-Party fails to seek a protective order from this court within 14
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days of receiving the notice and accompanying information, the Receiving Party may
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produce the Non-Party’s confidential information responsive to the discovery request.
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If the Non-Party timely seeks a protective order, the Receiving Party shall not produce
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any information in its possession or control that is subject to the confidentiality
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agreement with the Non-Party before a determination by the court. Absent a court
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order to the contrary, the Non-Party shall bear the burden and expense of seeking
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protection in this court of its Protected Material.
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10.
UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
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If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
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Protected Material to any person or in any circumstance not authorized under this
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Stipulated Protective Order, the Receiving Party must immediately (a) notify in
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writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
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to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
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persons to whom unauthorized disclosures were made of all the terms of this Order,
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STIPULATED PROTECTIVE ORDER
(Case No. 2:16-cv-09056-DMG-AGR)
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and (d) request such person or persons to execute the “Acknowledgment and
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Agreement to Be Bound” that is attached hereto as Exhibit A.
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11.
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
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inadvertently produced material is subject to a claim of privilege or other protection,
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the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
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Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
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may be established in an e-discovery order that provides for production without prior
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privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
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parties reach an agreement on the effect of disclosure of a communication or
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information covered by the attorney-client privilege or work product protection, the
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parties may incorporate their agreement in the stipulated protective order submitted to
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the court.
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12.
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MISCELLANEOUS
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.
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12.2 Right to Assert Other Objections. By stipulating to the entry of this
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Protective Order no Party waives any right it otherwise would have to object to
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disclosing or producing any information or item on any ground not addressed in this
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Stipulated Protective Order. Similarly, no Party waives any right to object on any
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ground to use in evidence of any of the material covered by this 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. 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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STIPULATED PROTECTIVE ORDER
(Case No. 2:16-cv-09056-DMG-AGR)
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13.
FINAL DISPOSITION
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After the final disposition of this Action, as defined in paragraph 4, within 60
3
days of a written request by the Designating Party, each Receiving Party must return
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all Protected Material to the Producing Party or destroy such material. As used in this
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subdivision, “all Protected Material” includes all copies, abstracts, compilations,
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summaries, and any other format reproducing or capturing any of the Protected
7
Material. Whether the Protected Material is returned or destroyed, the Receiving Party
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must submit a written certification to the Producing Party (and, if not the same person
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or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by
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category, where appropriate) all the Protected Material that was returned or destroyed
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and (2)affirms that the Receiving Party has not retained any copies, abstracts,
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compilations, summaries or any other format reproducing or capturing any of the
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Protected Material. Notwithstanding this provision, Counsel are entitled to retain an
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archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts,
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legal memoranda, correspondence, deposition and trial exhibits, expert reports,
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attorney work product, 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
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(DURATION).
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14.
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measures including, without limitation, contempt proceedings and/or monetary
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sanctions.
Any violation of this Order may be punished by any and all appropriate
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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
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DATED: June 25, 2018
/s/ Gary L. Tysch
GARY L. TYSCH
LAW OFFICES OF GARY L TYSCH
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STIPULATED PROTECTIVE ORDER
(Case No. 2:16-cv-09056-DMG-AGR)
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DATED: June 25, 2018
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/s/ Edward T. Kang
EDWARD T. KANG
EMILY COSTIN
ELIZABETH A. SPERLING
ALSTON & BIRD LLP
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FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
DATED: June 26, 2018
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HON. ALICIA G. ROSENBERG
UNITED STATES MAGISTRATE JUDGE
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STIPULATED PROTECTIVE ORDER
(Case No. 2:16-cv-09056-DMG-AGR)
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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
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penalty of perjury that I have read in its entirety and understand the Stipulated
6
Protective Order that was issued by the United States District Court for the Central
7
District of California on [date] in the case of
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[insert formal name of the case and the number and initials assigned to it by the
9
court]. I agree to comply with and to be bound by all the terms of this Stipulated
10
Protective Order and I understand and acknowledge that failure to so comply could
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expose me to sanctions and punishment in the nature of contempt. I solemnly promise
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that I will not disclose in any manner any information or item that is subject to this
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Stipulated Protective Order to any person or entity except in strict compliance with the
14
provisions of this Order.
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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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Stipulated Protective Order, even if such enforcement proceedings occur after
18
termination of this action. I hereby appoint
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full name] of
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telephone number] as my
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California agent for service of process in connection with this action or any
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proceedings related to enforcement of this Stipulated Protective Order.
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Date:
[print or type
[print or type full address and
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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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STIPULATED PROTECTIVE ORDER
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STIPULATED PROTECTIVE ORDER
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