Anthony Luna v. Ricoh USA, Inc.

Filing 18

STIPULATED PROTECTIVE ORDER by Magistrate Judge Alicia G. Rosenberg re Stipulation for Protective Order 17 . (See Order for Further Details) (kl)

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Case x:17-cv-00244-PSG-AGR Document 17 Filed 03/17/17 Page 1of 16 Page ID #:821 t 2 3 4 s Donald Potter (SBN 192735) 1 VIiran 1Vloore (SBN 308095) milan don LAW FFI~E OF DONALD POTTER 776 East Green Street Suite 210 Pasadena, California X1101 Telephone: 626.744.15 55 Facsimile: 626.3 89.0592 6 Attorneys for Plaint 8 9 ~o ~t 0 ~2 N ri a~~ 43►°' Tiffany Renee Thomas (SBN 239085) Email: Rafael N. Tumanyan (SBN 295402) Email: rtum~an~ yan REED SMITH LL 101 Second Street, Suite 1800 San Francisco, CA 94105-3659 Telephone: +l 415 543 8700 Facsimile: +1 415 391 8269 Attorneys for Defendant 13 14 UNITED STATES DISTRICT COURT is CENTRAL DISTRICT OF CALIFORNIA D N~ ~~ 0 U~ 16 LIJNA, an individual, CASE NO.: 2:17-cv-244 PSG (AGRx) Plaintiff, O~ STIPULATED PROTECTIVE ORDER g~ ~s 19 V. Zo [ Filed with [Proposed) Order) 21 RICOH USA, INC., a corporation; and DOES 1 to 20, inclusive, 23 Complaint filed: May 16, 2016 Removal Date: January 12, 2017 Defendants. 24 25 26 27 28 STIPULATED PROTECTIVE ORDER AND (PROPOSED ORDER Case x:17-cv-00244-PSG-AGR Document 17 Filed 03/17/17 Page 2 of 16 Page ID #:822 1. A. a PURPOSES AND LIMITATIONS Discovery in this court is likely to involve production of confidential, proprietary, or private information for which special protection from public 4 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 that are entitled to confidential treatment io ii in Section 12.3, below, that this Stipulated Protective Order does not entitle them to is 0 under the applicable legal principles. The parties further acknowledge, as set forth f confidential information under seal; Civil Local Rule 79-5 sets forth the ile 13 procedures that must be followed and the standards that will be applied when a 14 party seeks permission from the court to file material under seal. ONO a ~ ~~ ~ 9~ •~ a« d o no o ~= ~ ~v od 15 B . U~ e «~ d N 16 This Action is likely to involve trade secrets, internal business information, 17 and other valuable research, development, commercial, financial, technical and/or is proprietary information for which special protection from public disclosure and 19 rom use for any purpose other than prosecution of this Action is warranted. Such f ao confidential and proprietary materials and information consist of, among other ai things, confidential business or financial information; information regarding 22 confidential business practices, or other confidential research, development, or 23 commercial information (including information implicating privacy rights of third 24 parties); confidential settlement agreements; and information otherwise generally 25 unavailable to the public, or which may be privileged or otherwise protected from ~~~ disclosure under state or federal statutes, court rules, case decisions, or common 2~ law. ~~ W N GOOD CAUSE STATEMENT D ~oa 3^ g~ as -2- STIPULATED PROTECTIVE ORDER AND [PROPOSED]ORDER Case x:17-cv-00244-PSG-AGR Document 17 Filed 03/17/17 Page 3 of 16 Page ID #:823 i One specific need for this Stipulated Protective Order is that Plaintiff 2 Anthony Luna's medical records will be produced. This Stipulated Protective 3 Order will cover the production of Plaintiff Luna's sensitive medical information. 4 Accordingly, to expedite the flow of information, to facilitate the prompt s resolution of disputes over confidentiality of discovery materials, to adequately 6 protect information the Parties are entitled to keep confidential, to ensure that the Parties are permitted reasonable necessary uses of such material in preparation for s 9 serve the ends ofjustice, a protective order for such information is justified in this io matter. It is the intent ofthe Parties that information will not be designated as it 0 and in the conduct of trial, to address their handling at the end ofthe litigation, and CONFIDENTIAL for tactical reasons and that nothing be so designated without a 12 good faith belief that it has been maintained in a confidential, non-public manner, 13 and there is good cause why it should not be part ofthe public record of this case. 14 2 . ON O a «~ = ~, ~ 9~ •~ a~~ Zdo d DEFINITIONS G vf= ~ du 15 2.1 "Action" means the lawsuit filed by Plaintiff Anthony Luna, an W ~ t U ~d N9 ~~ 16 individual, on or about May 16, 2016 in the Superior Court of California, County 17 ofLos Angeles, under Case No. BC620578 and removed to United States District is '~ Court, Central District of California under Case No. 2:17-cv-244 PSG(AGI~)on i9 January 12, 2017. W N O ~oa 3^ 5~ Zo ai 22 2 "Challenging Party" means a Party or Non-Party that challenges the .2. designation of information or items under this Order. 2.3 "CONFIDENTIAL" Information or Items means information (regardless ~ ~~ of how it is generated, stored or maintained) or tangible things that qualify for 24 protection under Federal Rule of Civil Procedure 26(c), and as specified above in as the Good Cause Statement. 2 6 a~ .4 2 "Counsel" means Outside Counsel of Record and House Counsel(as well as their support staff. Zs -3- STIPULATED PROTECTIVE ORDER AND [PROPOSED]ORDER Case x:17-cv-00244-PSG-AGR Document 17 Filed 03/17/17 Page 4 of 16 Page ID #:824 t 2 3 2.5 "Designating Party" means a Party or Non-Party that designates information or items that it produces in disclosures or in responses to discovery as CONFIDENTIAL." " 2 "Disclosure" or "Discovery Material" means all items or information, .6 4 s regardless of the medium or manner in which it is generated, stored, or maintained 6 ( including, among other things, testimony, transcripts, and tangible things), that are produced or generated in disclosures or responses to discovery in this matter. s 2 "Expert" means a person with specialized knowledge or experience in a .7 9 matter pertinent to the litigation who has been retained by a Party or its counsel to io serve as an expert witness or as a consultant in this Action. ii 2 "House Counsel" means attorneys who are employees of a party to this .8 to Action. House Counsel does not include Outside Counsel of Record or any other a ,•°-' ~ o 13 outside counsel. o Nw D 14 ~ dv is 0 O ~'O ~~ +%•d c W ~ c U ~d ~~ 2 "Non-Party" means any natural person, partnership, corporation, .9 association, or other legal entity not named as a Party to this Action. 2 "Outside Counsel of Record" means attorneys who are not employees .10 16 LL W ~ ~ ~oa 3^ 5~ i~ of a Party to this Action but are retained to represent or advise a party to this is Action and have appeared in this Action on behalf of that party or are affiliated 19 with a law firm which has appeared on behalf ofthat party, and includes support 20 staff. 21 22 23 24 25 2.11 "Party" means any party to this Action, including all of its officers, directors, employees, consultants, retained experts, and Outside Counsel of Record ( their support staffs). and 2 "Producing Party" means a Party or Non-Party that produces Disclosure .12 or Discovery Material in this Action. 2 6 2 "Professional Vendors" means persons or entities that provide litigation .13 a~ support services (e.g., photocopying, videotaping, translating, preparing exhibits or Zs -4- STIPULATED PROTECTIVE ORDER AND [PROPOSED]ORDER /17 Page 5 of 16 Page ID #:825 Case x:17-cv-00244-PSG-AGR Document 17 Filed 03/17 demonstrations, and organizing, storing, or retrieving data in any form or medium) 2 and their employees and subcontractors. .14 2 "Protected Material" means any Disclosure or Discovery Material that 3 4 is designated as "CONFIDENTIAL." s 2 "Receiving Party" means a Party that receives Disclosure or Discovery .15 6 Material from a Producing Party. 7 3 . SCOPE s The protections conferred by this Stipulation and Order cover not only 9 Protected Material(as defined above), but also(1)any information copied or io it 0 extracted from Protected Material;(2)all copies, excerpts, summaries, or compilations of Protected Material; and(3)any testimony, conversations, or 12 presentations by Parties or their Counsel that might reveal Protected Material. O NO a «~ ~~ 9~ ~, a ;;•~ 14 trial judge. This Order does not govern the use of Protected Material at trial. is 4 . a~ LL du o„ U ~d N9 ~ W N ~ ~oa 3^ g~ Any use ofProtected Material at trial shall be governed by the orders ofthe 13 DURATION Even after final disposition ofthis litigation, the confidentiality obligations 16 i~ imposed by this Order shall remain in effect until a Designating Party agrees is otherwise in writing or a court order otherwise directs. Final disposition shall be i9 deemed to be the later of(1) dismissal of all claims and defenses in this Action, Zo with or without prejudice; and (2)final judgment herein after the completion and 21 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, Za including the time limits for filing any motions or applications for extension of 23 time pursuant to applicable law. 4 2 5 . as DESIGNATING PROTECTED MATERIAL 5.1 Exercise of Restraint and Care in Designating Material for Protection. 2 6 Each Party or Non-Party that designates information or items for protection under 2~ this Order must take care to limit any such designation to specific material that as qualifies under the appropriate standards. The Designating Party must designate for -5- STIPULATED PROTECTIVE ORDER AND[PROPOSED]ORDER Case x:17-cv-00244-PSG-AGR Document 17 Filed 03/17/17 Page 6 of 16 Page ID #:826 protection only those parts of material, documents, items, or oral or written a communications that qualify so that other portions ofthe material, documents, 3 items, or communications for which protection is not warranted are not swept 4 unjustifiably within the ambit of this Order. 5 6 Mass, indiscriminate, or routinized designations are prohibited. Designations that are shown to be clearly unjustified or that have been made for an improper purpose (e.g., to unnecessarily encumber the case development process or to s impose unnecessary expenses and burdens on other parties) may expose the 9 Designating Party to sanctions. io ii 0 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 is promptly notify all other Parties that it is withdrawing the inapplicable designation. ONO a =~ Except as otherwise provided in na Manner and Timing of Desib. ~ ~, ~ 9 N •~ Q r 13 o ~_ ~w o 14 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise ~ ~v is stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 16 under this Order must be clearly so designated before the material is disclosed or i~ produced. is Designation in conformity with this Order requires: y C W ~d ~~ U. ..~ h ~ W ~ ~ ioa 3^ g~ 19 5.2 ( for information in documentary form (e.g., paper or electronic a) ao documents, but excluding transcripts of depositions or other pretrial or trial 21 proceedings), that the Producing Party affix at a minimum,the legend a2 CONFIDENTIAL"(hereinafter "CONFIDENTIAL legend"), to each page " 2 3 that contains protected material. If only a portion or portions ofthe material 4 2 on a page qualifies for protection, the Producing Party also must clearly as identify the protected portions)(e.g., by making appropriate markings in the 2 6 margins). a~ A Party or Non-Party that makes original documents available for inspection ~~:~ need not designate them for protection until after the inspecting Party has -6- STIPULATED PROTECTIVE ORDER AND [PROPOSED]ORDER Case x:17-cv-00244-PSG-AGR Document 17 Filed 03/17/17 Page 7 of 16 Page ID #:827 t indicated which documents it would like copied and produced. During the ~ ~ inspection and before the designation, all of the material made available for 3 inspection shall be deemed "CONFIDENTIAL." After the inspecting Party 4 has identified the documents it wants copied and produced, the Producing s Party must determine which documents, or portions thereof, qualify for 6 protection under this Order. Then, before producing the specified documents, the Producing Party must affix the "CONFIDENTIAL legend" to each page g that contains Protected Material. If only a portion or portions of the material 9 on a page qualifies for protection, the Producing Pariy also must clearly io ii margins). 12 0 identify the protected portions) (e.g., by making appropriate markings in the (b) for testimony given in depositions that the Designating Party identify the 13 Disclosure or Discovery Material on the record, before the close of the 14 deposition all protected testimony. 15 (c) for information produced in some form other than documentary and for 16 any other tangible items, that the Producing Party affix in a prominent place i~ on the exterior of the container or containers in which the information is ig stored the legend "CONFIDENTIAL." If only a portion or portions of the i9 information warrants protection, the Producing Party, to the extent ao practicable, shall identify the protected portion(s). 21 5.3 O N O a «; ~~ 9N ~ Q ~' ~C d o ~w o ~~ du o„ U. ~d ..~ N ~ W A ~ ~oa g~ Inadvertent Failures to Designate. If timely corrected, an inadvertent as failure to designate qualified information or items does not, standing alone, waive 23 the Designating Party's right to secure protection under this Order for such 2 4 material. Upon timely correction of a designation, the Receiving Party must make 25 reasonable efforts to assure that the material is treated in accordance with the 2 6 provisions of this Order. 27 f •F;~ ► -7- STIPULATED PROTECTIVE ORDER AND [PROPOSED] ORDER Case ; x:17-cv-00244-PSG-AGR Document 17 Filed 03/17/17 Page 8 of 16 Page ID #:828 i 6 . a CHALLENGING CONFIDENTIALITY DESIGNATIONS 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 3 designation of confidentiality at any time that is consistent with the Court's 4 Scheduling Order.. 5 6 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 s the Designating Party. Frivolous challenges, and those made for an improper 9 purpose (e.g., to harass or impose unnecessary expenses and burdens on other io ii Party has waived or withdrawn the confidentiality designation, all parties shall 12 0 parties) may expose the Challenging Party to sanctions. Unless the Designating continue to afford the material in question the level of protection to which it is 13 entitled under the Producing Party's designation until the Court rules on the 14 challenge. 15 7 . ON O a =' ~ = N ~ 9 "' ~, Q 'C O `0 D hA p ~~ U ~d ~ N 16 W ~ ioa g~ ACCESS TO AND USE OF PROTECTED MATERIAL 7.1 Basic Principles. A Receiving Party may use Protected Material that is i~ disclosed or produced by another Party or by a Non-Party in connection with this is Action only for prosecuting, defending, or attempting to settle this Action. Such i9 Protected Material may be disclosed only to the categories of persons and under the Zo conditions described in this Order. When the Action has been terminated, a ai Receiving Party must comply with the provisions of section 13 below(FINAL a2 DISPOSITION). 2 3 Protected Material must be stored and maintained by a Receiving Party at a 2 4 location and in a secure manner that ensures that access is limited to the persons 25 authorized under this Order. 2 6 2~ 7 .2 Disclosure of"CONFIDENTIAL"Information or Items. Unless otherwise ordered by the court or permitted in writing by the Designating Party, a 2 8 -8- STIPULATED PROTECTIVE ORDER AND [PROPOSED]ORDER Case x:17-cv-00244-PSG-AGR Document 17 Filed 03/17/17 Page 9 of 16 Page ID #:829 Receiving Party may disclose any information or item designated a CONFIDENTIAL" only to: " 3 ( the Receiving Party's Outside Counsel of Record in this Action, as well a) : ~ as employees of said Outside Counsel of Record to whom it is reasonably 5 6 necessary to disclose the information for this Action; ( the officers, directors, and employees (including House Counsel) ofthe b) Receiving Party to whom disclosure is reasonably necessary for this Action; a 9 ( Experts (as defined in this Order) ofthe Receiving Party to whom c) disclosure is reasonably necessary for this Action and who have signed the io Acknowledgment and Agreement to Be Bound"(Exhibit A); " ii ( the court and its personnel; d) 12 ( court reporters and their staff; e) a"~ 13 ( professional jury or trial consultants, mock jurors, and Professional ~ o ~_ ~w 14 Vendors to whom disclosure is reasonably necessary for this Action and who o„ is have signed the "Acknowledgment and Agreement to Be Bound"(Exhibit 0 ONO o~ ~ ~ y'c o ~ dv U ~d N ~ ' u W A ~ ioa 3~ 5~ 16 A~ 7 t~ is 19 ( the author or recipient of a document containing the information or a g) custodian or other person who otherwise possessed or knew the information; ( during their depositions, witnesses ,and attorneys for witnesses, in the h) ao Action to whom disclosure is reasonably necessary provided:(1)the 21 deposing party requests that the witness sign the form attached as E~ibit 1 as hereto; and (2)they will not be permitted to keep any confidential 23 information unless they sign the "Acknowledgment and Agreement to Be 2 4 Bound"(E~ibit A), unless otherwise agreed by the Designating Party or as ordered by the court. Pages oftranscribed deposition testimony or exhibits to 2 6 depositions that reveal Protected Material may be separately bound by the 2~ court reporter and may not be disclosed to anyone except as permitted under Zs this Stipulated Protective Order; and -9- STIPULATED PROTECTIVE ORDER AND [PROPOSED]ORDER Case ~:I17-cv-00244-PSG-AGR Document 17 Filed 03/17/17 Page 10 of 16 Page ID #:830 1 (i) any mediator or settlement officer, and their supporting personnel, 2 mutually agreed upon by any ofthe parties engaged in settlement 3 discussions. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 4 8. 5 IN OTHER LITIGATION If a Party is served with a subpoena or a court order issued in other litigation 6 ~ that compels disclosure of any information or items designated in this Action as 8 "CONFIDENTIAL," that Party must: 9 to (a) promptly notify in writing the Designating Party. Such notification shall 11 (b)promptly notify in writing the party who caused the subpoena or order to 0 12 issue in the other litigation that some or all ofthe material covered by the N 9;,•~ a 13 subpoena or order is subject to this Protective Order. Such notification shall o ~~ o~W~ ~ 14 include a copy of this Stipulated Protective Order; and 15 (c)cooperate with respect to all reasonable procedures sought to be pursued ~W~ 16 by the Designating Party whose Protected Material may be affected. 17 If the Designating Party timely seeks a protective order, the Party served include a copy ofthe subpoena or court order; ~ ~oa g~ 18 19 with the subpoena or court order shall not produce any information designated in this action as "CONFIDENTIAL" before a determination by the court from which 20 21 the subpoena or order issued, unless the Party has obtained the Designating Party's 22 protection in that court of its confidential material and nothing in these provisions 23 24 should be construed as authorizing or encouraging a Receiving Party in this Action to disobey a lawful directive from another court. 25 9. 26 PRODUCED IN THIS LITIGATION 27 28 permission. The Designating Party shall bear the burden and expense of seeking ANON-PARTY'S PROTECTED MATERIAL SOUGHT TO BE (a) The terms of this Order are applicable to information produced by a NonParty in this Action and designated as "CONFIDENTIAL." Such information -io- STIPULATED PROTECTIVE ORDER AND [PROPOSED]ORDER 7-cv-00244-PSG-AGR Document 17 Filed 03/17/17 Page 11 of 16 Page ID #:831 Case 1 produced by Non-Parties in connection with this litigation is protected by the 2 remedies and relief provided by this Order. Nothing in these provisions should be 3 construed as prohibiting allon-Party from seeking additional protections. (b)In the event that a Party is required, by a valid discovery request, to 4 5 produce allon-Party's confidential information in its possession, and the Party is 6 subject to an agreement with the Non-Party not to produce the Non-Party's ~ confidential information, then the Party shall: (1) promptly notify in writing the Requesting Party and the Non-Party 8 9 that some or all ofthe information requested is subject to a confidentiality to agreement with allon-Party; 11 (2) promptly provide the Non-Party with a copy ofthe Stipulated 12 Protective Order in this Action, the relevant discovery request(s), and a reasonably 13 specific description ofthe information requested; and O ~'O a r ~+ N ; ~~` 0 o ~= 14 Wd~ 15 W~ 16 (3) make the information requested available for inspection by the Non-Party, if requested. (c)If the Non-Party fails to seek a protective order from this court within 14 D ioa g~ 17 days of receiving the notice and accompanying information, the Receiving Party 1g may produce the Non-Party's confidential information responsive to the discovery 19 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 20 not produce any information in its possession or control that is subject to the 21 confidentiality agreement with the Non-Party before a determination by the court. 22 Absent a court order to the contrary, the Non-Party shall bear the burden and 23 expense of seeking protection in this court of its Protected Material. 24 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 25 If a Receiving Party learns that, by inadvertence or otherwise, it has 26 disclosed Protected Material to any person or in any circumstance not authorized 27 under this Stipulated Protective Order, the Receiving Party must immediately(a) 28 notify in writing the Designating Party of the unauthorized disclosures,(b)use its -iiSTIPULATED PROTECTIVE ORDER AND [PROPOSED]ORDER Case ~:~17-cv-00244-PSG-AGR Document 17 Filed 03/17/17 Page 12 of 16 Page ID #:832 i best efforts to retrieve all unauthorized copies of the Protected Material,(c)inform 2 the person or persons to whom unauthorized disclosures were made of all the terms 3 ofthis Order, and (d)request such person or persons to execute the 4 " Acknowledgment and Agreement to Be Bound" that is attached hereto as Exhibit 5 6 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED MATERIAL s 9 When a Producing Party gives notice to Receiving Parties that certain inadvertently produced material is subject to a claim of privilege or other io ii 0 protection, the obligations ofthe Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 12 whatever procedure may be established in an e-discovery order that provides for 13 production without prior privilege review. Pursuant to Federal Rule of Evidence 14 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure is of a communication or information covered by the attorney-client privilege or work 16 product protection, the parties may incorporate their agreement in the stipulated i~ protective order submitted to the court. is 12. ONO a ~~ o~ H ~ y'c D N '~ yv W `C U ~d N~ LL W ~ D ina 3^ 5~ 19 Zo 21 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. 12.2 Right to Assert Other Objections. By stipulating to the entry of this Za Protective Order no Party waives any right it otherwise would have to object to 23 disclosing or producing any information or item on any ground not addressed in 2 4 this Stipulated Protective Order. Similarly, no Party waives any right to object on 25 any ground to use in evidence of any of the material covered by this Protective 2 6 Order. 2~ as 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 - ~zSTIPULATED PROTECTIVE ORDER AND [PROPOSED]ORDER Case ;~:~17-cv-00244-PSG-AGR Document 17 Filed 03/17/17 Page 13 of 16 Page ID #:833 may only be filed under seal pursuant to a court order authorizing the sealing of the specific Protected Material at issue. If a Party's request to file Protected Material under seal is denied by the court, then the Receiving Party may file the information in the public record unless otherwise instructed by the court. 12.4 Any violation of this Order may be punished by any and all 6 appropriate measures including, without limitation, contempt proceedings and/or monetary sanctions. 13. 9 io ii o is ONO a ='~ ~, 13 ~ a~ 14 o~W c is N ~ ~'~ U ~d N ~° 16 ~ N W D ~oa g~ i~ is i9 Zo ai 22 FINAL DISPOSITION After the final disposition of this Action, as defined in paragraph 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 ofthe 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 ofthe 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 4 2 and trial exhibits, expert reports, attorney work product, and consultant and expert work product, even if such materials contain Protected Material. Any such archival as copies that contain or constitute Protected Material remain subject to this 6 2 Protective Order as set forth in Section 4(DURATION). 23 27 28 -13- STIPULATED PROTECTIVE ORDER AND [PROPOSED]ORDER Case ~k17-cv-00244-PSG-AGR Document 17 Filed 03/17/17 Page 14 of 16 Page ID #:834 14. Any violation ofthis Order may be punished by any and all appropriate 2 measures including, without limitation, contempt proceedings and/or monetary 3 sanctions. 4 s IT IS SO STIPULATED,THROUGH COUNSEL OF RECORD. 6 DATE: March 17, 2017 LAW OFFICE OF DONALD POTTER g 9 10 B}r: Donald P r Milan Moore Attorneys for Plaintiff, ANTHONY LUNA,an individual i~ ~2 ~~o 9,~ ~ ~ o ~ ~ 0 ~~ 13 14 IS DATE: March 17, 2017 REED SMITH LLP 16 gF t~ is By: /s/Rafael N. Tumanvan Tiffany Renee Thomas Rafael N. Tumanyan Attorneys for Defendant, RICOH USA,INC. 19 20 it a2 23 2 4 Zs 2 6 27 IT IS SO ORDERED. D ATED: 3IZ0 ~ ~~ ~1,;~-~-~-- .--~--- UNITED STATES MAGI TRATE JU~r 8 2 -14- STIPULATED PROTECTIVE ORDER AND(PROPOSED ORDER Case ~:~17-cv-00244-PSG-AGR Document 17 Filed 03/17/17 Page 15 of 16 Page ID #:835 I~:~OII:~Yr:1 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 2 3 [print or type full name], of I , 4 [print or type full address], declare under penalty of perjury s thatIhave read in its entirety and understand the Stipulated Protective Order that 6 was issued by the United States District Court for the Central District of California on [date] in the case of [insert formal name of the case and the s number and initials assigned to it by the court].Iagree to comply with and to be ►~ bound by all the terms of this Stipulated Protective Order andIunderstand and io acknowledge that failure to so comply could expose me to sanctions and ii punishment in the nature of contempt.Isolemnly promise thatIwill not disclose in iz any manner any information or item that is subject to this Stipulated Protective a =' ~ 13 Order to any person or entity except in strict compliance with the provisions of this o~0 14 Order. o ONO ~~ 9 ~ ~, a ~ •D Nm p d~ 15 W l7 c `y ~ g N W Ifurther agree to submit to the jurisdiction of the United States District Court for 16 the Central District of California for the purpose of enforcing the terms of this 17 Stipulated Protective Order, even if such enforcement proceedings occur after is termination of this action.Ihereby appoint i9 or type full name] of ao type full address and telephone number] as my California agent for service of 21 process in connection with this action or any proceedings related to enforcement of 22 this Stipulated Protective Order. 23 1 1 Date: 24 City and State where sworn and signed: Zs Printed name: 26 Signature: ~ ~oa n [print [print or 27 28 -15- STIPULATED PROTECTIVE ORDER AND [PROPOSED] ORDER Case ~~17-cv-00244-PSG-AGR Document 17 Filed 03/17/17 Page 16 of 16 Page ID #:836 PROOF OF SERVICE I am employed in the County ofLos Angeles, State of California. I am over the a e of 18 and not a to the instant action. My business address is: LAW OFFICE~F DONALD POE ,776 East Green Street, Suite 210,Pasadena, California 91101. 4 On March 17, 2017,I served the following documents)described as: STIPULATED PROTECTIVE ORDER 6 on the interested parties in this action, by placing a true copy thereof in a sealed envelope addressed as follows: Tiffany R. Thomas,Esq. Rafael N.Tumanyan,Esq. 9 REED SMITH LLP 355 South Grand Avenue, Suite 2900 to Los Angeles, California 90071 >> Attorneysfor Defendants 0 12 ~~s 13 . ~ 14 c 0 15 ~~~ 16 o ~, ( FACSIMILE)to BY ;and, ( PERSONAL SERVICE)I caused such envelopes)to be delivered by BY ~~to the above addressee(s). an 17 g~ BY ( ELECTRO1vIC MAIL)I caused said documents)to be transmitted to ti mail addresses)ofthe addressees)designated X (BY MAIL)and personally placing such envelope with postage fully prepaid aor collection and mailing on the above-referenced date following the ordinary is practices ofthis office. I am readily familiar with our office's practice for collection 19 and processing of comespondence for mailin with the United States Postal Service. In the ordinary course of business correspondence including said envelope, will be 20 deposited with the United States postal Service at ~'asadena, CA on the above referenced date. z~ I declare under penalty of perjury that the foregoing is true and correct under the z2 laws oftie State of California. Executed March 17, 2017 at Pasadena, California. 23 2 4 25 2 6 27 2 8 Jessica Parra

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