Apollo Enterprise Solutions, Inc. v. Lantern Credit, LLC et al
Filing
53
PROTECTIVE ORDER by Magistrate Judge Jacqueline Chooljian. (see order for details) 52 (klg)
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David M. Stein (State Bar No. 198256)
dstein@ggtriallaw.com
Andrew M. Purdy (State Bar No. 261912)
apurdy@ggtriallaw.com
Jamie E. Sutton (State Bar No. 312853)
jsutton@ggtriallaw.com
GREENBERG GROSS LLP
650 Town Center Drive, Suite 1700
Costa Mesa, California 92626
Phone: 949.383.2800
Fax: 949.383.2801
Aluyah I. Imoisili (State Bar No. 245572)
aimoisili@ggtriallaw.com
GREENBERG GROSS LLP
601 South Figueroa Street, 30th Floor
Los Angeles, California 90017
Phone: 213.334.7000
Fax: 213.334.7001
Attorneys for Defendant and
Counterclaimant
LANTERN CREDIT, LLC
F/K/A NEW ENGLAND FUNDING
TECHNOLOGIES, LLC
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UNITED STATES DISTRICT COURT
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CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION
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APOLLO ENTERPRISE SOLUTIONS,
INC., a California corporation,
Plaintiff,
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v.
LANTERN CREDIT, LLC, F/K/A
NEW ENGLAND FUNDING
TECHNOLOGIES, LLC, a Delaware
limited liability corporation; and DOES
1-10, inclusive,
Case No. 2:17-CV-02331-AB-JC
DISCOVERY MATTER –
STIPULATION AND PROTECTIVE
ORDER
Judge: Hon. André Birotte Jr.
Magistrate: Hon. Jacqueline Chooljian
Defendant.
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STIPULATION AND PROTECTIVE ORDER
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1.
A. PURPOSES AND LIMITATIONS
As the parties have represented that discovery in this action is likely to
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involve production of confidential, proprietary, or private information for which
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special protection from public disclosure and from use for any purpose other than
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prosecuting this litigation may be warranted, this Court enters the following
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Protective Order. This Order does not confer blanket protections on all disclosures
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or responses to discovery. The protection it affords from public disclosure and use
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extends only to the limited information or items that are entitled to confidential
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treatment under the applicable legal principles. Further, as set forth in Section 12.3,
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below, this Protective Order does not entitle the parties to file confidential
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information under seal. Rather, when the parties seek permission from the court to
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file material under seal, the parties must comply with Civil Local Rule 79-5 and
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with any pertinent orders of the assigned 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
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to 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
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in a confidential, non-public manner, and that there is good cause or a compelling
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reason why it should not be part of the public record of this case.
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STIPULATION AND PROTECTIVE ORDER
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2.
DEFINITIONS
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2.1
Action: The instant action: Apollo Enterprise Solutions, Inc. v.
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Lantern Credit, LLC, Case No. 2:17-CV-02331-AB-JC.
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
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protection under Federal Rule of Civil Procedure 26(c), and as specified above in
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the Good Cause Statement.
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2.4
“HIGHLY CONFIDENTIAL -- ATTORNEYS’ EYES ONLY”
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Information or Items: extremely sensitive “CONFIDENTIAL” Information or
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Items, the disclosure of which to another Party or Non-Party would create a
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substantial risk of serious harm that could not be avoided by less restrictive means.
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2.5
Counsel: Outside Counsel of Record and House Counsel (as well as
their support staff).
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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” or “HIGHLY CONFIDENTIAL -- ATTORNEYS’ EYES
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ONLY.”
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2.7
Disclosure or Discovery Material: all items or information, regardless
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of the medium or manner in which it is generated, stored, or maintained (including,
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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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2.8
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
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an expert witness or as a consultant in this Action.
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2.9
House Counsel: attorneys who are employees of a party to this Action.
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STIPULATION AND PROTECTIVE ORDER
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House Counsel does not include Outside Counsel of Record or any other outside
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counsel.
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2.10 Non-Party: any natural person, partnership, corporation, association, or
other legal entity not named as a Party to this action.
2.11 Outside Counsel of Record: attorneys who are not employees of a
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party to this Action but are retained to represent or advise a party to this Action and
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have appeared in this Action on behalf of that party or are affiliated with a law firm
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which has appeared on behalf of that party, and includes support staff.
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2.12 Party: any party to this Action, including all of its officers, directors,
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employees, consultants, retained experts, and Outside Counsel of Record (and their
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support staffs).
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2.13 Producing Party: a Party or Non-Party that produces Disclosure or
Discovery Material in this Action.
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2.14 Professional Vendors: persons or entities that provide litigation
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support services (e.g., photocopying, videotaping, translating, preparing exhibits or
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demonstrations, and organizing, storing, or retrieving data in any form or medium)
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and their employees and subcontractors.
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2.15 Protected Material: any Disclosure or Discovery Material that is
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designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL --
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ATTORNEYS’ EYES ONLY.”
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2.16 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
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STIPULATION AND PROTECTIVE ORDER
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Counsel that might reveal Protected Material, other than during a court hearing or at
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trial.
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Any use of Protected Material during a court hearing or at trial shall be
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governed by the orders of the presiding judge. This Order does not govern the use
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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
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this Order must take care to limit any such designation to specific material that
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qualifies under the appropriate standards. The Designating Party must designate for
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protection only those parts of material, documents, items, or oral or written
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communications that qualify so that other portions of the material, documents,
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items, or communications for which protection is not warranted are not swept
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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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STIPULATION AND PROTECTIVE ORDER
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unnecessary expenses and burdens on other parties) may expose the Designating
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Party 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.
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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.
Designation in conformity with this Order requires:
(a) for information in documentary form (e.g., paper or electronic
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documents, but excluding transcripts of depositions), that the Producing Party affix
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at a minimum, the legend “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL --
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ATTORNEYS’ EYES ONLY” to each page that contains protected material. If
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only a portion or portions of the material on a page qualifies for protection, the
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Producing Party also must clearly identify the protected portion(s) (e.g., by making
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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
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before the designation, all of the material made available for inspection shall be
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deemed “CONFIDENTIAL.” After the inspecting Party has identified the
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documents it wants copied and produced, the Producing Party must determine which
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documents, or portions thereof, qualify for protection under this Order. Then,
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before producing the specified documents, the Producing Party must affix the
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“CONFIDENTIAL”, or “HIGHLY CONFIDENTIAL -- ATTORNEYS’ EYES
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STIPULATION AND PROTECTIVE ORDER
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ONLY” legend to each page that contains Protected Material. If only a portion or
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portions of the material on a page qualifies for protection, the Producing Party also
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must clearly identify the protected portion(s) (e.g., by making appropriate markings
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in the margins).
(b) for testimony given in depositions that the Designating Party identifies
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on the record, before the close of the deposition as protected testimony.
(c) for information produced in some form other than documentary and
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for any other tangible items, that the Producing Party affix in a prominent place on
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the exterior of the container or containers in which the information is stored the
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legend “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL -- ATTORNEYS’
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EYES ONLY.” If only a portion or portions of the information warrants protection,
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the Producing Party, to the extent practicable, shall identify the protected portion(s).
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5.3
Inadvertent Failures to Designate. If timely corrected, an inadvertent
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failure to designate qualified information or items does not, standing alone, waive
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the 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.
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
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purpose (e.g., to harass or impose unnecessary expenses and burdens on other
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STIPULATION AND PROTECTIVE ORDER
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parties) may expose the Challenging Party to sanctions. Unless the Designating
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Party has waived or withdrawn the confidentiality designation, all parties shall
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continue to afford the material in question the level of protection to which it is
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entitled under the Producing Party’s designation until the Court rules on the
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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
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Receiving Party must comply with the provisions of Section 13 below.
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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
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“CONFIDENTIAL” 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
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the Receiving Party to whom disclosure is reasonably necessary for this Action;
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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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STIPULATION AND PROTECTIVE ORDER
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(d) the court and its personnel;
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(e) private court reporters and their staff to whom disclosure is reasonably
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necessary for this Action and who have signed the “Acknowledgment and
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Agreement to Be Bound” (Exhibit A);
(f) professional jury or trial consultants, mock jurors, and Professional
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Vendors to whom disclosure is reasonably necessary for this Action and who have
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signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
(g) the author or recipient of a document containing the information or a
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custodian or other person who otherwise possessed or knew the information;
(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 “Acknowledgment and Agreement to Be Bound”
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(Exhibit A); and (2) they will not be permitted to keep any confidential information
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unless they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A),
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unless otherwise agreed by the Designating Party or ordered by the court. Pages of
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transcribed deposition testimony or exhibits to depositions that reveal Protected
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Material may be separately bound by the court reporter and may not be disclosed to
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anyone except as permitted under this Protective Order; and
(i) any mediator or settlement officer, and their supporting personnel,
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mutually agreed upon by any of the parties engaged in settlement discussions.
7.3
Disclosure of “HIGHLY CONFIDENTIAL -- ATTORNEYS’ EYES
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ONLY” Information or Items. Unless otherwise ordered by the court or permitted in
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writing by the Designating Party, a Receiving Party may disclose any information or
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item designated “CONFIDENTIAL” 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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STIPULATION AND PROTECTIVE ORDER
(b) 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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(c) the court and its personnel;
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(d) private court reporters and their staff to whom disclosure is reasonably
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necessary for this Action and who have signed the “Acknowledgment and
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Agreement to Be Bound” (Exhibit A);
(e) professional jury or trial consultants, mock jurors, and Professional
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Vendors to whom disclosure is reasonably necessary for this Action and who have
signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
(f) the author or recipient of a document containing the information or a
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custodian or other person who otherwise possessed or knew the information; and
(g) any mediator or settlement officer, and their supporting personnel,
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mutually agreed upon by any of the parties engaged in settlement discussions.
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 order
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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
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a copy of this Protective Order; and
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(c) cooperate with respect to all reasonable procedures sought to be
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STIPULATION AND PROTECTIVE ORDER
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pursued by the Designating Party whose Protected Material may be affected.
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” or “HIGHLY CONFIDENTIAL -- ATTORNEYS’
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EYES ONLY” before a determination by the court from which the subpoena or
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order issued, unless the Party has obtained the Designating Party’s permission, or
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unless otherwise required by the law or court order. The Designating Party shall
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bear the burden and expense of seeking protection in that court of its confidential
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material and nothing in these provisions should be construed as authorizing or
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encouraging a Receiving Party in this Action to disobey a lawful directive from
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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 a
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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, 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
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agreement with a Non-Party;
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(2) promptly provide the Non-Party with a copy of the Protective
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STIPULATION AND PROTECTIVE ORDER
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Order in this Action, the relevant discovery request(s), and a reasonably specific
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description of the information requested; and
(3) make the information requested available for inspection by the
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Non-Party, if requested.
(c) If a Non-Party represented by counsel fails to commence the process
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called for by Local Rules 45-1 and 37-1, et seq. within 14 days of receiving the
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notice and accompanying information or fails contemporaneously to notify the
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Receiving Party that it has done so, the Receiving Party may produce the Non-
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Party’s confidential information responsive to the discovery request. If an
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unrepresented 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
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may produce the Non-Party’s confidential information responsive to the discovery
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request. If the Non-Party timely seeks a protective order, the Receiving Party shall
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not produce any information in its possession or control that is subject to the
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confidentiality agreement with the Non-Party before a determination by the court
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unless otherwise required by the law or court order. Absent a court order to the
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contrary, the Non-Party shall bear the burden and expense of seeking protection in
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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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Protective Order, the Receiving Party must immediately (a) notify in writing the
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Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve
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all unauthorized copies of the Protected Material, (c) inform the person or persons to
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whom unauthorized disclosures were made of all the terms of this Order, and
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(d) request such person or persons to execute the “Acknowledgment and Agreement
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to Be Bound” (Exhibit A).
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STIPULATION AND PROTECTIVE ORDER
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11.
OTHERWISE PROTECTED MATERIAL
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INADVERTENT PRODUCTION OF PRIVILEGED OR
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
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procedure may be established in an e-discovery order that provides for production
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without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and
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(e), insofar as the parties reach an agreement on the effect of disclosure of a
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communication or information covered by the attorney-client privilege or work
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product protection, the parties may incorporate their agreement into this Protective
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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.
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12.2 Right to Assert Other Objections. No Party waives any right it
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otherwise would have to object to disclosing or producing any information or item
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on any ground not addressed in this Protective Order. Similarly, no Party waives
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any right to object on any ground to use in evidence of any of the material covered
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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 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
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in the public record unless otherwise instructed by the court.
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13.
FINAL DISPOSITION
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After the final disposition of this Action, as defined in Section 4, within 60
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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
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this 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
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Material. Whether the Protected Material is returned or destroyed, the Receiving
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Party must submit a written certification to the Producing Party (and, if not the same
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person or entity, to the Designating Party) by the 60 day deadline that (1) identifies
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(by category, where appropriate) all the Protected Material that was returned or
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destroyed and (2) affirms that the Receiving Party has not retained any copies,
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abstracts, compilations, summaries or any other format reproducing or capturing any
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of the Protected Material. Notwithstanding this provision, Counsel are entitled to
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retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing
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transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
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reports, attorney work product, and consultant and expert work product, even if such
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materials contain Protected Material. Any such archival copies that contain or
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constitute Protected Material remain subject to this Protective Order as set forth in
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Section 4.
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14.
Any violation of this Order may be punished by any and all appropriate
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measures including, without limitation, contempt proceedings and/or monetary
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sanctions.
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STIPULATION AND PROTECTIVE ORDER
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SO STIPULATED:
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Dated: January 22, 2018
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GREENBERG GROSS LLP
By: /s/ David M. Stein
David M. Stein
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Attorneys for Defendant and
Counterclaimant LANTERN CREDIT,
LLC F/K/A NEW ENGLAND
FUNDING TECHNOLOGIES, LLC
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Dated: January 23, 2018
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JEFFER MANGELS BUTLER &
MITCHELL LLP
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By:
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/s/ Stanley M. Gibson
Stanley M. Gibson
Attorneys for Plaintiff and
Counterdefendant
APOLLO ENTERPRISE SOLUTIONS,
INC.
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APPROVED AND SO ORDERED:
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Dated: January 24, 2018
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___________/s/______________
Honorable Jacqueline Chooljian
United States Magistrate Judge
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STIPULATION AND PROTECTIVE ORDER
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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
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that I have read in its entirety and understand the Protective Order that was issued
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by the United States District Court for the Central District of California on January
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24, 2018, in the case of Apollo Enterprise Solutions, Inc. v. Lantern Credit, LLC,
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Case No. 2:17-CV-02331-AB-JC. I agree to comply with and to be bound by all the
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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
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solemnly promise that I will not disclose in any manner any information or item that
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is subject to this Protective Order to any person or entity except in strict compliance
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with the 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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Protective Order, even if such enforcement proceedings occur after termination of
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this action. I hereby appoint __________________________ [print or type full
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name] of _______________________________________ [print or type full address
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and telephone number] as my California agent for service of process in connection
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with 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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STIPULATION AND PROTECTIVE ORDER
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