Michel Desta v. Wins Finance Holdings Inc. et al

Filing 54

DISCOVERY CONFIDENTIALITY ORDER - NOTE CHANGES MADE BY THE COURT by Magistrate Judge Alicia G. Rosenberg re Stipulation for Protective Order 52 . (see order for details) (hr)

~e 2:17-cv-02983-CAS-AGR Document 52-1 Filed 05/24/18 Page 1 of 17 Page ID ~

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UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA

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MICHEL DESTA,Individually and on
behalf of all others similarly situated,

Case No: 2:17-cv-02983-CAS-AGR

Plaintiffs,

CLASS ACTION

v.

ISCOVERY
CONFIDENTIALITY ORDER

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WINS FINANCE HOLDINGS INC.,
JIANMING HAO,RENHUI MU, AND
JUNFENG ZHAO,

Hon. Christina A. Snyder
t~~~T~ ~?~A~G~S N~AflE B'~' T4~E Ca~~;~

U~fendants.

IT iS SO ORDERED.
DATED: ~I ~ ao ~ g

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~HT'REAS, Lead Plaintiffs Brian

G~^~ '~
UNITED STATES MAGISTRATE JU ,~F

Raymond l~✓Ieiltor ~"Plaintiffs") and Defendant Wins Finance Holdings Inc.

"Wins", and together with Plaintiffs, the "Parties"), by and through their
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20 unde~~igned counsel, have stipulated and agreed, subject to the approval of the
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Court, that the protective order set forth below (the "Stipulated Protective Order"

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or "Order") shall govern the production and use of documents and information

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pro~,Tided during the course of discovery in the above-captioned action (the

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Action");
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Ti~EREFORE, IT IS I~EREBY ORDERED BY THE COURT, that any

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person subject to this Order, including without limitation, the individuals and

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entities described herein, shall adhere to the following terms, procedures, and

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conditions:
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Purpose and Limitations

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Disclosure and Discovery Material in this Action are likely to involve

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production of confidential, proprietary, or private information for which special
protection from public disclosure and from use for any purpose other than

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prosecuting this Action may be warranted. The Parties agree that documents or
information produced or exchanged in the course of this Action shall only be used
by the party or parties to whom the information is produced solely for the purpose
of this Action, in conformity with the terms of this Order, and shall not be used

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f any other purpose not directly related to this Action. Accordingly, the Parties
or
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hereby stipulate to and petition the court to enter the following Stipulated
Protective Order.

The Parries acknowledge that this Order does not confer

blanket protections on all disclosures or responses to discovery and that the

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protection it affords from public disclosure and use extends only to the

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inforrr~ation or items that are entitled to confidential treatment under the

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~pplicat~le legal principles.

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Generall~efinitivns.

For purposes of this Order, the terms

forth below are defined as follows:

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a.

"Confidential Discovery Material" shall mean Discovery Material

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contains rion-public information, regardless of the medium or manner in which it i

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generated, stored, or maintained, identified by the Designating Party in accordanc

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with this Order and that has been designated as "Confidential" because it contain

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non-public trade secret or other confidential, proprietary, financial, andio

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commercially sensitive data, including marketing, sales, research, development, o
planning information, in accordance with the standards developed under Federa
Rule of Civil procedure 26(c) and other applicable law.
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b.

"Designating Party" shah mean the Party or non-party that

~ Discovery Material as "Confidential."

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c.

"Discovery Material" shall mean and include, without limitati

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Documents, including Electronically Stored Information ("ESI"); responses

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interrogatories, requests for admissions, or other discovery requests; physic

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objects; samples; disks for digital media (such as CD-ROMs or DVDs); depositic

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transcripts and exhibits thereto; and information provided by or on behalf of tt

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Parties or any non-party pursuant to the Federal Rules of Civil Procedure, tt

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Local Rules of this Court, subpoena, or any formal or informal request in tY

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course of discovery in the Litigation.

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d.

"Document" or "Documents" shall mean and include, wi

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limitation, all written material and other tangible items produced in any forma

e.g., hard-copy, electronic, digital, etc.) in any medium e.g., haxdcopy, videotape
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CD-ROM, DVD, hard drive, etc.) defined as broadly as permitted under Federa
Rule of Civil Procedure 34.

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e.

"Party" or "Parties" shall mean any natural person who is a party

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this action; and Wins Finance Holdings Inc. (including its officers,

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employees, corporate parents, subsidiaries, affiliates, and insurers).

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"Producing Party" shall mean the Party or non-party produc

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Discovery Material.
g.

"Receiving Party" shall mean the Party receiving Discovery Materi

produced by a Producing Party.
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Scope of Order. This Order is intended to facilitate the Parties
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production of Discovery Material. 1~?othing in this Order shall be construed a~
expanding or limiting the Parties' discovery obligations. This Order covers the

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production and use of all Confidential Discovery Material in this Litigation.

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Nothing in this Order prevents counsel for the Parties from using Confidential

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Discovery Material in connection with work product created by or on behalf of that

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counsel. Such work product may be retained by counsel who created it. However.

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Confidential Discovery Material in such work product will remain Confidential

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Discovery Material that may not be shared with any entity or person or used in any

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way except as provided in this Order.

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I~esianating Confidential Discovery Material.

a.

All designations of Confidential Discovery Material shall be made

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good faith by the Besionating Party and, except as provided in ~ 5 and 11 10 below

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shall be made at or prior to the time of disclosure, production, or tender, provides

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that a Designating Party tnay designate as confd.ential Discovery Nlatel~ia
produced by another Party or non-party at any tirr~e within thirty (30) day:

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f
ollowing the Designating Party's receipt of such Discovery Material.
b.

The designation of Confidential Discovery Material may be made

marking or placing the legend "CONFIDENTIAL" on each page, or, in the case o
a document that is produced in native format, by placing the above-describes

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legend on a TIFF-placeholder image bearing the production number of tht

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document. Any visual or other non-paper or non-electronic Confidential Discover

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Material shall be designated on the exterior surface of the container or object tha

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contains it.
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c.

Prior to designating Discovery Material as "Confidential,"

Designating Party must make a bona fide determination that the Disco

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Material qualifies as Confidential Discovery Material.
d.

If a Receiving Party disputes the "Confidential" designation

Discovery Material, the following procedure shall apply:

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(
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Counsel for the objecting party shall serve on the Designatin

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Party a written objection to such designation within fourteen (14) days of receipt o

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the Confidential Discovery Material, which shall describe with particularity the

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documents or information in question and shall state the grounds for oUjection

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Counsel for the Designating Party shall respond in writing to such objection within

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fourteen (14) days, and shall state with particularity the grounds for asserting tha
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the document or information is confidential If no timely written response is rnadf

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to the objection, the challenged designation will be deemed to be void. If thf

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Designating Party or nonparty snakes a timely response to such objection asserting

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the pro~~riety of designation, counsel shall then confer in good faith in an effort tc

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resolve the dispute.
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2)

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If a dispute as to a confidential designation of a document

stein of information cannot be resolved by agreement, the Receiving Part
challenging the designation shall confer with the Producing Party or its counsel

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and attempt to resolve such disagreements before seeking the Court's resolution, a:

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provided by Local Civil Rule 37-1. The document or information that is the subjec

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of the filing shall be treated as originally designated pending resolution of thf

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dispute.
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Any document or inforrnation designated as Confidential Di

Material shall only be used, shown, or disclosed as provided in this Order.

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Use and Disclosure of Confidential Discovery Material.

a.

All Confidential Discovery Material shall be used by the receivi

party solely for purposes of the prosecution or defense of this action, shall not bf
used by the Receiving Party or Qualified Persons for any business, commercial

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competitive, personal, or other purpose, and shall not be disclosed by the

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Receiving Party or Qualified Persons to anyone other than those set forth below.

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unless and until the restrictions herein are removed either by written consent of the

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Designating Party or by Order of the Court. Trie persons or entities below to whirr

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Confidential Discovery Material are disclosed shall keep all such material, and any
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copies, notes, extracts, summaries, or descriptions of the same ~~itlun ~heil

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exclusive possession and control; shall treat all such copies, notes, extracts,

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summaries, or descriptions of the Con:idential Discovery Material as confidential;

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and shall take all necessary and prudent measure to maintain the confidentiality o

fi►,,'s ~~,r

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all Confidential Dis4overy Material in accordance with this Order. h0#'

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b.

Confidential Discovery Material may be disclosed only to "Qual_ifie

Persons" defined as:
(1)

Outside counsel and relevant in-house counsel for the Partie

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as well as employes of such outside counsel ot~ in-house counsel to whom it i

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reasonably necessary to disclose the information for the prosecution or defense c

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this litigation;

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~}-a ~-l~le. Co~elt
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Experts and consu~tants retained by or on behalf of the Partie

f the preparation or trial of this case. Confidential Discovery Material may n
or

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~ be disclosed to any experts or consultants retained by or on behalf the Parties un

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such experts or consultants have signed anon-disclosure agreement in the fon

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attached hereto as Exhibit A (signed copies of such agreements must be maintaine

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by counsel for the Party disclosing Confidential Discovery Material to the exp

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~ or consultant);

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Secretarial, paralegal, clerical, duplicating, and data process

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~ personnel ofthe foregoing;

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(
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The Court and court personnel, including court reporters

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~ record and/or transcribe deposition testimony;
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(
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Special masters and mediators and their employees;

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The original authors) or recipients) of the Confidentia

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Discovery Material;
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Any deponent provided that, if the deponent is not th

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Designating Party or employed by the Designating Party, the deponent shall b.

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made aware of the confidentiality restrictions of this Order and the Parties shal

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confer to ensure that appropriate confidentiality restrictions are maintained prior

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the deponent being shown any Confidential Discovery Material;

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(
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Litigation support consultants and vendors retained by or f

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the parties to assist in preparing for pretrial discovery, trial, and/or he

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including, but not limited to, court reporters, litigation support personnel, j

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consultants, individuals to prepare demonstrative and audiovisual aids for use
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~ the courtroom or in depositions or mock jury sessions, as well as their staff;
stenographic, and clerical employees whose duties and responsibilities requi

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~ access to such materials;
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9) The Parties, as defined above in ¶ l.e.; and
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10) Any person expressly named and agreed to in writing by
~ Designating Party or by Order ofthe Court.

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b.

Nothing herein shall limit a Producing Party's use of its

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c.

To the extent Confidential Discovery Material is attached to,

or referenced in Documents tiled with the Court, such Confidential

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Material is subject to the Court's requirements for filing documents under seal
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outlined in Paragraph 6 below.

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Designation of Deposition Testimony.

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a.

Deposition testimony that counsel for a Party or non-party wi

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tendering such testimony, in good faith, believes constitutes Confident

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Discovery Material may be designated as confidential by making a statement

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the record for inclusion in the deposition transcript or by written notice to

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Parties within thirty(30)calendar days after receipt of the transcript. All depositi

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testimony will be treated as having been designated confidential through t

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thirtieth (30th) day following each Party's receipt (through counsel or the coy

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reporter) of the transcript of such deposition testimony, after which time, only su

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testimony designated as confidential will be treated as Confidential Discove
Material.
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b.

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When Confidential Discovery 1~Iaterial is designated as Confidenti

in a deposition transcript, counsel on behalf of the Designating Party shall instruc
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the reporter to imprint a legend "CONTAINS CONFIDENTIAL INFORMATIO '

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on the cover page of the transcript and to include, at the front of the transcript,

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page identifying all pages and lines designated as "CONFIDENTIAL" in th

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transcript.

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c.

Any Court reporter or transcriber who reports or transcribes tes

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shall agree that anything designated as Confidential Discovery Material pursuant t

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this Order will be disclosed only in accordance with this Order, and that any note

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or transcriptions of such testimony (and any accompanying exhibits) will b

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retained by the reporter or delivered to counsel of record.
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d.

At the conclusion of any deposition taken in the case, any copies

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e~ibits used during the deposition that contain Confidential Discovery Materi~

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shall be collected and retained by the court reporter for the Parties. Nothing in thi

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paragraph shall prevent a deponent or a deponent's counsel from having reasonabl

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access to the deponent's deposition transcript for purposes of executing th

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transcript, preparing to testify further in this Litigation, or for other purpose

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specially agreed to by the parties.

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Filing Under Seal.

All requests to seal documents filed with th

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Court shall comply with Local Civil Rule 79-5.
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Discovery Material Received from Third Parties.

A Party wh

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receives documents or information from athird-party pursuant to a subpoena

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provide those documents or information to all other Parties within a reasona
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~ time or otherwise make reasonable provision for access to any such document
information.

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Conclusion of Litigation.

Within sixty (60) days of

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Litigation's conclusion (i.e., the date that any appeal deadlines have expired, or

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agreed to by the Parties), counsel for a Receiving Party who has recei`

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Confidential Discovery Material shall either: (1) return to the Producing Pariy 1

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Confidential Discovery Material; or (2) securely destroy the Confident

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Discovery Material and certify in writing that such destruction has occurred to 1

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Producing Party and Designating Party.

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Not Applicable to Trial.

This Order does not apply to the o

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of or admission into evidence of Confidential Discovery Material at trial or in ;

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evidentiary hearing, nor does it apply for any other purpose under the Fed

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Rules of Evidence. Such evidentiary issues should be raised as a separate ma

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upon the request of any Party at the time of trial or evidentiary hearing.

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10.

Inadvertent Production/Disclosure.

a.

Inadvertent production of any document that a Producing Party

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claims should not have been produced because of a privilege, including witho

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limitation the attorney-client privilege, the work product doctrine, or any oth

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applicable privilege or immunity from disclosure ("Inadvertently Product

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Privileged Document"), will not be deemed to waive such privilege or immuni

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rom disclosure. A Producing Party may, within ten (10) days of the date
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discovery by that Producing Party of the inadvertent production, request the retu:

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of any Inadvertently Produced Privileged Document by identifying the docume
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inadvertently produced and stating the basis for asserting a privilege over suc
document. In that event, each Receiving Party in possession of a copy of th

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Inadvertently Produced Privileged Document shall promptly (but in no event late
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than five (5) business days after receiving notice from the Producing Part;

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requesting rehirn) return or destroy the Inadvertently Produced Privilege

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Document and all copies thereof and shall, to the extent possible, expunge fron

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any other document material information derived solely from the Inadvertentl:

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Produced Privileged Document. If the Receiving Party determines that it seeks t~

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challenge the request for .return of the document, it shall contact the Producin;

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Party that inadvertently produced the document. If the Producing Party and the

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2eceiving Party camlot resolve the issue after good faith attempts, the Receiving
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Party shall raise the dispute with the Court in compliance with the Court's Loca

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Civil Rules and Orders) an Discovery Objections and Procedures. In accordance

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with Federal Rule of Civil Pracedure 26(b)(5)(B), in the event that the Re~eivin~

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Party seeks an order from the Court regarding an Inadvertently Produces

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Privileged Document, the Receiving Party may retain possession of the documen

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during the pendency of such application, provided that the document is sequesterec

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and is not used by the Receiving Party during that time except in connection with

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any application opposing the Producing Party's assertion that it inadvertently

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produced privileged documents. I~ the Receiving Party does not timely seek ar

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order from the Court regarding the Inadvertently Produced Privileged Document i

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shall promptly return or destroy the Inadvertently Produced Privileged Documen

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~ and shall, to the extent possible, e~:punge from any other document ma
information derived solely from the Inadvertently Produced Privileged Document.

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b.

Inadvertent failure to designate any Discovery Material a Produc

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Party later claims should have been designated as Confidential Discovery Materi~

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will not be deemed to waive such confidential status from the mistaken designatio

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A Producing Party may, within ten (10) days of the date of discovery by the

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Producing Party of the inadvertent designation, request the return of any suci

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inadvertently designated Discovery Material by identifying the Discovery Materia

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inadvertently designated. and stating the basis for designating such Discover

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Material as confidential. In that event, each Receiving Party in possession of ;

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copy of the mistakenly designated Discovery Material shall immediately treat tli~
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Discovery Material and all copies thereof as though it were designated a

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"
Confide.itial." ~n addition, the Producing Party shall provide a replacement o

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such Discovery Material to the Receiving Panty within ten (10) business days o

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notifying the Receiving Party of the mistaken designation. If the Receiving Part

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determ~ne~ that it seeks to challenge the request for designation and treatment o

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the Discovery Material as confidential, the Receiving Party shall make sucl

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challenge in accordance with Paragraph 3(c) above. The Designating Party shal

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remove the confidentiality designation from such Discovery Material, and provide

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a replacement of such Discovery material to the Receiving Party, within ten (10
business days of the entry of a court order striking the confidentiality designation.
11.

No Application to Public or Otherwise Available Information.

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No information that is in the public domain or which is already known
the Receiving Party through proper means or which is or becomes available to

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Party from a source other than the party asserting confidentiality, rightfully i~

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possession of such information on anon-confidential. basis, shall be deemed o

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considered to be confidential under this Order.

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12.

Protected Material

l or Qrdered Produced in Other

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Actions,

If a Receiving Party (or any person receiving documents through the

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Receiving Party) is served with a subpoena, order, interrogatory, document, or civi

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investigative demand, ~r any other- legal demand (collectively, a "Demand")issues

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in any other action, investigation, or proceeding, and such Demand seek.

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Confidential Discovery Material produced to the Receiving Party in this Litigation
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the Receiving Party shall dive prompt written notice by hand, overnight courier, n

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email within three (3) business days of receipt of such Demand and at least five (5

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days prior to tY~e deadline for the Receivi~ig Party's response to s~~ch Demand to thf

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Designating Party and, if' requested in writing by the Designating Party, shal

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pestpane producing docum~i~ts until such time as the Designating Party has timer

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f
iled a motion for a protective order and, the relevant court has ordered thf

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production of such documents. The burden of opposing the enforcement of thf

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Derriand shall fall upon the Designating Party. If the Designating Party obtains ar.

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order from any court or' administrative agency of competent jurisdiction directing

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that the Demand be complied with, it must serve such order upon the Receiving

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Party within at least three (3) business days of the order; the Receiving Party muss
then promptly comply with the terms of the order.
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13.

Modification

This Order may not be waived, modi

abandoned, or terminated, in whole or in part, except by an instrument in writi

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signed by all Parties, or by further Court Order. If the Court finds any provision o
this Order invalid for any reason, the remaining provisions shall remain in effect.
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Duration. At the close of this Litigation, this Order shall remain i

effect.

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This Order is binding upon the Parties here

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their atto~-~eys, and upon the Parties' and their attorneys' successors, executo
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persoYial ~•epr~sentat~ve~, administrators, heirs, legal representatives, assi

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subsidiaries, divisions, ~mployeEs, agenxs, independent contractors, ar
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persons oz ~rganiza.ti~ns over which they have control.
IT I5 SO S1 IPtTLATFD, 1'HiZOL7~I~ ~COU~TSEL; OF RECORD.
,

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Dated: May 24, 201 S

Respectfully submitted,
'
I'~-IE I~OSEl~1 L~VV FIRI~~, ~.A.
Bv: /s/ Laurence M. Rosen
Laurence M. Rosen(SBN 219683)
355 S. Grand Avenue, Suite 2450
Los Angeles, CA 90071
Telephone:[phone]
Facsimile:[phone]
Email: lrosen~cr~z~osenlegal.com
T IE ROSEN L,AW FIRM,P.A.
Yu Shi(pro hac vice)
275 Madison Ave, 34th Floor
New York, NY 10016
Telephone:[phone]
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Facsimile: [phone]
Email: [e-mail]

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Counselfor Lead Plaintiffs

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~ dated: May 24, 2018

LOEB & LOEB LLP
By: /s/ Jay K. Musoff
Jay K. Musoff(pro hac vice)
John Piskora (pro hac vice)
345 Park Avenue
New York, NY 10154
Telephone:[phone]
Facsimile: [phone]
Email:[e-mail]
[e-mail]

h
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LOEB & LOEB LLP
Daniel Murphy(SBN 141006)
Jennifer Jason(SBN 274142)
10100 Santa Monica Blvd, Suite 2200
Los Angeles, CA 90067
Telephone:[phone]
Facsimile:[phone]
Email: [e-mail]
j
[e-mail]

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IS
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Counselfog Defendant Wins Finance
Holdings Inc.

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ATTESTATION OF CONCURRENCE IN FILING
Pursuant to Local Rule 5-4.3.4 ofthe United States District Court for the
Central District of California, I attest that counsel for Defendant Wins Finance

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Holdings have authorized the filing ofthis document.
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/s/ Laurence M. Rosen

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rnvrrTnrm

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,being duly sworn, state that:
1.

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My address is

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My present employer is

and

~ the address of my present employment is

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.

My present occupation or job description is

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.

I have carefully read and understood the provisions ofthe Discovery

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Confidentiality Order in this case signed by the Court, and I will comply with all

12 ~ provisions ofthe Discovery Confidentiality Order.
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I will hold in confidence and not disclose to anyone not qualified

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under the Discovery Confidentiality Order any Confidential Discovery Material or
any words, summaries, abstracts, or indices of such material disclosed to me.

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.

I will limit use of Confidential Discovery Material disclosed to me

solely for purpose of this action.

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0
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No later than the final conclusion of the case, I will return all

Confidential Discovery Material and summaries, abstracts, and indices thereof
which come into my possession, and documents or things which I have prepared

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relating thereto, to counsel for the party for whom I was employed or retained.
I declare under penalty of perjury that the foregoing is true and correct.

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Dated:
[Name]
— 16—
[.~'~e~ese~-] Discovery Confidentiality Order

2:17-cv-02983-CAS-AGR Document 52-1 Filed 05/24/18 Page 17 of 17 Page
#
:848

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PURSUANT TO STIPULATION,IT IS SO ORDERED.

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DATED:

.2018

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C

Hon. Christina A. Snyder
United States District Judge

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— 17—
{~epese$] Discovery Confidentiality Order