Mario Ruiz et al v. Shamrock Foods Company
Filing
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ORDER APPROVING STIPULATED PROTECTIVE ORDER by Magistrate Judge Alexander F. MacKinnon. Re Stipulation for Protective Order 21 . (ib)
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UNITED STATES DISTRICT COURT
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CENTRAL DISTRICT OF CALIFORNIA
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MARIO RUIZ, RAUL GUERRERO,
and ROBERT TORRES on behalf of
themselves and all others similarly
situated,
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[PROPOSED] ORDER APPROVING
STIPULATED PROTECTIVE ORDER
Plaintiffs,
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CASE NO. 2:17-cv-06017-SVW-AFM
v.
Complaint Filed: August 14, 2017
SHAMROCK FOODS COMPANY,
an Arizona Corporation, and DOES
1 to 10, inclusive,
Trial Date:
None Set
Defendants.
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Based upon the parties’ stipulation and good cause showing, the court hereby
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issues the protective order on the following terms:
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1.
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A.
PURPOSES AND LIMITATIONS
Discovery in this action is likely to involve production of confidential,
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proprietary or private information for which special protection from public
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disclosure and from use for any purpose other than prosecuting this litigation may
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be warranted. Accordingly, the parties hereby stipulate to and petition the Court to
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enter the following Stipulated Protective Order. The parties acknowledge that this
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Order does not confer blanket protections on all disclosures or responses to
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discovery and that the protection it affords from public disclosure and use extends
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only to the limited information or items that are entitled to confidential treatment
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under the applicable legal principles.
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B.
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This action is likely to involve trade secrets, and confidential and proprietary
GOOD CAUSE STATEMENT
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information for which special protection from public disclosure and from use for
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any purpose other than prosecution of this action is warranted. Such confidential
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and proprietary materials and information consist of, among other things,
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[PROPOSED] ORDER APPROVING STIPULATED PROTECTIVE ORDER: CASE NO. 2:17-CV-06017
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confidential business or financial information, information regarding confidential
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business practices, or other confidential research, development, or commercial
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information (including information implicating privacy rights of employees and
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other third parties), information otherwise generally unavailable to the public, or
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which may be privileged or otherwise protected from disclosure under state or
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federal statutes, court rules, case decisions, or common law. Accordingly, to
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expedite the flow of information, to facilitate the prompt resolution of disputes over
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confidentiality of discovery materials, to adequately protect information the parties
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are entitled to keep confidential, to ensure that the parties are permitted reasonable
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necessary uses of such material in preparation for and in the conduct of trial, to
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address their handling at the end of the litigation, and serve the ends of justice, a
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protective order for such information is justified in this matter. It is the intent of the
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parties that information will not be designated as confidential for tactical reasons
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and that nothing be so designated without a good faith belief that it has been
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maintained in a confidential, non-public manner, and there is good cause why it
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should not be part of the public record of this case.
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C.
ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER
SEAL
The parties further acknowledge, as set forth in Section 12.3, below, that this
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Stipulated Protective Order does not entitle them to file confidential information
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under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed
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and the standards that will be applied when a party seeks permission from the court
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to file material under seal.
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There is a strong presumption that the public has a right of access to judicial
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proceedings and records in civil cases. In connection with non-dispositive motions,
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good cause must be shown to support a filing under seal. See Kamakana v. City and
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County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors
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Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics,
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[PROPOSED] ORDER APPROVING STIPULATED PROTECTIVE ORDER: CASE NO. 2:17-CV-06017
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Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders
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require good cause showing), and a specific showing of good cause or compelling
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reasons with proper evidentiary support and legal justification, must be made with
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respect to Protected Material that a party seeks to file under seal. The parties’ mere
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designation of Disclosure or Discovery Material as CONFIDENTIAL does not—
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without the submission of competent evidence by declaration, establishing that the
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material sought to be filed under seal qualifies as confidential, privileged, or
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otherwise protectable—constitute good cause.
Further, if a party requests sealing related to a dispositive motion or trial,
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then compelling reasons, not only good cause, for the sealing must be shown, and
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the relief sought shall be narrowly tailored to serve the specific interest to be
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protected. See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir.
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2010). For each item or type of information, document, or thing sought to be filed
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or introduced under seal in connection with a dispositive motion or trial, the party
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seeking protection must articulate compelling reasons, supported by specific facts
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and legal justification, for the requested sealing order. Again, competent evidence
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supporting the application to file documents under seal must be provided by
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declaration.
Any document that is not confidential, privileged, or otherwise protectable in
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its entirety will not be filed under seal if the confidential portions can be redacted.
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If documents can be redacted, then a redacted version for public viewing, omitting
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only the confidential, privileged, or otherwise protectable portions of the document,
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shall be filed. Any application that seeks to file documents under seal in their
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entirety should include an explanation of why redaction is not feasible.
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2.
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DEFINITIONS
2.1
Action: This pending class action in this Court entitled, Mario Ruiz,
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Raul Guerrero, and Robert Torres on behalf of themselves and all others similarly
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situated, v. Shamrock Foods Company, an Arizona Corporation, and DOES 1 to
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[PROPOSED] ORDER APPROVING STIPULATED PROTECTIVE ORDER: CASE NO. 2:17-CV-06017
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10, Case No. 2:17-cv-06017-SVW-AFM.
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
Counsel: Outside Counsel of Record and House Counsel (as well as
their support staff).
2.5
Designating Party: a Party or Non-Party that designates information or
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items that it produces in disclosures or in responses to discovery as
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“CONFIDENTIAL.”
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2.6
Disclosure or Discovery Material: all items or information, regardless
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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
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or generated in disclosures or responses to discovery in this matter.
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2.7
Expert: a person with specialized knowledge or experience in a matter
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pertinent to the litigation who has been retained by a Party or its counsel to serve as
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an expert witness or as a consultant in this Action.
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2.8
House Counsel: attorneys who are employees of a party to this Action.
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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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2.9
Non-Party: any natural person, partnership, corporation, association or
other legal entity not named as a Party to this action.
2.10 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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that has appeared on behalf of that party, and includes support staff.
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[PROPOSED] ORDER APPROVING STIPULATED PROTECTIVE ORDER: CASE NO. 2:17-CV-06017
2.11 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).
2.12 Producing Party: a Party or Non-Party that produces Disclosure or
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Discovery Material in this Action.
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2.13 Professional Vendors: persons or entities that provide litigation
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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.
2.14 Protected Material: any Disclosure or Discovery Material that is
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designated as “CONFIDENTIAL.”
2.15 Receiving Party: a Party that receives Disclosure or Discovery
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Material from a Producing Party.
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3.
SCOPE
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The protections conferred by this Stipulation and Order cover not only
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Protected Material (as defined above), but also (1) any information copied or
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extracted from Protected Material; (2) all copies, excerpts, summaries, or
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compilations of Protected Material; and (3) any testimony, conversations, or
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presentations by Parties or their Counsel that might reveal Protected Material.
Any use of Protected Material at trial shall be governed by the orders of the
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trial judge. This Order does not govern the use of Protected Material at trial.
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4.
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DURATION
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/or (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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[PROPOSED] ORDER APPROVING STIPULATED PROTECTIVE ORDER: CASE NO. 2:17-CV-06017
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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.
Once a case proceeds to trial, information that was designated as
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CONFIDENTIAL or maintained pursuant to this protective order used or
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introduced as an exhibit at trial becomes public and will be presumptively available
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to all members of the public, including the press, unless compelling reasons
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supported by specific factual findings to proceed otherwise are made to the trial
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judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing
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“good cause” showing for sealing documents produced in discovery from
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“compelling reasons” standard when merits-related documents are part of court
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record). Accordingly, the terms of this protective order do not extend to information
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used or introduced as an exhibit at trial.
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5.
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DESIGNATING PROTECTED MATERIAL
5.1
Exercise of Restraint and Care in Designating Material for Protection.
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Each Party or Non-Party that designates information or items for protection under
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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
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impose unnecessary expenses and burdens on other parties) may expose the
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Designating 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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[PROPOSED] ORDER APPROVING STIPULATED PROTECTIVE ORDER: CASE NO. 2:17-CV-06017
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promptly notify all other Parties that it is withdrawing the inapplicable designation.
5.2
Manner and Timing of Designations. Except as otherwise provided in
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this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
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stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
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under this Order must be clearly so designated before the material is disclosed or
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produced.
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Designation in conformity with this Order requires:
(a) for information in documentary form (e.g., paper or electronic
documents, but excluding transcripts of depositions or other pretrial or trial
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proceedings), that the Producing Party affix at a minimum, the legend
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“CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
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contains protected material. If only a portion of the material on a page qualifies for
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protection, the Producing Party also must clearly identify the protected portion(s)
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(e.g., by making appropriate markings in the margins).
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A Party or Non-Party that makes original documents available for inspection
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need not designate them for protection until after the inspecting Party has indicated
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which documents it would like copied and produced. During the inspection and
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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
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which 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 legend” to each page that contains Protected Material. If only a
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portion 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).
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(b) for testimony given in depositions that the Designating Party
identifies the Disclosure or Discovery Material on the record, within 30 days of
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[PROPOSED] ORDER APPROVING STIPULATED PROTECTIVE ORDER: CASE NO. 2:17-CV-06017
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receipt of the deposition transcript all 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.” If only a portion or portions of the information
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warrants protection, the Producing Party, to the extent practicable, shall identify the
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protected portion(s).
5.3
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Inadvertent Failures to Designate. If timely corrected upon discovery,
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an inadvertent failure to designate qualified information or items does not, standing
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alone, waive the Designating Party’s right to secure protection under this Order for
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such material. Upon timely correction of a designation, the Receiving Party must
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make reasonable efforts to assure that the material is treated in accordance with the
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provisions of this Order.
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6.
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CHALLENGING CONFIDENTIALITY DESIGNATIONS
6.1
Timing of Challenges. Any Party or Non-Party may challenge a
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designation of confidentiality at any time that is consistent with the Court’s
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Scheduling Order.
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6.2
Meet and Confer. The Challenging Party shall initiate the dispute
resolution process under Local Rule 37-1 et seq.
6.3
Joint Stipulation. Any challenge submitted to the Court shall be via a
joint stipulation pursuant to Local Rule 37-2.
6.4
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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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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[PROPOSED] ORDER APPROVING STIPULATED PROTECTIVE ORDER: CASE NO. 2:17-CV-06017
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challenge.
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7.
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ACCESS TO AND USE OF PROTECTED MATERIAL
7.1
Basic Principles. A Receiving Party may use Protected Material that is
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disclosed or produced by another Party or by a Non-Party in connection with this
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Action only for prosecuting, defending or attempting to settle this Action. Such
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Protected Material may be disclosed only to the categories of persons and under the
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conditions described in this Order. When the Action has been terminated, a
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Receiving Party must comply with the provisions of section 13 below (FINAL
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DISPOSITION).
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Protected Material must be stored and maintained by a Receiving Party at a
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location and in a secure manner that ensures that access is limited to the persons
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authorized under this Order.
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7.2
Disclosure of “CONFIDENTIAL” Information or Items. Unless
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otherwise ordered by the court or permitted in writing by the Designating Party, a
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Receiving Party may disclose any information or item designated
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“CONFIDENTIAL” only to:
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(a) where the Receiving Party is a named plaintiff, to other named
plaintiffs (Mario Ruiz, Raul Guerrero and/or Robert Torres) in this action;
(b) 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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(c) the officers, directors, and employees (including House Counsel) of
the Receiving Party to whom disclosure is reasonably necessary for this Action;
(d) 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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(e) the court and its personnel;
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(f) court reporters and their staff;
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[PROPOSED] ORDER APPROVING STIPULATED PROTECTIVE ORDER: CASE NO. 2:17-CV-06017
(g) 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);
(h) an individual who authored or has personal knowledge of that
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information provided that individual (1) has signed the form attached as Exhibit A
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hereto, and (2) is not permitted to keep any confidential information, unless
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otherwise agreed by the Designating Party or ordered by the court;
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(i) during their depositions, witnesses, and attorneys for witnesses, in
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the Action to whom disclosure is reasonably necessary provided: (1) the deposing
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party requests that the witness sign the form attached as Exhibit A hereto; and (2)
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they will not be permitted to keep any confidential information, unless otherwise
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agreed by the Designating Party or ordered by the court. Pages of transcribed
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deposition testimony or exhibits to depositions that reveal Protected Material may
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be separately bound by the court reporter and may not be disclosed to anyone
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except as permitted under this Stipulated Protective Order; and
(j) 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.
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Putative Class Member Information. Contact information and any
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other identifying information for putative class members provided in this action
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shall only be used for purposes of pre-class certification discovery in this action,
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and for no other reason. If the class is certified, however, the information may be
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used during the pendency of this action, but solely for the purpose of this litigation.
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8.
PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
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IN OTHER LITIGATION
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If a Party is served with a subpoena or a court order issued in other litigation
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that compels disclosure of any information or items designated in this Action as
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“CONFIDENTIAL,” that Party must:
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(a) promptly notify in writing the Designating Party. Such notification
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[PROPOSED] ORDER APPROVING STIPULATED PROTECTIVE ORDER: CASE NO. 2:17-CV-06017
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shall include a copy of the subpoena or court order;
(b) promptly notify in writing the party who caused the subpoena or
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order to issue in the other litigation that some or all of the material covered by the
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subpoena or order is subject to this Protective Order. Such notification shall include
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a copy of this Stipulated Protective Order; and
(c) cooperate with respect to all reasonable procedures sought to be
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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
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served with the subpoena or court order shall not produce any information
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designated in this action as “CONFIDENTIAL” before a determination by the court
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from which the subpoena or order issued, unless the Party has obtained the
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Designating Party’s permission. The Designating Party shall bear the burden and
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expense of seeking protection in that court of its confidential material and nothing
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in these provisions should be construed as authorizing or encouraging a Receiving
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Party in this Action to disobey a lawful directive from another court.
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9.
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A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
PRODUCED IN THIS LITIGATION
(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.” Such information
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produced by Non-Parties in connection with this litigation is protected by the
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remedies and relief provided by this Order. Nothing in these provisions should be
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construed as prohibiting a Non-Party from seeking additional protections.
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(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 NonParty that some or all of the information requested is subject to a confidentiality
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agreement with a Non-Party;
(2) promptly provide the Non-Party with a copy of the
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Stipulated Protective Order in this Action, the relevant discovery request(s), and a
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reasonably specific description of the information requested; and
(3) make the information requested available for inspection by
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the Non-Party, if requested.
(c) If the Non-Party fails to seek a protective order from this court
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within 14 days of receiving the notice and accompanying information, the
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Receiving Party may produce the Non-Party’s confidential information responsive
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to the discovery request. If the Non-Party timely seeks a protective order, the
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Receiving Party shall not produce any information in its possession or control that
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is subject to the confidentiality agreement with the Non-Party before a
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determination by the court. Absent a court order to the contrary, the Non-Party
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shall bear the burden and expense of seeking protection in this court of its Protected
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Material.
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10.
UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
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Protected Material to any person or in any circumstance not authorized under this
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Stipulated Protective Order, the Receiving Party must immediately (a) notify in
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writing the Designating Party of the unauthorized disclosures, (b) use its best
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efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the
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person or persons to whom unauthorized disclosures were made of all the terms of
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this Order, and (d) request such person or persons to execute the “Acknowledgment
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and Agreement to Be Bound” that is attached hereto as Exhibit A.
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11.
INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
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PROTECTED MATERIAL
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When a Producing Party gives notice to Receiving Parties that certain
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inadvertently produced material is subject to a claim of privilege or other
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protection, the obligations of the Receiving Parties are those set forth in Federal
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Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify
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whatever procedure may be established in an e-discovery order that provides for
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production without prior privilege review. Pursuant to Federal Rule of Evidence
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502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure
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of a communication or information covered by the attorney-client privilege or work
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product protection, the parties may incorporate their agreement in the stipulated
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protective order submitted to the court.
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12.
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. By stipulating to the entry of this
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Protective Order, no Party waives any right it otherwise would have to object to
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disclosing or producing any information or item on any ground not addressed in
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this Stipulated Protective Order. Similarly, no Party waives any right to object on
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any ground to use in evidence of any of the material covered by this Protective
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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 Local Civil Rule 79-5. Protected Material
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may 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.
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FINAL DISPOSITION
After the final disposition of this Action, as defined in paragraph 4, within 60
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days of a written request by the Designating Party, each Receiving Party must
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return all Protected Material to the Producing Party or destroy such material. As
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used in this subdivision, “all Protected Material” includes all copies, abstracts,
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[PROPOSED] ORDER APPROVING STIPULATED PROTECTIVE ORDER: CASE NO. 2:17-CV-06017
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compilations, summaries, and any other format reproducing or capturing any of the
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Protected Material. Whether the Protected Material is returned or destroyed, the
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Receiving Party must submit a written certification to the Producing Party (and, if
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not the same person or entity, to the Designating Party) by the 60 day deadline that
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(1) identifies (by category, where appropriate) all the Protected Material that was
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returned or destroyed and (2) affirms that the Receiving Party has not retained any
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copies, abstracts, compilations, summaries or any other format reproducing or
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capturing any of the Protected Material. Notwithstanding this provision, Counsel
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are entitled to retain an archival copy of all pleadings, motion papers, trial,
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deposition, and hearing transcripts, legal memoranda, correspondence, deposition
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and trial exhibits, expert reports, attorney work product, and consultant and expert
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work product, even if such materials contain Protected Material. Any such archival
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copies that contain or constitute Protected Material remain subject to this Protective
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Order as set forth in Section 4 (DURATION).
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14.
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VIOLATION
Any violation of this Order may be punished by appropriate measures
including, without limitation, contempt proceedings and/or monetary sanctions.
DATED: 11/15/2017
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Alexander F. MacKinnon
United States Magistrate Judge
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[PROPOSED] ORDER APPROVING STIPULATED PROTECTIVE ORDER: CASE NO. 2:17-CV-06017
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