BLM Products, Ltd. v. Covves, LLC

Filing 32

STIPULATED PROTECTIVE ORDER by Magistrate Judge Paul L. Abrams re Stipulation for Protective Order 30 . (SEE ORDER FOR FURTHER INFORMATION) (gr)

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Alan Engle (Bar No. 224779)
[e-mail]
MEADOR & ENGLE
5151 California Ave., Suite 100
Irvine, CA 92617
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff and Counter-Defendant
BLM PRODUCTS, LTD.
Stephen C. McArthur (Bar No. 277712)
[e-mail]
Valerie McConnell (State Bar No. 274159)
[e-mail]
THE MCARTHUR LAW FIRM
11400 W. Olympic Blvd., Suite 200
Los Angeles, CA 90064
Telephone: [phone]
Attorneys for Defendant and Counter-Claimant
COVVES, LLC

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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BLM PRODUCTS, LTD.,

[PROPOSED] STIPULATED
PROTECTIVE ORDER

Plaintiff,

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v.

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CASE NO. 2:17−cv−06224−RGK−PLA

COVVES, LLC,
Defendant.

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Judge: Hon. R. Gary Klausner
Magistrate Judge: Paul L. Abrams

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1.

A. PURPOSES AND LIMITATIONS

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Discovery in this action is likely to involve production of confidential, proprietary,

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or private information for which special protection from public disclosure and from use for

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any purpose other than prosecuting this litigation may be warranted. Accordingly, the

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parties hereby stipulate to and petition the Court to enter the following Stipulated
Protective Order. The parties acknowledge that this Order does not confer blanket
protections on all disclosures or responses to discovery and that the protection it affords
from public disclosure and use extends only to the limited information or items that are
entitled to confidential treatment under the applicable legal principles. The parties further
acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective Order
does not entitle them to file confidential information under seal; Civil Local Rule 79-5 sets
forth the procedures that must be followed and the standards that will be applied when a
party seeks permission from the court to file material under seal.
B. GOOD CAUSE STATEMENT
This action is likely to involve trade secrets, customer and pricing lists and other
valuable research, development, commercial, financial, technical and/or proprietary
information for which special protection from public disclosure and from use for any
purpose other than prosecution of this action is warranted. Such confidential and
proprietary materials and information consist of, among other things, confidential
business or financial information, information regarding confidential business practices,
or other confidential research, development, or commercial information (including
information implicating privacy rights of third parties), information otherwise generally
unavailable to the public, or which may be privileged or otherwise protected from
disclosure under state or federal statutes, court rules, case decisions, or common law.
Accordingly, the parties believe that the designation of certain materials as
Confidential Information or Attorneys’ Eyes-Only Information is necessary because there is
significant risk in disclosing certain highly sensitive information beyond the purposes of this
litigation. Any of the parties could be irreparably harmed if designated Confidential
Information and Attorneys’ Eyes-Only Information is divulged or somehow wrongly misused
by the Parties or-non-parties

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STIPULATED PROTECTIVE ORDER
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To expedite the flow of information, to facilitate the prompt resolution of disputes
over confidentiality of discovery materials, to adequately protect information the parties
are entitled to keep confidential, to ensure that the parties are permitted reasonable
necessary uses of such material in preparation for and in the conduct of trial, to address
their handling at the end of the litigation, and serve the ends of justice, a protective order
for such information is justified in this matter. It is the intent of the parties that information
will not be designated as confidential for tactical reasons and that nothing be so
designated without a good faith belief that it has been maintained in a confidential, nonpublic manner, and there is good cause why it should not be part of the public record of
this case.
2. DEFINITIONS
2.1

Action:

BLM

Products,

Ltd.

v.

Covves,

LLC,

Case

No.

2:17−cv−06224−RGK−PLA.
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 how it is
generated, stored or maintained) or tangible things that qualify for protection under
Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause
Statement.
2.4 "ATTORNEYS’ EYES ONLY" Information or Items: a subset of Confidential
Information that a party in good faith believes is entitled to heightened protection in order
to protect economic, competitive, or sensitive personal information that there is a
compelling need to keep confidential from the opposing party and/or its employees and
that could materially damage the Designating Party in a manner unrelated to the instant
case if revealed.
2.5 Counsel: Outside Counsel of Record and House Counsel (as well as their
support staff).

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STIPULATED PROTECTIVE ORDER
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2.6 Designating Party: a Party or Non-Party that designates information or items
that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.”
2.7 Disclosure or Discovery Material: all items or information, regardless of the
medium or manner in which it is generated, stored, or maintained (including, among
other things, testimony, transcripts, and tangible things), that are produced or generated
in disclosures or responses to discovery in this matter.
2.8 Expert: a person with specialized knowledge or experience in a matter
pertinent to the litigation who has been retained by a Party or its counsel to serve as an
expert witness or as a consultant in this Action.
2.9 House Counsel: attorneys who are employees of a party to this Action. House
Counsel does not include Outside Counsel of Record or any other outside counsel.
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 party to
this Action but are retained to represent or advise a party to this Action and have
appeared in this Action on behalf of that party or are affiliated with a law firm that has
appeared on behalf of that party, including support staff.
2.12 Party: any party to this Action, including all of its officers, directors,
employees, consultants, retained experts, and Outside Counsel of Record (and their
support staffs).
2.13 Producing Party: a Party or Non-Party that produces Disclosure or Discovery
Material in this Action.
2.14 Professional Vendors: persons or entities that provide litigation support
services

(e.g.,

photocopying,

videotaping,

translating,

preparing

exhibits

or

demonstrations, and organizing, storing, or retrieving data in any form or medium) and
their employees and subcontractors.
2.15 Protected Material: any Disclosure or Discovery Material that is designated
as “CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY.”
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STIPULATED PROTECTIVE ORDER
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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.

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The protections conferred by this Stipulation and Order cover not only
Protected Material (as defined above), but also (1) any information copied or extracted
from Protected Material; (2) all copies, excerpts, summaries, or compilations of
Protected Material; and (3) any testimony, conversations, or presentations by Parties or
their Counsel that might reveal Protected Material.

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Any use of Protected Material at trial shall be governed by the orders of the
trial judge. This Order does not govern the use of Protected Material at trial.

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4.

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SCOPE

DURATION
Once a case proceeds to trial, all of the court-filed information to be introduced

that was previously designated as confidential or maintained pursuant to this protective
order becomes public and will be presumptively available to all members of the public,
including the press, unless compelling reasons supported by specific factual findings to
proceed otherwise are made to the trial judge in advance of the trial. See Kamakana v.
City and County of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing
“good cause” showing for sealing documents produced in discovery from “compelling
reasons” standard when merits-related documents are part of court record). Accordingly,
the terms of this protective order do not extend beyond the commencement of the trial.
5.

DESIGNATING PROTECTED MATERIAL
5.1 Exercise of Restraint and Care in Designating Material for Protection. Each

Party or Non-Party that designates information or items for protection under this Order
must take care to limit any such designation to specific material that qualifies under the
appropriate standards. The Designating Party must designate for protection only those
parts of material, documents, items, or oral or written communications that qualify so that
other portions of the material, documents, items, or communications for which protection

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STIPULATED PROTECTIVE ORDER
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is not warranted are not swept unjustifiably within the ambit of this Order.
Mass, indiscriminate, or routinized designations are prohibited. Designations that
are shown to be clearly unjustified or that have been made for an improper purpose
(e.g., to unnecessarily encumber the case development process or to impose
unnecessary expenses and burdens on other parties) may expose the Designating Party
to sanctions.
If it comes to a Designating Party’s attention that information or items that it
designated for protection do not qualify for protection, that Designating Party must
promptly notify all other Parties that it is withdrawing the inapplicable designation.
5.2 Manner and Timing of Designations. Except as otherwise provided in this
Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated
or ordered, Disclosure or Discovery Material that qualifies for protection under this Order
must be clearly so designated before the material is disclosed or produced.
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 proceedings), that the
Producing Party affix, at a minimum, the legend “CONFIDENTIAL” (hereinafter
“CONFIDENTIAL legend”) or “ATTORNEYS’ EYES ONLY” (hereinafter “AEO legend”),
to each page that contains protected material. If only a portion or portions of the material
on a page qualifies for protection, the Producing Party also must clearly identify the
protected portion(s) (e.g., by making appropriate markings in the margins).
A Party or Non-Party that makes original documents available for inspection need
not designate them for protection until after the inspecting Party has indicated which
documents it would like copied and produced. During the inspection and before the
designation, all of the material made available for inspection shall be deemed
“ATTORNEYS’ EYES ONLY.” After the inspecting Party has identified the documents it
wants copied and produced, the Producing Party must determine which documents, or

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portions thereof, qualify for protection under this Order. Then, before producing the
specified documents, the Producing Party must affix either the “CONFIDENTIAL legend”
or the “AEO legend” to each page that contains Protected Material..
(b) for testimony given in depositions that the Designating Party identify the
Disclosure or Discovery Material on the record, before the close of the deposition.
(c) for information produced in some form other than documentary and for any
other tangible items, that the Producing Party affix in a prominent place on the exterior of
the container or containers in which the information is stored the legend
“CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY.” If only a portion or portions of the
information warrants protection, the Producing Party, to the extent practicable, shall
identify the protected portion(s).
5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to
designate qualified information or items does not, standing alone, waive the Designating
Party’s right to secure protection under this Order for such material. Upon timely
correction of a designation, the Receiving Party must make reasonable efforts to assure
that the material is treated in accordance with the provisions of this Order.
6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation of
confidentiality at any time that is consistent with the Court’s Scheduling Order.
6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution
process under Local Rule 37.1, et seq. Any discovery motion must strictly comply with
the procedures set forth in Local Rules 37-1, 37-2, and 37-3.
6.3 Burden. The burden of persuasion in any such challenge proceeding shall be
on the Designating Party. Frivolous challenges, and those made for an improper
purpose (e.g., to harass or impose unnecessary expenses and burdens on other parties)
may expose the Challenging Party to sanctions. Unless the Designating Party has
waived or withdrawn the confidentiality designation, all parties shall continue to afford

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the material in question the level of protection to which it is entitled under the Producing
Party’s designation until the Court rules on the challenge.
7. ACCESS TO AND USE OF PROTECTED MATERIAL
7.1 Basic Principles. A Receiving Party may use Protected Material that is
disclosed or produced by another Party or by a Non-Party in connection with this Action
only for prosecuting, defending, or attempting to settle this Action. Such Protected
Material may be disclosed only to the categories of persons and under the conditions
described in this Order. When the Action has been terminated, a Receiving Party must
comply with the provisions of section 13 below (FINAL DISPOSITION).
Protected Material must be stored and maintained by a Receiving Party at a
location and in a secure manner that ensures that access is limited to the persons
authorized under this Order.
7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise
ordered by the Court or permitted in writing by the Designating Party, a Receiving Party
may disclose any information or item designated “CONFIDENTIAL” only to:
(a) the Receiving Party’s Outside Counsel of Record in this Action, as well as
employees of said Outside Counsel of Record to whom it is reasonably necessary to
disclose the information for this Action;
(b) the officers, directors, and employees (including House Counsel) of the
Receiving Party to whom disclosure is reasonably necessary for this Action;
(c) Experts (as defined in this Order) of the Receiving Party to whom disclosure is
reasonably necessary for this Action and who have signed the “Acknowledgment and
Agreement to Be Bound” (Exhibit A);
(d) the Court and its personnel;
(e) court reporters and their staff;
(f) professional jury or trial consultants, mock jurors, and Professional Vendors to
whom disclosure is reasonably necessary for this Action and who have signed the

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STIPULATED PROTECTIVE ORDER
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“Acknowledgment and Agreement to Be Bound” (Exhibit A);
(g) the author or recipient of a document containing the information or a custodian
or other person who otherwise possessed or knew the information;
(h) during their depositions, witnesses, and attorneys for witnesses, in the Action
to whom disclosure is reasonably necessary provided: (1) the deposing party requests
that the witness sign the form attached as Exhibit 1 hereto; and (2) they will not be
permitted to keep any confidential information unless they sign the “Acknowledgment
and Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating
Party or ordered by the Court. Pages of transcribed deposition testimony or exhibits to
depositions that reveal Protected Material may be separately bound by the court reporter
and may not be disclosed to anyone except as permitted under this Stipulated Protective
Order; and
(i) any mediator or settlement officer, and their supporting personnel, mutually
agreed upon by any of the parties engaged in settlement discussions.
7.3 Disclosure of “ATTORNEYS’ EYES ONLY” Information or Items.
Unless otherwise ordered by the Court or permitted in writing by the Designating
Party, a Receiving Party may disclose any information or item designated as
“ATTORNEYS’ EYES ONLY” only to:
(a) the Receiving Party’s Outside Counsel of Record in this Action, as well as
employees of said Outside Counsel of Record to whom it is reasonably necessary to
disclose the information for this Action;
(b) Experts (as defined in this Order) of the Receiving Party to whom disclosure is
reasonably necessary for this Action and who have signed the “Acknowledgement and
Agreement to be Bound” (Exhibit A);
(c) the Court and its personnel; and
(d) court reporters and their staff.
(e) Limited disclosure for purpose of evaluating settlement: The Receiving Party’s

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STIPULATED PROTECTIVE ORDER
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Outside Counsel of Record in this Action may disclose overall summaries of total
revenue, costs, and profits data related to the Accused Products found in “ATTORNEYS’
EYES ONLY” documents to the Receiving Party for the limited purpose of evaluating
settlement in this Action.
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 that
compels disclosure of any information or items designated in this Action as
“CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY” that Party must:
(a) promptly notify in writing the Designating Party. Such notification shall include
a copy of the subpoena or court order;
(b) promptly notify in writing the party who caused the subpoena or order to issue
in the other litigation that some or all of the material covered by the subpoena or order is
subject to this Protective Order. Such notification shall include a copy of this Stipulated
Protective Order; and
(c) cooperate with respect to all reasonable procedures sought to be pursued by
the Designating Party whose Protected Material may be affected.
If the Designating Party timely seeks a protective order, the Party served with the
subpoena or court order shall not produce any information designated in this action as
“CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY” before a determination by the court
from which the subpoena or order issued, unless the Party has obtained the Designating
Party’s permission. The Designating Party shall bear the burden and expense of seeking
protection in that court of its confidential material and nothing in these provisions should
be construed as authorizing or encouraging a Receiving Party in this Action to disobey a
lawful directive from another court.

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9. 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 Non-Party
in this Action and designated as “CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY.”
Such information produced by Non-Parties in connection with this litigation is protected
by the remedies and relief provided by this Order.
Nothing in these provisions should be construed as prohibiting a Non-Party from
seeking additional protections.
(b) In the event that a Party is required, by a valid discovery request, to produce a
Non-Party’s confidential information in its possession, and the Party is subject to an
agreement with the Non-Party not to produce the Non-Party’s confidential information,
then the Party shall:
(1) promptly notify in writing the Requesting Party and the Non-Party that
some or all of the information requested is subject to a confidentiality agreement
with a Non-Party;
(2) promptly provide the Non-Party with a copy of the Stipulated Protective
Order in this Action, the relevant discovery request(s), and a reasonably specific
description of the information requested; and
(3) make the information requested available for inspection by the NonParty, if requested.
(c) If the Non-Party fails to seek a protective order from this Court within 14 days
of receiving the notice and accompanying information, the Receiving Party may produce
the Non- Party’s confidential information responsive to the discovery request. If the NonParty timely seeks a protective order, the Receiving Party shall not produce any
information in its possession or control that is subject to the confidentiality agreement
with the Non-Party before a determination by the Court. Absent a court order to the
contrary, the Non-Party shall bear the burden and expense of seeking protection in this

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STIPULATED PROTECTIVE ORDER
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Court of its Protected Material.
10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
Protected Material to any person or in any circumstance not authorized under this
Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing
the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve
all unauthorized copies of the Protected Material, (c) inform the person or persons to
whom unauthorized disclosures were made of all the terms of this Order, and (d) request
such person or persons to execute the “Acknowledgment and Agreement to Be Bound”
that is attached hereto as Exhibit A.
11.

INADVERTENT

PRODUCTION

OF

PRIVILEGED

OR

OTHERWISE

PROTECTED MATERIAL
When a Producing Party gives notice to Receiving Parties that certain
inadvertently produced material is subject to a claim of privilege or other protection, the
obligations of the Receiving Parties are those set forth in Federal Rule of Civil Procedure
26(b)(5)(B). This provision is not intended to modify whatever procedure may be
established in an e-discovery order that provides for production without prior privilege
review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the parties reach
an agreement on the effect of disclosure of a communication or information covered by
the attorney-client privilege or work product protection, the parties may incorporate their
agreement in the stipulated protective order submitted to the Court.
12. MISCELLANEOUS
12.1 Right to Further Relief. Nothing in this Order abridges the right of any person
to seek its modification by the Court in the future.
12.2 Right to Assert Other Objections. By stipulating to the entry of this Protective
Order, no Party waives any right it otherwise would have to object to disclosing or
producing any information or item on any ground not addressed in this Stipulated

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STIPULATED PROTECTIVE ORDER
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Protective Order. Similarly, no Party waives any right to object on any ground to use in
evidence of any of the material covered by this Protective Order.

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12.3 Filing Protected Material. A Party that seeks to file under seal any Protected
Material must comply with Civil Local Rule 79-5. Protected Material may only be filed
under seal pursuant to a court order authorizing the sealing of the specific Protected
Material at issue; good cause must be shown in the request to file under seal. If a Party’s
request to file Protected Material under seal is denied by the Court, then the Receiving
Party may file the information in the public record unless otherwise instructed by the
Court.
13. FINAL DISPOSITION
After the final disposition of this Action, within 60 days of a written request by the
Designating Party, each Receiving Party must return all Protected Material to the
Producing Party or destroy such material. As used in this subdivision, “all Protected
Material” includes all copies, abstracts, compilations, summaries, and any other format
reproducing or capturing any of the Protected Material. Whether the Protected Material is
returned or destroyed, the Receiving Party must submit a written certification to the
Producing Party (and, if not the same person or entity, to the Designating Party) by the
60 day deadline that (1) identifies (by category, where appropriate) all the Protected
Material that was returned or destroyed and (2) affirms that the Receiving Party has not
retained any copies, abstracts, compilations, summaries or any other format reproducing
or capturing any of the Protected Material. Notwithstanding this provision, counsel are
entitled to retain an archival copy of all pleadings, motion papers, trial, deposition, and
hearing transcripts, legal memoranda, correspondence, deposition and trial exhibits,
expert reports, attorney work product, and consultant and expert work product, even if
such materials contain Protected Material. Any such archival copies that contain or
constitute Protected Material remain subject to this Protective Order as set forth in
Section 4 (DURATION).

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14. Any violation of this Order may be punished by any and all appropriate
measures including, without limitation, contempt proceedings and/or monetary sanctions.
IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

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Dated: December 21, 2017

MEADOR & ENGLE

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By: ____/s/ Alan E. Engle_____ ___
Alan E. Engle
Attorneys for Plaintiff
BLM PRODUCTS, LTD

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Dated: December 21, 2017

THE MCARTHUR LAW FIRM

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By: ___/s/ Stephen McArthur_______
Stephen C. McArthur
Attorneys for Defendant and
Counter-Claimant COVVES, LLC

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FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
DATED: December 27, 2017
_____________________________________
Paul L. Abrams
United States Magistrate Judge

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EXHIBIT A 

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ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 

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I, 

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_____________________________________  [print  or  type  full  address],  declare 

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under  penalty  of  perjury  that  I  have  read  in  its  entirety  and  understand  the 

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Stipulated Protective Order that was issued by the United States District Court for 

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the  Central  District  of  California  in  the  case  of  BLM  PRODUCTS,  LTD.  v.  COVVES, 

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LLC, CASE NO. 2:17−cv−06224−RGK−PLA. I agree to comply with and to be bound 

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by  all  the  terms  of  this  Stipulated  Protective  Order  and  I  understand  and 

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_____________________________ 

[print 

or 

type 

full 

name], 

of 

acknowledge  that  failure  to  so  comply  could  expose  me  to  sanctions  and 
punishment in the nature of contempt. I solemnly promise that I will not disclose 
in any manner any information or item that is subject to this Stipulated Protective 
Order  to  any  person  or  entity  except  in  strict  compliance  with  the  provisions  of 
this Order. 

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I  further  agree  to  submit  to  the  jurisdiction  of  the  United  States  District 

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Court for the Central District of California for the purpose of enforcing the terms of 

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this Stipulated Protective Order, even if such enforcement proceedings occur after 

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termination of this action.  

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I hereby appoint _____________________________________ [print or type 

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full  name]  of  _____________________________________  [print  or  type  full 

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address  and  telephone  number]  as  my  California  agent  for  service  of  process  in 

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connection  with  this  action  or  any  proceedings  related  to  enforcement  of  this 
Stipulated Protective Order. 

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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STIPULATED PROTECTIVE ORDER
2:17−cv−06224−RGK−PLA