Min S. Park v. Dongbu Insurance Company, Ltd., et al

Filing 23

PROTECTIVE ORDER by Magistrate Judge Alka Sagar re Amended Stipulation for Protective Order 22 . (see order for details) (hr)

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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) Case No. 2:17-cv-08648-AB(ASx)
) [Assigned to Judge Andre Birotte, Jr.]
PLAINTIFF,
)
) PROTECTIVE ORDER
vs.
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DONGBU INSURANCE
)
COMPANY, LTD., AND DOES 1 )
TO 50.
)
)
DEFENDANTS. )
)
)
MIN S. PARK

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Plaintiff Min S. Park (“Park”) and defendant Dongbu Insurance Co., Ltd.

20 (U.S. Branch), now known as DB Insurance Company, Ltd. (U.S. Branch) and
21 hereinafter “DB,” by and through their attorneys of record, hereby stipulate and
22 agree as follows:
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24 1.

A.

PURPOSES AND LIMITATIONS

25

Discovery in this action involves production of confidential, proprietary, or

26 private information for which special protection from public disclosure and from use
27 for any purpose other than prosecuting this litigation may be warranted.
28 Accordingly, the parties hereby stipulate to and petition the Court to enter the
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AMENDED STIPULATED PROTECTIVE ORDER RE: DONGBU INS. CO., LTD.’S CLAIM MANUAL

1 following Stipulated Protective Order. The parties acknowledge that this Order does
2 not confer blanket protections on all disclosures or responses to discovery and that
3 the protection it affords from public disclosure and use extends only to the limited
4 information or items that are entitled to confidential treatment under the applicable
5 legal principles. The parties further acknowledge, as set forth in Section 12.3,
6 below, that this Stipulated Protective Order does not entitle them to file confidential
7 information under seal; Civil Local Rule 79-5 sets forth the procedures that must be
8 followed and the standards that will be applied when a party seeks permission from
9 the court to file material under seal.
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B.

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Park propounded a Request for Production of Documents which asked DB to

GOOD CAUSE STATEMENT

13 produce “Defendant Dongbu Insurance Company’s claim manual pertaining to the
14 handling of Min S. Park’s claim that is the subject of this litigation” (hereinafter
15 “subject claim manual”).
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DB objected to the Request for Production of Documents concerning the

17 production of its subject claim manual on the basis that, among other things, any
18 such subject claim manual is protected as commercially sensitive, trade secret,
19 and/or proprietary information relative to DB’s business which has value to DB and
20 its competitors such that the production of same would violate DB’s rights,
21 privileges, and protections.
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DB’s subject claim manual is proprietary to DB and DB derives economic

23 value from the subject claim manual not being generally known to other persons
24 who can obtain economic value from its disclosure or use. Any disclosure or
25 unauthorized use of the subject claim manual could cause irreparable harm to DB.
26

The subject claim manual of which Park seeks production involves trade

27 secrets and other valuable research, development, commercial and/or proprietary
28 information for which special protection from public disclosure and from use for any
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AMENDED STIPULATED PROTECTIVE ORDER RE: DONGBU INS. CO., LTD.’S CLAIM MANUAL

1 purpose other than prosecution of this action is warranted. Such confidential and
2 proprietary materials and information consist of, among other things, confidential
3 business information, information regarding confidential business practices, or other
4 confidential commercial information, information otherwise generally unavailable to
5 the public, or which may be privileged or otherwise protected from disclosure under
6 state or federal statutes, court rules, case decisions, or common law.
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Accordingly, to expedite the flow of information, to facilitate the prompt

8 resolution of disputes over confidentiality of discovery materials, to adequately
9 protect information the parties are entitled to keep confidential, to ensure that the
10 parties are permitted reasonable necessary uses of such material in preparation for
11 and in the conduct of trial, to address their handling at the end of the litigation, and
12 serve the ends of justice, a protective order for such information is justified in this
13 matter. It is the intent of the parties that information will not be designated as
14 confidential for tactical reasons and that nothing be so designated without a good
15 faith belief that it has been maintained in a confidential, non-public manner, and
16 there is good cause why it should not be part of the public record of this case.
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18 2.

DEFINITIONS

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2.1 Action: Min S. Park v. Dongbu Ins. Co., Ltd. (U.S. Branch), Case No.

20 2:17-cv-08648-AB-AS.
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2.2 Challenging Party: a Party or Non-Party that challenges the designation of

22 information or items under this Order.
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2.3 “CONFIDENTIAL” Information or Items: information (regardless of how

24 it is generated, stored or maintained) or tangible things that qualify for protection
25 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good
26 Cause Statement.
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2.4 Counsel: Outside Counsel of Record and House Counsel (as well as their

28 support staff).
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AMENDED STIPULATED PROTECTIVE ORDER RE: DONGBU INS. CO., LTD.’S CLAIM MANUAL

1

2.5 Designating Party: a Party or Non-Party that designates information or

2 items that it produces in disclosures or in responses to discovery as
3 “CONFIDENTIAL.”
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2.6 Disclosure or Discovery Material: all items or information, regardless of

5 the medium or manner in which it is generated, stored, or maintained (including,
6 among other things, testimony, transcripts, and tangible things), that are produced or
7 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

9 pertinent to the litigation who has been retained by a Party or its counsel to serve as
10 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.

12 House Counsel does not include Outside Counsel of Record or any other outside
13 counsel.
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2.9 Non-Party: any natural person, partnership, corporation, association, or

15 other legal entity not named as a Party to this action.
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2.10 Outside Counsel of Record: attorneys who are not employees of a party

17 to this Action but are retained to represent or advise a party to this Action and have
18 appeared in this Action on behalf of that party or are affiliated with a law firm which
19 has appeared on behalf of that party, and includes support staff.
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2.11 Party: any party to this Action, including all of its officers, directors,

21 employees, consultants, retained experts, and Outside Counsel of Record (and their
22 support staffs).
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2.12 Producing Party: a Party or Non-Party that produces Disclosure or

24 Discovery Material in this Action.
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2.13 Professional Vendors: persons or entities that provide litigation support

26 services (e.g., photocopying, videotaping, translating, preparing exhibits or
27 demonstrations, and organizing, storing, or retrieving data in any form or medium)
28 and their employees and subcontractors.
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AMENDED STIPULATED PROTECTIVE ORDER RE: DONGBU INS. CO., LTD.’S CLAIM MANUAL

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2.14 Protected Material: any Disclosure or Discovery Material that is

2 designated as “CONFIDENTIAL.”
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2.15 Receiving Party: a Party that receives Disclosure or DiscoveryMaterial

4 from a Producing Party.
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6 3.

SCOPE

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The protections conferred by this Stipulation and Order cover not only

8 Protected Material (as defined above), but also (1) any information copied or
9 extracted from Protected Material; (2) all copies, excerpts, summaries, or
10 compilations of Protected Material; and (3) any testimony, conversations, or
11 presentations by Parties or their Counsel that might reveal Protected Material.
12 Any use of Protected Material at trial shall be governed by the orders of the trial
13 judge. This Order does not govern the use of Protected Material at trial.
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15 4.

DURATION

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Even after final disposition of this litigation, the confidentiality obligations

17 imposed by this Order shall remain in effect until a Designating Party agrees
18 otherwise in writing or a court order otherwise directs. Final disposition shall be
19 deemed to be the later of (1) dismissal of all claims and defenses in this Action, with
20 or without prejudice; and (2) final judgment herein after the completion and
21 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action,
22 including the time limits for filing any motions or applications for extension of time
23 pursuant to applicable law.
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25 5.

DESIGNATING PROTECTED MATERIAL

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5.1 Exercise of Restraint and Care in Designating Material for Protection.

27 Each Party or Non-Party that designates information or items for protection under
28 this Order must take care to limit any such designation to specific material that
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AMENDED STIPULATED PROTECTIVE ORDER RE: DONGBU INS. CO., LTD.’S CLAIM MANUAL

1 qualifies under the appropriate standards. The Designating Party must designate for
2 protection only those parts of material, documents, items, or oral or written
3 communications that qualify so that other portions of the material, documents, items,
4 or communications for which protection is not warranted are not swept unjustifiably
5 within the ambit of this Order.
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Mass, indiscriminate, or routinized designations are prohibited. Designations

7 that are shown to be clearly unjustified or that have been made for an improper
8 purpose (e.g., to unnecessarily encumber the case development process or to impose
9 unnecessary expenses and burdens on other parties) may expose the Designating
10 Party to sanctions.
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If it comes to a Designating Party’s attention that information or items that it

12 designated for protection do not qualify for protection, that Designating Party must
13 promptly notify all other Parties that it is withdrawing the inapplicable designation.
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5.2 Manner and Timing of Designations. Except as otherwise provided in this

15 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
16 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
17 under this Order must be clearly so designated before the material is disclosed or
18 produced.
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Designation in conformity with this Order requires:

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(a)

for information in documentary form (e.g., paper or electronic

21 documents, but excluding transcripts of depositions or other pretrial or trial
22 proceedings), that the Producing Party affix at a minimum, the legend
23 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
24 contains protected material. If only a portion or portions of the material on a page
25 qualifies for protection, the Producing Party also must clearly identify the protected
26 portion(s) (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

28 need not designate them for protection until after the inspecting Party has indicated
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AMENDED STIPULATED PROTECTIVE ORDER RE: DONGBU INS. CO., LTD.’S CLAIM MANUAL

1 which documents it would like copied and produced. During the inspection and
2 before the designation, all of the material made available for inspection shall be
3 deemed “CONFIDENTIAL.” After the inspecting Party has identified the
4 documents it wants copied and produced, the Producing Party must determine which
5 documents, or portions thereof, qualify for protection under this Order. Then, before
6 producing the specified documents, the Producing Party must affix the
7 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a
8 portion or portions of the material on a page qualifies for protection, the Producing
9 Party also must clearly identify the protected portion(s) (e.g., by making appropriate
10 markings in the margins).
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(b)

for testimony given in depositions that the Designating Party identify

12 the Disclosure or Discovery Material on the record, before the close of the
13 deposition all protected testimony.
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(c)

for information produced in some form other than documentary and for

15 any other tangible items, that the Producing Party affix in a prominent place on the
16 exterior of the container or containers in which the information is stored the legend
17 “CONFIDENTIAL.” If only a portion or portions of the information warrants
18 protection, the Producing Party, to the extent practicable, shall identify the protected
19 portion(s).
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5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent

21 failure to designate qualified information or items does not, standing alone, waive
22 the Designating Party’s right to secure protection under this Order for such material.
23 Upon timely correction of a designation, the Receiving Party must make reasonable
24 efforts to assure that the material is treated in accordance with the provisions of this
25 Order.
26 / / /
27 / / /
28 / / /
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AMENDED STIPULATED PROTECTIVE ORDER RE: DONGBU INS. CO., LTD.’S CLAIM MANUAL

1 6.

CHALLENGING CONFIDENTIALITY DESIGNATIONS

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6.1 Timing of Challenges. Any Party or Non-Party may challenge a

3 designation of confidentiality at any time that is consistent with the Court’s
4 Scheduling Order.
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6.2 Meet and Confer. The Challenging Party shall initiate the dispute

6 resolution process under Local Rule 37.1 et seq.
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6.3 The burden of persuasion in any such challenge proceeding shall be on the

8 Designating Party. Frivolous challenges, and those made for an improper purpose
9 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may
10 expose the Challenging Party to sanctions. Unless the Designating Party has waived
11 or withdrawn the confidentiality designation, all parties shall continue to afford the
12 material in question the level of protection to which it is entitled under the
13 Producing Party’s designation until the Court rules on the challenge.
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15 7.

ACCESS TO AND USE OF PROTECTED MATERIAL

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7.1 Basic Principles. A Receiving Party may use Protected Material that is

17 disclosed or produced by another Party or by a Non-Party in connection with this
18 Action only for prosecuting, defending, or attempting to settle this Action. Such
19 Protected Material may be disclosed only to the categories of persons and under the
20 conditions described in this Order. When the Action has been terminated, a
21 Receiving Party must comply with the provisions of section 13 below (FINAL
22 DISPOSITION).
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Protected Material must be stored and maintained by a Receiving Party at a

24 location and in a secure manner that ensures that access is limited to the persons
25 authorized under this Order.
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7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless

27 otherwise ordered by the court or permitted in writing by the Designating Party, a
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AMENDED STIPULATED PROTECTIVE ORDER RE: DONGBU INS. CO., LTD.’S CLAIM MANUAL

1 Receiving Party may disclose any information or item designated
2 “CONFIDENTIAL” only to:
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(a)

the Receiving Party’s Outside Counsel of Record in this Action, as well

4 as employees of said Outside Counsel of Record to whom it is reasonably necessary
5 to disclose the information for this Action;
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(b)

the officers, directors, and employees (including House Counsel) of the

7 Receiving Party to whom disclosure is reasonably necessary for this Action;
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(c)

Experts (as defined in this Order) of the Receiving Party to whom

9 disclosure is reasonably necessary for this Action and who have signed the
10 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
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(d)

the court and its personnel;

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(e)

court reporters and their staff;

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(f)

professional jury or trial consultants, mock jurors, and Professional

14 Vendors to whom disclosure is reasonably necessary for this Action and who have
15 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
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(g)

the author or recipient of a document containing the information or a

17 custodian or other person who otherwise possessed or knew the information;
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(h)

during their depositions, witnesses, and attorneys for witnesses, in the

19 Action to whom disclosure is reasonably necessary provided: (1) the deposing party
20 requests that the witness sign the form attached as Exhibit A hereto; and (2) they
21 will not be permitted to keep any confidential information unless they sign the
22 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
23 agreed by the Designating Party or ordered by the court. Pages of transcribed
24 deposition testimony or exhibits to depositions that reveal Protected Material may be
25 separately bound by the court reporter and may not be disclosed to anyone except as
26 permitted under this Stipulated Protective Order; and
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(i)

any mediator or settlement officer, and their supporting personnel,

28 mutually agreed upon by any of the parties engaged in settlement discussions.
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AMENDED STIPULATED PROTECTIVE ORDER RE: DONGBU INS. CO., LTD.’S CLAIM MANUAL

1 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

4 that compels disclosure of any information or items designated in this Action as
5 “CONFIDENTIAL,” that Party must:
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(a)

promptly notify in writing the Designating Party. Such notification

7 shall include a copy of the subpoena or court order;
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(b)

promptly notify in writing the party who caused the subpoena or order

9 to issue in the other litigation that some or all of the material covered by the
10 subpoena or order is subject to this Protective Order. Such notification shall include
11 a copy of this Stipulated Protective Order; and
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(c)

cooperate with respect to all reasonable procedures sought to be

13 pursued by the Designating Party whose Protected Material may be affected.
14 If the Designating Party timely seeks a protective order, the Party served with the
15 subpoena or court order shall not produce any information designated in this action
16 as “CONFIDENTIAL” before a determination by the court from which the subpoena
17 or order issued, unless the Party has obtained the Designating Party’s permission.
18 The Designating Party shall bear the burden and expense of seeking protection in
19 that court of its confidential material and nothing in these provisions should be
20 construed as authorizing or encouraging a Receiving Party in this Action to disobey
21 a lawful directive from another court.
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23 9.

A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

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PRODUCED IN THIS LITIGATION

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(a)

The terms of this Order are applicable to information produced by a

26 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information
27 produced by Non-Parties in connection with this litigation is protected by the
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AMENDED STIPULATED PROTECTIVE ORDER RE: DONGBU INS. CO., LTD.’S CLAIM MANUAL

1 remedies and relief provided by this Order. Nothing in these provisions should be
2 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

4 produce a Non-Party’s confidential information in its possession, and the Party is
5 subject to an agreement with the Non-Party not to produce the Non-Party’s
6 confidential information, then the Party shall:
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(1)

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Party that some or all of the information requested is subject to a

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confidentiality agreement with a Non-Party;

promptly notify in writing the Requesting Party and the Non-

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(2)

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Protective Order in this Action, the relevant discovery request(s), and a

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reasonably specific description of the information requested; and

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(3)

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Non-Party, if requested.

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(c)

promptly provide the Non-Party with a copy of the Stipulated

make the information requested available for inspection by the

If the Non-Party fails to seek a protective order from this court within

16 14 days of receiving the notice and accompanying information, the Receiving Party
17 may produce the Non-Party’s confidential information responsive to the discovery
18 request. If the Non-Party timely seeks a protective order, the Receiving Party shall
19 not produce any information in its possession or control that is subject to the
20 confidentiality agreement with the Non-Party before a determination by the court.
21 Absent a court order to the contrary, the Non-Party shall bear the burden and
22 expense of seeking protection in this court of its Protected Material.
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24 10.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed

26 Protected Material to any person or in any circumstance not authorized under this
27 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
28 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
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AMENDED STIPULATED PROTECTIVE ORDER RE: DONGBU INS. CO., LTD.’S CLAIM MANUAL

1 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
2 persons to whom unauthorized disclosures were made of all the terms of this Order,
3 and (d) request such person or persons to execute the “Acknowledgment and
4 Agreement to Be Bound” that is attached hereto as Exhibit A.
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6 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

9 inadvertently produced material is subject to a claim of privilege or other protection,
10 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
11 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
12 may be established in an e-discovery order that provides for production without
13 prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar
14 as the parties reach an agreement on the effect of disclosure of a communication or
15 information covered by the attorney-client privilege or work product protection, the
16 parties may incorporate their agreement in the stipulated protective order submitted
17 to the court.
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19 12.

MISCELLANEOUS

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12.1 Right to Further Relief. Nothing in this Order abridges the right of any

21 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

23 Protective Order no Party waives any right it otherwise would have to object to
24 disclosing or producing any information or item on any ground not addressed in this
25 Stipulated Protective Order. Similarly, no Party waives any right to object on any
26 ground to use in evidence of any of the material covered by this Protective Order.
27

12.3 Filing Protected Material. A Party that seeks to file under seal any

28 Protected Material must comply with Civil Local Rule 79-5. Protected Material may
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AMENDED STIPULATED PROTECTIVE ORDER RE: DONGBU INS. CO., LTD.’S CLAIM MANUAL

1 only be filed under seal pursuant to a court order authorizing the sealing of the
2 specific Protected Material at issue. If a Party's request to file Protected Material
3 under seal is denied by the court, then the Receiving Party may file the information
4 in the public record unless otherwise instructed by the court.
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6 13.

FINAL DISPOSITION

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After the final disposition of this Action, as defined in paragraph 4, within

8 fourteen (14) business days, each Receiving Party must return all Protected Material
9 to the Producing Party or destroy such material. As used in this subdivision, “all
10 Protected Material” includes all copies, abstracts, compilations, summaries, and any
11 other format reproducing or capturing any of the Protected Material. Whether the
12 Protected Material is returned or destroyed, the Receiving Party must submit a
13 written certification to the Producing Party (and, if not the same person or entity, to
14 the Designating Party) by the 60 day deadline that (1) identifies (by category, where
15 appropriate) all the Protected Material that was returned or destroyed and (2) affirms
16 that the Receiving Party has not retained any copies, abstracts, compilations,
17 summaries or any other format reproducing or capturing any of the Protected
18 Material. Notwithstanding this provision, Counsel are entitled to retain an archival
19 copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal
20 memoranda, correspondence, deposition and trial exhibits, expert reports, attorney
21 work product, and consultant and expert work product, even if such materials
22 contain Protected Material. Any such archival copies that contain or constitute
23 Protected Material remain subject to this Protective Order as set forth in Section 4
24 (DURATION).
25 / / /
26 / / /
27 / / /
28 / / /
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AMENDED STIPULATED PROTECTIVE ORDER RE: DONGBU INS. CO., LTD.’S CLAIM MANUAL

1 14.

Any violation of this Order may be punished by any and all appropriate

2 measures including, without limitation, contempt proceedings and/or monetary
3 sanctions.
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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
DATED: September 6, 2018

BERMAN BERMAN BERMAN
SCHNEIDER & LOWARY, LLP

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/s/ Karen E. Adelman
By: ________________________
SPENCER A. SCHNEIDER
KAREN E. ADELMAN
Attorneys for Defendant
DONGBU INSURANCE CO., LTD.
(U.S. Branch), now known as DB
INSURANCE CO., LTD. (U.S. Branch)

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DATED: September 6, 2018

LAW OFFICES OF
RACKOHN & RACKOHN

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/s/ Craig Rackohn
By: ________________________
CRAIG RACKOHN
Attorneys for Plaintiff
MIN S. PARK

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19 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
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September 10, 2018
21 DATED: ________________________
22
23 ________________________________
/s/
Honorable Alka Sagar
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United States Magistrate Judge
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AMENDED STIPULATED PROTECTIVE ORDER RE: DONGBU INS. CO., LTD.’S CLAIM MANUAL

1

EXHIBIT A

2

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3

I, _____________________________ [print or type full name], of

4 _______________________________ [print or type full address], declare under
5 penalty of perjury that I have read in its entirety and understand the Stipulated
6 Protective Order that was issued by the United States District Court for the Central
7 District of California on September _____, 2018 in the case of Min S. Park v.
8 Dongbu Ins. Co., Ltd. (U.S. Branch), Case No. 2:17-cv-08648-AB-AS. I agree to
9 comply with and to be bound by all the terms of this Stipulated Protective Order and
10 I understand and acknowledge that failure to so comply could expose me to
11 sanctions and punishment in the nature of contempt. I solemnly promise that I will
12 not disclose in any manner any information or item that is subject to this Stipulated
13 Protective Order to any person or entity except in strict compliance with the
14 provisions of this Order.
15

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

16 for the Central District of California for the purpose of enforcing the terms of this
17 Stipulated Protective Order, even if such enforcement proceedings occur after
18 termination of this action. I hereby appoint __________________________ [print
19 or type full name] of _______________________________________ [print or type
20 full address and telephone number] as my California agent for service of process in
21 connection with this action or any proceedings related to enforcement of this
22 Stipulated Protective Order.
23
24 Date: ______________________________________
25 City and State where sworn and signed: ________________________________
26 Printed name: _______________________________
27 Signature: __________________________________
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AMENDED STIPULATED PROTECTIVE ORDER RE: DONGBU INS. CO., LTD.’S CLAIM MANUAL