Dieter Hartmann v. Tyler Bates et al
Filing
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PROTECTIVE ORDER by Magistrate Judge Michael R. Wilner. re Stipulation for Protective Order 17 (vm)
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Peter Anderson, Esq., Cal. Bar No. 88891
peteranderson@dwt.com
Alonzo Wickers IV, Esq., Cal. Bar No. 169454
alonzowickers@dwt.com
Nicolette Vairo, Esq., Cal. Bar No. 311592
nicolettevairo@dwt.com
DAVIS WRIGHT TREMAINE LLP
865 South Figueroa Street, Suite 2400
Los Angeles, CA 90017-2566
Tel: (213) 633-6800
Fax: (213) 633-6899
Attorney for Defendants
FOCUS FEATURES, LLC, and
FOCUS FEATURES PRODUCTIONS, LLC
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UNITED STATES DISTRICT COURT
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CENTRAL DISTRICT OF CALIFORNIA
DIETER HARTMANN,
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Plaintiff,
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v.
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TYLER BATES; TYLER BATES
MUSIC INC.; FOCUS FEATURES,
LLC; FOCUS FEATURES
PRODUCTIONS, LLC,
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Defendants.
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Case No. 2:19-cv-05273-AB(MRWx)
STIPULATED PROTECTIVE
ORDER
(MRW VERSION 4/19)
Check if submitted without
material modifications to MRW form
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1.
INTRODUCTION
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1.1
PURPOSES AND LIMITATIONS
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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 disclosure
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and from use for any purpose other than prosecuting this litigation may be warranted.
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Accordingly, the parties hereby stipulate to and petition the Court to enter the
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following Stipulated Protective Order. The parties acknowledge that this Order does
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not confer blanket protections on all disclosures or responses to discovery and that
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the protection it affords from public disclosure and use extends only to the limited
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information or items that are entitled to confidential treatment under the applicable
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legal principles. The parties further acknowledge, as set forth in Section 12.3, below,
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that this Stipulated Protective Order does not entitle them to file confidential
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information under seal; Civil Local Rule 79-5 sets forth the procedures that must be
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followed and the standards that will be applied when a party seeks permission from
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the court to file material under seal.
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1.2
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This case involves claims of copyright infringement relating to the creation and
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distribution of certain recorded musical compositions. As a result, this action is likely
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to involve trade secrets, customer and pricing lists and other valuable research,
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development, commercial, financial, technical and/or proprietary information for
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which special protection from public disclosure and from use for any purpose other
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than prosecution of this action is warranted. Such confidential and proprietary
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materials and information consist of, among other things, confidential business or
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financial information, information regarding confidential business practices, or other
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confidential research, development, or commercial information (including
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information implicating privacy rights of third parties), information otherwise
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generally unavailable to the public, or which may be privileged or otherwise protected
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from disclosure under state or federal statutes, court rules, case decisions, or common
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law, and material or information that is subject to a written independent obligation of
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confidentiality. Accordingly, to expedite the flow of information, to facilitate the
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prompt resolution of disputes over confidentiality of discovery materials, to
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adequately protect information the parties are entitled to keep confidential, to ensure
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that the parties are permitted reasonable necessary uses of such material in preparation
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for and in the conduct of trial, to address their handling at the end of the litigation,
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and serve the ends of justice, a protective order for such information is justified in this
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matter. It is the intent of the parties that information will not be designated as
GOOD CAUSE STATEMENT
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confidential for tactical reasons and that nothing be so designated without a good faith
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belief that it has been maintained in a confidential, non-public manner, and there is
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good cause why it should not be part of the public record of this case.
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2.
DEFINITIONS
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2.1
Action: this pending federal lawsuit.
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2.2
Challenging Party: a Party or Non-Party that challenges the designation
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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 or
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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.
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2.10 Outside Counsel of Record: attorneys who are not employees of a party
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to this Action but are retained to represent or advise a party to this Action and have
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appeared in this Action on behalf of that party or are affiliated with a law firm which
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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,
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employees, consultants, retained experts, and Outside Counsel of Record (and their
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support staffs).
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2.12 Producing Party: a Party or Non-Party that produces Disclosure or
Discovery Material in this Action.
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2.13 Professional Vendors: persons or entities that provide litigation support
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services (e.g., photocopying, videotaping, translating, preparing exhibits or
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demonstrations, and organizing, storing, or retrieving data in any form or medium)
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and their employees and subcontractors.
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2.14 Protected Material:
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designated as “CONFIDENTIAL.”
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any Disclosure or Discovery Material that is
2.15 Receiving Party: a Party that receives Disclosure or Discovery Material
from a Producing Party.
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3.
SCOPE
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The protections conferred by this Stipulation and Order cover not only
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Protected Material (as defined above), but also (1) any information copied or extracted
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from Protected Material; (2) all copies, excerpts, summaries, or compilations of
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Protected Material; and (3) any testimony, conversations, or presentations by Parties
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or their Counsel that might reveal Protected Material.
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Any use of Protected Material at trial will 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.
DURATION
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Even after final disposition of this litigation, the confidentiality obligations
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imposed by this Order will remain in effect until a Designating Party agrees otherwise
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in writing or a court order otherwise directs. Final disposition will be deemed to be
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the later of (1) dismissal of all claims and defenses in this Action, with or without
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prejudice; and (2) final judgment herein after the completion and exhaustion of all
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appeals, rehearings, remands, trials, or reviews of this Action, including the time
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limits for filing any motions or applications for extension of time pursuant to
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applicable law.
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5.
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 this
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Order must take care to limit any such designation to specific material that qualifies
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under the appropriate standards. The Designating Party must designate for protection
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only those parts of material, documents, items, or oral or written communications that
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qualify so that other portions of the material, documents, items, or communications
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for which protection is not warranted are not swept unjustifiably within the ambit of
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this Order.
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Mass, indiscriminate, or routinized designations are prohibited. Designations
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that are shown to be clearly unjustified or that have been made for an improper
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purpose (e.g., to unnecessarily encumber the case development process or to impose
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unnecessary expenses and burdens on other parties) may expose the Designating Party
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to sanctions.
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If it comes to a Designating Party’s attention that information or items that it
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designated for protection do not qualify for protection, that Designating Party must
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promptly notify all other Parties that it is withdrawing the inapplicable designation.
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5.2
Manner and Timing of Designations. Except as otherwise provided in
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this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
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stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
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under this Order must be clearly so designated before the material is disclosed or
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produced.
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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 documents,
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but excluding transcripts of depositions or other pretrial or trial proceedings), that the
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Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter
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“CONFIDENTIAL legend”), to each page that contains protected material. If only a
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portion or portions of the material on a page qualifies for protection, the Producing
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Party also must clearly identify the protected portion(s) (e.g., by making appropriate
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markings in the margins).
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A Party or Non-Party that makes original documents available for
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inspection need not designate them for protection until after the inspecting Party has
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indicated which documents it would like copied and produced. During the inspection
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and before the designation, all of the material made available for inspection will be
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deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents
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it wants copied and produced, the Producing Party must determine which documents,
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or portions thereof, qualify for protection under this Order. Then, before producing
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the specified documents, the Producing Party must affix the “CONFIDENTIAL
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legend” to each page that contains Protected Material. If only a portion or portions
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of the material on a page qualifies for protection, the Producing Party also must clearly
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identify the protected portion(s) (e.g., by making appropriate markings in the
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margins).
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(b) for testimony given in depositions Parties and deponents may, within thirty
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(30) days after receiving a transcript of a deposition, designate pages of the transcript
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(and exhibits thereto) as Confidential to the extent the Party or deponent believes they
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contain material or information entitled to that protection. Confidential information
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within the deposition transcript may be designated only by sending a letter indicating
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the page and line numbers of the deposition transcript that the Party or deponent
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designates as Confidential to the party who took the deposition and to the court
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reporter. Until the expiration of the 30-day period during which such designations
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may be made, the transcript of the deposition will be treated as subject to protection
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as Confidential under this Stipulated Protective Order. Further, to avoid misuse of
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audiovisual recordings of depositions to embarrass or harass a party or witness, and
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consistent with the limitations of California Rule of Professional Conduct 3.6
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(adopted by this Court under Local Rule 83-3.1.2) upon extrajudicial statements likely
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to materially prejudice an adjudicative proceeding, all audiovisual recordings of
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depositions shall be used solely for the prosecution or defense of this action and shall
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not be posted on the Internet or otherwise publicly exhibited, publicly distributed, or
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disclosed to anyone other than Parties, House Counsel and Experts, other than if
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played in open court in, or otherwise used in the prosecution or defense of, this action
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or the action styled entitled Kurt Oldman, et al. vs. Tyler Bates, et al., Los Angeles
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Superior Court Case No. 18STCV01060 (the “State Case”), or as may be permitted
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by further order of this Court or the Court in the State Case. The foregoing provision
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does not, however, authorize the State Court in the State Action to permit the use or
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disclosure of material or information that has been designated “CONFIDENTIAL”
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pursuant to this Stipulated Protective Order and appears in the audiovisual recordings,
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and, instead, any use or disclosure of that material or information designated
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“CONFIDENTIAL” shall be governed by paragraph 8 of this Stipulated Protective
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Order.
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(c) for information produced in some form other than documentary and for any
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other tangible items, that the Producing Party affix in a prominent place on the exterior
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of the container or containers in which the information is stored the legend
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“CONFIDENTIAL.” If only a portion or portions of the information warrants
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protection, the Producing Party, to the extent practicable, will identify the protected
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portion(s).
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5.3
Inadvertent Failures to Designate. If timely corrected, an inadvertent
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failure to designate qualified information or items does not, standing alone, waive the
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Designating Party’s right to secure protection under this Order for such material.
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Upon timely correction of a designation, the Receiving Party must make reasonable
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efforts to assure that the material is treated in accordance with the provisions of this
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Order.
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6.
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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 will initiate the dispute
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resolution process (and, if necessary, file a discovery motion) under Local Rule 37.1
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et seq.
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6.3
The burden of persuasion in any such challenge proceeding will be on
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the Designating Party. Frivolous challenges, and those made for an improper purpose
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(e.g., to harass or impose unnecessary expenses and burdens on other parties) may
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expose the Challenging Party to sanctions. Unless the Designating Party has waived
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or withdrawn the confidentiality designation, all parties will continue to afford the
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material in question the level of protection to which it is entitled under the Producing
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Party’s designation until the Court rules on the challenge.
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7.
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 Receiving
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Party must comply with the provisions of section 13 below (FINAL 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
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Party
may
disclose
any
information
or
item
designated
“CONFIDENTIAL” only to:
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(a) the Receiving Party and the Receiving Party’s Outside Counsel of
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Record in this Action, as well as employees of said Outside Counsel of Record to
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whom it is reasonably necessary to disclose the information for this Action;
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(b) the officers, directors, and employees (including House Counsel) of the
Receiving Party to whom disclosure is reasonably necessary for this Action;
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(c) Experts (as defined in this Order) of the Receiving Party to whom
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disclosure is reasonably necessary for this Action and who have signed the
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“Acknowledgment and Agreement to Be Bound” (Exhibit A);
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(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
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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);
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(g) the author or recipient of a document containing the information or a
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
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Action to whom disclosure is reasonably necessary provided: (1) the deposing party
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requests that the witness sign the form attached as Exhibit A hereto; and (2) they will
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not be permitted to keep any confidential information unless they sign the
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“Acknowledgment and Agreement to Be Bound” (Exhibit A), 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 be
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separately bound by the court reporter and may not be disclosed to anyone except as
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permitted under this Stipulated Protective Order; and
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(i) any mediator or settlement officer, and their supporting personnel, mutually
agreed upon by any of the parties engaged in settlement discussions.
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8.
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ORDERED PRODUCED, OR OTHERWISE SOUGHT TO BE USED, IN OTHER
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LITIGATION
PROTECTED MATERIAL SUBPOENAED, SOUGHT IN DISCOVERY,
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If a Party is served with a subpoena, discovery request, or a court order issued
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in other litigation that compels disclosure of any information or items designated in
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this Action as “CONFIDENTIAL,” or if a Party wishes to disclose in other litigation
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any information or items designated in this Action as “CONFIDENTIAL,” that Party
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must:
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(a) promptly notify in writing the Designating Party prior to the disclosure.
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Such notification will include, as applicable, a copy of the subpoena, discovery
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request, or court order or a description of the proposed disclosure;
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(b) in the case of a subpoena, discovery request, or court order compelling
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disclosure, promptly notify in writing the party who caused the subpoena, discovery
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request, or order to issue in the other litigation that some or all of the material covered
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by the subpoena, discovery request, or order is subject to this Protective Order. Such
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notification will include a copy of this Stipulated Protective Order; and
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(c) cooperate with respect to all reasonable procedures sought to be pursued
by the Designating Party whose Protected Material may be affected.
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If the Designating Party timely seeks a protective order, the Party served with
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the subpoena, discovery request, or court order or who seeks to disclose information
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or items designated in this Action as “CONFIDENTIAL,” will not produce any
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information designated in this Action as “CONFIDENTIAL” before a determination
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by the court in the other litigation, unless the Party has obtained the Designating
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Party’s permission. The Designating Party will bear the burden and expense of
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seeking protection in that court of its confidential material and nothing in these
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provisions should be construed as authorizing or encouraging a Receiving Party in
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this Action to disobey a lawful directive from another court.
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9.
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PRODUCED IN THIS LITIGATION
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A
NON-PARTY’S
PROTECTED
MATERIAL
SOUGHT
TO
BE
(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 will:
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(1) promptly notify in writing the Requesting Party and the Non-Party
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that some or all of the information requested is subject to a confidentiality agreement
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with a Non-Party;
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(2) promptly provide the Non-Party with a copy of the Stipulated
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Protective Order in this Action, the relevant discovery request(s), and a reasonably
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specific description of the information requested; and
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(3) make the information requested available for inspection by the NonParty, if requested.
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(c) If the Non-Party fails to seek a protective order from this court within
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14 days of receiving the notice and accompanying information, the Receiving Party
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may produce the Non-Party’s confidential information responsive to the discovery
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request. If the Non-Party timely seeks a protective order, the Receiving Party will not
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produce any information in its possession or control that is subject to the
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confidentiality agreement with the Non-Party before a determination by the court.
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Absent a court order to the contrary, the Non-Party will bear the burden and expense
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of seeking protection in this court of its Protected Material.
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10.
UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
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If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
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Protected Material to any person or in any circumstance not authorized under this
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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 efforts
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to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
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persons to whom unauthorized disclosures were made of all the terms of this Order,
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and (d) request such person or persons to execute the “Acknowledgment and
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Agreement to Be Bound” that is attached hereto as Exhibit A.
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11.
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PROTECTED MATERIAL
INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
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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 protection,
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the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
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Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
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may be established in an e-discovery order that provides for production without prior
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privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
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parties reach an agreement on the effect of disclosure of a communication or
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information covered by the attorney-client privilege or work product protection, the
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parties may incorporate their agreement in the stipulated protective order submitted
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to the court.
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12.
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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.
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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 this
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Stipulated Protective Order. Similarly, no Party waives any right to object on any
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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
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Protected Material must comply with Civil Local Rule 79-5. Protected Material may
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only be filed under seal pursuant to a court order authorizing the sealing of the specific
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Protected Material at issue. If a Party's request to file Protected Material under seal
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is denied by the court, then the Receiving Party may file the information in the public
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record unless otherwise instructed by the court.
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13.
FINAL DISPOSITION
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After the final disposition of this Action, as defined in paragraph 4, within 60
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days of a written request by the Designating Party, each Receiving Party must return
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all Protected Material to the Producing Party or destroy such material. As used in this
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subdivision, “all Protected Material” includes all copies, abstracts, compilations,
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summaries, and any other format reproducing or capturing any of the Protected
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Material. Whether the Protected Material is returned or destroyed, the Receiving
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Party must submit a written certification to the Producing Party (and, if not the same
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person or entity, to the Designating Party) by the 60 day deadline that (1) identifies
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(by category, where appropriate) all the Protected Material that was returned or
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destroyed and (2) affirms that the Receiving Party has not retained any copies,
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abstracts, compilations, summaries or any other format reproducing or capturing any
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of the Protected Material. Notwithstanding this provision, Counsel are entitled to
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retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing
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transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
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reports, attorney work product, and consultant and expert work product, even if such
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materials contain Protected Material. Any such archival copies that contain or
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constitute Protected Material remain subject to this Protective Order as set forth in
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Section 4 (DURATION).
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14.
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contempt proceedings, financial or evidentiary sanctions, reference to disciplinary
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authorities, or other appropriate action at the discretion of the Court.
Any willful violation of this Order may be punished by civil or criminal
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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
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DATED: September __, 2019
GUTMAN LAW
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By:
___________
Alan S. Gutman
John Juenger
Attorneys for Plaintiff Dieter Hartmann
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Dated: September __, 2019
THEODORA ORINGER PC
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By:
Edward E. Johnson
Katherine J. Flores
Attorneys for Defendants Tyler Bates and
Tyler Bates Music, Inc.
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Dated: September __, 2019
DAVIS WRIGHT TREMAINE LLP
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By:
_________
Peter Anderson
Alonzo Wickers IV
Nicolette Vairo
Attorneys for Defendants Focus Features,
LLC and Focus Features Productions, LLC
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Attestation Regarding Signatures
The undersigned attests that all signatories listed, and on whose behalf this
filing is submitted, concur in this filing’s content and have authorized its filing.
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Dated: October 7, 2019
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____________________________
Peter Anderson, Esq.
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FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
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DATED: October 7, 2019
__________________________________
HON. MICHAEL R. WILNER
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, _____________________________ [full name], of _________________
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[full address], declare under penalty of perjury that I have read in its entirety and
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understand the Stipulated Protective Order that was issued by the United States
7
District Court Hartmann v. Bates, et al. Case No. 2:19-cv-05273-AB-MRWx. I agree
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to comply with and to be bound by all the terms of this Stipulated Protective Order
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and I understand and acknowledge that failure to so comply could expose me to
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sanctions and punishment in the nature of contempt. I solemnly promise that I will
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not disclose in any manner any information or item that is subject to this Stipulated
12
Protective Order to any person or entity except in strict compliance with the
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provisions of this Order.
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I further agree to submit to the jurisdiction of the United States District Court
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for the Central District of California for the purpose of enforcing the terms of this
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Stipulated Protective Order, even if such enforcement proceedings occur after
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termination of this action. I hereby appoint __________________________ [full
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name] of _______________________________________ [full address and
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telephone number] as my California agent for service of process in connection with
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this action or any proceedings related to enforcement of this Stipulated Protective
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Order.
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Date: ______________________________________
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City and State where signed: _________________________________
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Printed name: _______________________________
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Signature: __________________________________
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16
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