Julian Vargas et al v. Quest Diagnostics Clinical Laboratories, Inc. et al

Filing 60

PROTECTIVE ORDER by Magistrate Judge Michael R. Wilner. re Stipulation for Protective Order 59 (vm)

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OGLETREE, DEAKINS, NASH,
SMOAK & STEWART, P.C.
DAVID RAIZMAN, CA Bar No. 129407
[e-mail]
AMBER L. ROLLER, CA Bar No. 273354
[e-mail]
J. NICHOLAS MARFORI, CA Bar No. 311765
[e-mail]
400 South Hope Street, Suite 1200
Los Angeles, California 90071
Telephone: [phone]
Facsimile: 213-239-9045

Attorneys for Defendants
QUEST DIAGNOSTICS CLINICAL
LABORATORIES, INC.; QUEST
9 DIAGNOSTICS HOLDINGS, INC. and
QUEST DIAGNOSTICS INCORPORATED
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Counsel For Plaintiffs Listed on Next Page

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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JULIAN VARGAS, ANNE WEST and
AMERICAN COUNCIL OF THE
16 BLIND, individually on behalf of
themselves and all others similarly
17 situated,
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Plaintiffs,

QUEST DIAGNOSTICS CLINICAL
21 LABORATORIES, INC., QUEST
DIAGNOSTICS HOLDINGS, INC.,
22 QUEST DIAGNOSTICS
INCORPORATED; and DOES 1-10,
23 inclusive,
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STIPULATED PROTECTIVE ORDER
(MRW VERSION 4/19)
Check if submitted without material
modifications to MRW form

v.

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Case No. 2:19-cv-08108 DMG (MRWx)

Complaint Filed: September 18, 2019
Trial Date:
October 5, 2021
District Judge: Hon. Dolly M. Gee
Courtroom 8C, First St.
Magistrate Judge: Hon. Michael R. Wilner
Courtroom 550, Roybal

Defendants.

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Stipulated
Protective

Case No. 2:19-cv-08108 DMG (MRWx)
STIPULATED PROTECTIVE ORDER

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Jonathan D. Miller (Bar No. 220848)
[e-mail]
Alison M. Bernal (Bar No. 264629)
[e-mail]
NYE, STIRLING, HALE & MILLER, LLP
33 West Mission Street, Suite 201
Santa Barbara, CA 93101
Telephone: [phone]
Facsimile: [phone]
Benjamin J. Sweet
(admission pro hac vice)
[e-mail]
NYE, STIRLING, HALE & MILLER, LLP
1145 Bower Hill Road, Suite 104
Pittsburgh, PA 15243
Telephone: [phone]
Matthew K. Handley
(admitted pro hac vice)
[e-mail]
HANDLEY FARAH & ANDERSON PLLC
777 6th St. NW
Washington, DC 20001
Telephone: [phone]

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Attorneys for Plaintiffs
JULIAN VARGAS, ANNE WEST, and
20 AMERICAN COUNCIL OF THE BLIND
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Stipulated
Protective

Case No. 2:19-cv-08108 DMG (MRWx)
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Plaintiffs Julian Vargas, Anne West, and American Council of the Blind

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Inc., Quest Diagnostics Holdings, Inc., and Quest Diagnostics Incorporated

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hereby stipulate and agree as follows:

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1.

INTRODUCTION

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1.1.

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

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PURPOSES AND LIMITATIONS

proprietary, or private information for which special protection from public

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disclosure and from use for any purpose other than prosecuting this litigation may be

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warranted. Accordingly, the parties hereby stipulate to and petition the Court to

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enter the following Stipulated Protective Order. The parties acknowledge that this

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Order does not confer blanket protections on all disclosures or responses to

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discovery and that the protection it affords from public disclosure and use extends

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only to the limited information or items that are entitled to confidential treatment

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under the applicable legal principles. The parties further acknowledge, as set forth in

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Section 12.3, below, that this Stipulated Protective Order does not entitle them to file

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confidential information under seal; Civil Local Rule 79-5 sets forth the procedures

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that must be followed and the standards that will be applied when a party seeks

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permission from the court to file material under seal.

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1.2.

GOOD CAUSE STATEMENT

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Defendants provide diagnostic testing information services. Quest patient
services to

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patients, including persons with disabilities. Plaintiffs brought this putative class
inaccessible to patients with visual impairments in violation of the American with

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Stipulated
Protective

Disabled Persons Act. Plaintiffs seek certification of a nationwide class of
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STIPULATED PROTECTIVE ORDER

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individuals with visual impairments who visited a PSC in the United States, and a

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California sub-class of those visiting PSCs in California, and who were allegedly

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denied full and equal enjoyment of the goods, services, facilities, privileges,

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advantages, or accommodations because of the Kiosks.

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Accordingly, this action is likely to involve trade secrets, customer/patient lists

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and pricing information and other valuable research, development, commercial,

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financial, technical and/or proprietary information for which special protection from

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public disclosure and from use for any purpose other than prosecution of this action

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is warranted. Such confidential and proprietary materials and information consist of,

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among other things, confidential business or financial information, information

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regarding patients, 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

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protected from disclosure under state or federal statutes, court rules, case decisions,

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or common law. For Plaintiffs, confidential information is likely to consist of

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medical and financial information.

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Accordingly, to expedite the flow of information, to facilitate the prompt

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resolution of disputes over confidentiality of discovery materials, to adequately

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protect information the parties are entitled to keep confidential, to ensure that the

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parties are permitted reasonable necessary uses of such material in preparation for

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and in the conduct of trial, to address their handling at the end of the litigation, and

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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

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confidential for tactical reasons and that nothing be so designated without a good

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faith belief that it has been maintained in a confidential, non-public manner, and

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there is good cause why it should not be part of the public record of this case.

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Stipulated
Protective

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2.

DEFINITIONS
2.1

Action: Julian Vargas, et al. v. Quest Diagnostics Clinical Laboratories,

Inc., et al., U.S.D.C. Case No. 2:19-cv-08108-DMG-MRW
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Challenging Party: a Party or Non-Party that challenges the designation

of information or items under this Order.
2.3

: 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 the

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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

items that it produces in disclosures or in responses to discovery as

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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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Stipulated
Protective

2.9

Non-Party: any natural person, partnership, corporation, association, or

other legal entity not named as a Party to this action.
2.10 Outside Counsel of Record: attorneys who are not employees of a party
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.
2.11 Party: any party to this Action, including all of its officers, directors,

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employees, consultants, retained experts, and Outside Counsel of Record (and their

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support staffs).
2.12 Producing Party: a Party or Non-Party that produces Disclosure or

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Discovery Material in this Action.
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.
2.14 Protected Material: any Disclosure or Discovery Material that is

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2.15 Receiving Party: a Party that receives Disclosure or Discovery Material

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from a Producing Party.

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3.

SCOPE

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The protections conferred by this Stipulation and Order cover not only

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Protected Material (as defined above), but also (1) any information copied or

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extracted from Protected Material; (2) all copies, excerpts, summaries, or

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compilations of Protected Material; and (3) any testimony, conversations, or

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presentations by Parties or their Counsel that might reveal Protected Material.
Any use of Protected Material at trial will be governed by the orders of the

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trial judge. This Order does not govern the use of Protected Material at trial.

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Protective

4.

DURATION
Once a case proceeds to trial, all of the information that was designated as

confidential or maintained pursuant to this protective order becomes public and will
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be presumptively available to all members of the public, including the press, unless

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compelling reasons supported by specific factual findings to proceed otherwise are

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made to the trial judge in advance of the trial. See Kamakana v. City and County of

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Honolulu, 447 F.3d 1172, 1180-

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standard when merits-related documents are part of court record). Accordingly, the

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terms of this protective order do not extend beyond the commencement of the trial.

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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

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this Order must take care to limit any such designation to specific material that

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qualifies under the appropriate standards. The Designating Party must designate for

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protection only those parts of material, documents, items, or oral or written

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communications that qualify so that other portions of the material, documents, items,

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or communications for which protection is not warranted are not swept unjustifiably

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within the ambit of this Order.

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Mass, indiscriminate, or routinized designations are prohibited. Designations

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that are shown to be clearly unjustified or that have been made for an improper

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purpose (e.g., to unnecessarily encumber the case development process or to impose

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unnecessary expenses and burdens on other parties) may expose the Designating

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Party to sanctions.

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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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Stipulated
Protective

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
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STIPULATED PROTECTIVE ORDER

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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

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documents, but excluding transcripts of depositions or other pretrial or trial

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proceedings), that the Producing Party affix at a minimum, the legend

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contains protected material. If only a portion or portions of the material on a page

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qualifies for protection, the Producing Party also must clearly identify the protected

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portion(s) (e.g., by making appropriate markings in the margins).
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

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inspection and before the designation, all of the material made available for

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identified the documents it wants copied and produced, the Producing Party must

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determine which documents, or portions thereof, qualify for protection under this

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Order. Then, before producing the specified documents, the Producing Party must

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If only a portion or portions of the material on a page qualifies for protection, the

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Producing Party also must clearly identify the protected portion(s) (e.g., by making

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appropriate markings in the margins).

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(b)

for testimony given in depositions that the Designating Party identify

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the Disclosure or Discovery Material on the record, before the close of the deposition

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all protected testimony.

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(c)

for information produced in some form other than documentary and for

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Stipulated
Protective

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
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STIPULATED PROTECTIVE ORDER

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protection, the Producing Party, to the extent practicable, will identify the protected

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portion(s).
5.3

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Inadvertent Failures to Designate. An inadvertent failure to designate

qualified information or items (if promptly corrected upon discovery of such

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secure protection under this Order for such material. Upon timely correction of a

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designation, the Receiving Party must make reasonable efforts to assure that the

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material is treated in accordance with the provisions of this Order.

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6.

CHALLENGING CONFIDENTIALITY DESIGNATIONS
6.1

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

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Scheduling Order.
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. Any challenge submitted to the Court shall be made by a joint stipulation

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pursuant to Local Rule 37-2.

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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

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purpose (e.g., to harass or impose unnecessary expenses and burdens on other

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parties) may expose the Challenging Party to sanctions. Unless the Designating

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Party has waived or withdrawn the confidentiality designation, all parties will

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continue to afford the material in question the level of protection to which it is

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challenge.

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Stipulated
Protective

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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

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Receiving Party must comply with the provisions of section 13 below (FINAL

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DISPOSITION).

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Protected Material must be stored and maintained by a Receiving Party at a

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location and in a secure manner that ensures that access is limited to the persons

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authorized under this Order.

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7.2

. Unless

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otherwise ordered by the court or permitted in writing by the Designating Party, a

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Receiving Party may disclose any information or item designated

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(a)

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as employees of said Outside Counsel of Record to whom it is reasonably necessary

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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;
(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

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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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Stipulated
Protective

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(g)

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

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

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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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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
(i)

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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.

PROTECTED MATERIAL SUBPOENAED OR ORDERED

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PRODUCED IN OTHER LITIGATION

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If a Party is served with a subpoena or a court order issued in other litigation

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that compels disclosure of any information or items designated in this Action as

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(a)

promptly notify in writing the Designating Party. Such notification will

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

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

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to issue in the other litigation that some or all of the material covered by the

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subpoena or order is subject to this Protective Order. Such notification will include a

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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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Stipulated
Protective

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STIPULATED PROTECTIVE ORDER

If the Designating Party timely seeks a protective order, the Party served with

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the subpoena or court order will not produce any information designated in this

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subpoena or order issued, unless

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permission. The Designating Party will bear the burden and expense of seeking

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protection in that court of its confidential material and nothing in these provisions

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should be construed as authorizing or encouraging a Receiving Party in this Action

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to disobey a lawful directive from another court.

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9.

A NON-

TED 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

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Non-Party in this A

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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)

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produce a Non-

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subject to an agreement with the Non-Party not to produce the Non-

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confidential information, then the Party will:

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In the event that a Party is required, by a valid discovery request, to

(1)

promptly notify in writing the Requesting Party and the Non-

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

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agreement 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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Protective

(3)

make the information requested available for inspection by the

Non-Party, if requested.
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STIPULATED PROTECTIVE ORDER

(c)

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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-

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request. If the Non-Party timely seeks a protective order, the Receiving Party will

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not 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.

o the discovery

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10.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed

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Protected Material to any person or in any circumstance not authorized under this

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Stipulated Protective Order, the Receiving Party must immediately (a) notify in

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writing the Designating Party of the unauthorized disclosures, (b) use its best 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,
dgment and

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section 10 shall limit in any way the relief the Designating Party may seek or obtain

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against the Receiving Party for any violation of this Order.

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11.

INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

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PROTECTED MATERIAL

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When a Producing Party gives notice to Receiving Parties that certain

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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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Stipulated
Protective

inadvertently produced material is subject to a claim of privilege or other protection,

may be established in an e-discovery order that provides for production without prior
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STIPULATED PROTECTIVE ORDER

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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.

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

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MISCELLANEOUS

person to seek its modification by the Court in the future.
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.
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

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specific Protected Material at issue. If a Party's request to file Protected Material

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under seal is denied by the court, then the Receiving Party may file the information

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in the public record unless otherwise instructed by the court.

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13.

FINAL DISPOSITION
After the final disposition of this Action, as defined in paragraph 4, within 60

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all Protected Material to the Producing Party or destroy such material. As used in

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this s

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summaries, and any other format reproducing or capturing any of the Protected

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Stipulated
Protective

days of a written request by the Designating Party, each Receiving Party must return

Material. Whether the Protected Material is returned or destroyed, the Receiving
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STIPULATED PROTECTIVE ORDER

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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.

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Any willful violation of this Order may be punished by civil or criminal

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
Respectfully submitted,

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DATED: November 16, 2020

NYE, STIRLING, HALE & MILLER, LLP

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By: /s/ Alison M. Bernal
Jonathan D. Miller
Benjamin J. Sweet
Alison M. Bernal
Attorneys for Plaintiffs
JULIAN VARGAS, ANNE WEST, AND
AMERICAN COUNCIL OF THE BLIND

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Stipulated
Protective

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STIPULATED PROTECTIVE ORDER

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DATED: November 16, 2020

OGLETREE, DEAKINS, NASH, SMOAK &
STEWART, P.C.

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By: /s/ Amber L. Roller
David Raizman
Amber L. Roller
J. Nicholas Marfori

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Attorneys for Defendants
QUEST DIAGNOSTICS CLINICAL
LABORATORIES, INC.; QUEST
DIAGNOSTICS HOLDINGS, INC. and
QUEST DIAGNOSTICS INCORPORATED

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Certification Pursuant to Local Rule 5-4.3.4(a)(2)(i)
Pursuant to Local Rule 5-4.3.4(a)(2)(i), I, Amber L. Roller, do attest that all

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signatories listed, and on whose behalf the filing is

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content and have authorized the filing.

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Dated: November 16, 2020

By: /s/ Amber L. Roller
Amber L. Roller

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FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

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11/18/2020
DATED: ___________________

__________________________________
HON. MICHAEL R. WILNER
United States Magistrate Judge

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Stipulated
Protective

Case No. 2:19-cv-08108 DMG (MRWx)
14
STIPULATED PROTECTIVE ORDER

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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

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have read in its entirety and understand the Stipulated Protective Order that was

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issued by the United States District Court for the Central District of California on

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[date] in the case of ___________ [insert case name and number]. I agree to

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comply with and to be bound by all the terms of this Stipulated Protective Order and

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I understand and acknowledge that failure to so comply could expose me to sanctions

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and punishment in the nature of contempt. I solemnly promise that I will not disclose

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in any manner any information or item that is subject to this Stipulated Protective

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Order to any person or entity except in strict compliance with the provisions of this

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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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Stipulated
Protective

EXHIBIT A

Case No. 2:19-cv-08108 DMG (MRWx)
1
STIPULATED PROTECTIVE ORDER