Jiae Lee v. Dong Yeoun Lee et al
Filing
61
AMENDED PROTECTIVE ORDER by Magistrate Judge Pedro V. Castillo re Amended Stipulation for Protective Order 58 . (see document for details) (hr)
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UNITED STATES DISTRICT COURT
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CENTRAL DISTRICT OF CALIFORNIA
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WESTERN DIVISION
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Case No.: 2:19-CV-08814 JAK (PVCx)
JIAE LEE,
Plaintiff,
AMENDED STIPULATED
PROTECTIVE ORDER
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v.
DONG YEOUN LEE, aka DAMON
LEE; and GRACE MIN;
Complaint Filed: October 14, 2019
Defendants,
Consolidated Case: Creative Global
Investment, Inc., et al. v. Jiae Lee, et al.
(California Central District Court; Case
No. 2:19-cv-9564-JAK-FFM)
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This Amended Stipulated Protective Order supersedes the Protective Order
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Pursuant to Stipulation, previously entered in this action as Docket No. 35, to
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provide for “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY”
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designations.
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I.
PURPOSES AND LIMITATIONS
Discovery in this action is likely to involve production of confidential,
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proprietary, or private information for which special protection from public
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disclosure and from use for any purpose other than prosecuting this litigation may
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be warranted. Accordingly, the parties hereby stipulate to and petition the Court
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to enter the following Stipulated Protective Order. The parties acknowledge that
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this 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
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in Section XIII(C), below, that this Stipulated Protective Order does not entitle
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them to file confidential information under seal; Civil Local Rule 79-5 sets forth
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the procedures that must be followed and the standards that will be applied when a
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party seeks permission from the Court to file material under seal.
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II.
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GOOD CAUSE STATEMENT
This action is likely to involve trade secrets, franchise agreements,
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customer and supplier lists, sales and revenue information, and other valuable
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research, development, commercial, financial, technical and/or proprietary
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information for which special protection from public disclosure and from use for
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any purpose other than prosecution of this action is warranted. Such confidential
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and proprietary materials and information consist of, among other things,
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confidential business or financial information, information regarding confidential
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business practices, or other confidential research, development, or commercial
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information (including information implicating privacy rights of third parties),
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information otherwise generally unavailable to the public, or which may be
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privileged or otherwise protected from disclosure under state or federal statutes,
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court rules, case decisions, or common law. Accordingly, to expedite the flow of
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information, to facilitate the prompt resolution of disputes over confidentiality of
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discovery materials, to adequately protect information the parties or non-parties
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are entitled to keep confidential, to ensure that the parties are permitted reasonable
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necessary uses of such material in preparation for and in the conduct of trial, to
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address their handling at the end of the litigation, and serve the ends of justice, a
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protective order for such information is justified in this matter. It is the intent of
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the parties that information will not be designated as confidential or highly
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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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III.
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DEFINITIONS
A.
Action: The lead action entitled Jiae Lee v. Dong Yeoun Lee, et al.
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(Central District of California, Western Division, Case No. 2:19-cv-08814-JAK-
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PVC), as well as the consolidated action entitled Creative Global Investment, Inc.,
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et al. v. Jiae Lee, et al. (Central District of California, Western Division, Case No.
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2:19-cv-9564-JAK-FFM).
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B.
Challenging Party: A Party or Non-Party that challenges the
designation of information or items under this Order.
C.
“CONFIDENTIAL” Information or Items: Information (regardless
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of 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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D.
Counsel: Outside Counsel of Record and House Counsel (as well as
their support staff).
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Designating Party: A Party or Non-Party that designates information
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or items that it produces in disclosures or in responses to discovery as
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“CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
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ONLY.”
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F.
Disclosure or Discovery Material: All items or information,
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regardless of the medium or manner in which it is generated, stored, or maintained
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(including, among other things, testimony, transcripts, and tangible things), that
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are produced or generated in disclosures or responses to discovery in this matter.
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G.
Expert: A person with specialized knowledge or experience in a
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matter pertinent to the litigation who has been retained by a Party or its counsel to
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serve as an expert witness or as a consultant in this Action.
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H.
“HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY”
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Information or Items: Extremely sensitive “Confidential Information or Items,”
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disclosure of which to another Party or Non-Party would create a substantial risk
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of serious harm that could not be avoided by less restrictive means.
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I.
House Counsel: Attorneys who are employees of a party to this
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Action. House Counsel does not include Outside Counsel of Record or any other
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outside counsel.
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Non-Party: Any natural person, partnership, corporation, association,
or other legal entity not named as a Party to this action.
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Outside Counsel of Record: Attorneys who are not employees of a
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party to this Action but are retained to represent or advise a party to this Action
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and have appeared in this Action on behalf of that party or are affiliated with a law
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firm that has appeared on behalf of that party, and includes support staff.
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L.
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Party: Any party to this Action, including all of its officers,
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directors, employees, consultants, retained experts, and Outside Counsel of
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Record (and their support staffs).
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Producing Party: A Party or Non-Party that produces Disclosure or
Discovery Material in this Action.
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Professional Vendors: Persons or entities that provide litigation
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support services (e.g., photocopying, videotaping, translating, preparing exhibits
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or demonstrations, and organizing, storing, or retrieving data in any form or
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medium) and their employees and subcontractors.
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Protected Material: Any Disclosure or Discovery Material that is
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designated as “CONFIDENTIAL,” or as “HIGHLY CONFIDENTIAL –
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ATTORNEYS’ EYES ONLY.”
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Receiving Party: A Party that receives Disclosure or Discovery
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Material from a Producing Party.
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IV.
SCOPE
A.
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The protections conferred by this Stipulation and Order cover not
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only 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.
B.
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Any use of Protected Material at trial shall be governed by the orders
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of the trial judge. This Order does not govern the use of Protected Material at
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trial.
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V.
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DURATION
Even after final disposition of this litigation, the confidentiality obligations
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imposed by this Order shall remain in effect until a Designating Party agrees
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otherwise in writing or a court order otherwise directs. Final disposition shall be
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deemed to be the later of (1) dismissal of all claims and defenses in this Action,
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with or without prejudice; and (2) final judgment herein after the completion and
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exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action,
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including the time limits for filing any motions or applications for extension of
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time pursuant to applicable law.
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VI.
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DESIGNATING PROTECTED MATERIAL
A.
Exercise of Restraint and Care in Designating Material for
Protection.
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Each Party or Non-Party that designates information or items
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for protection under this Order must take care to limit any such
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designation to specific material that qualifies under the appropriate
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standards. The Designating Party must designate for protection only
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those parts of material, documents, items, or oral or written
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communications that qualify so that other portions of the material,
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documents, items, or communications for which protection is not
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warranted are not swept unjustifiably within the ambit of this Order.
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2.
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Designations that are shown to be clearly unjustified or that have
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been made for an improper purpose (e.g., to unnecessarily encumber
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the case development process or to impose unnecessary expenses and
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burdens on other parties) may expose the Designating Party to
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sanctions.
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3.
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or items that it designated for protection do not qualify for protection,
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that Designating Party must promptly notify all other Parties that it is
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withdrawing the inapplicable designation.
Mass, indiscriminate, or routinized designations are prohibited.
If it comes to a Designating Party’s attention that information
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B.
Manner and Timing of Designations.
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Except as otherwise provided in this Order (see, e.g., Section
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B(2)(b) below), or as otherwise stipulated or ordered, Disclosure or
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Discovery Material that qualifies for protection under this Order must
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be clearly so designated before the material is disclosed or produced.
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2.
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following:
Designation in conformity with this Order requires the
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a.
For information in documentary form (e.g., paper or
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electronic documents, but excluding transcripts of depositions
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or other pretrial or trial proceedings), that the Producing Party
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affix the legend “CONFIDENTIAL” or “HIGHLY
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CONFIDENTIAL – ATTORNEYS’ EYES ONLY” to each
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page that contains protected material. If only a portion or
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portions of the material on a page qualifies for protection, the
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Producing Party also must clearly identify the protected
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portion(s) (e.g., by making appropriate markings in the
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margins) and must specify, for each portion, the level of
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protection being asserted.
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b.
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available for inspection need not designate them for protection
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until after the inspecting Party has indicated which documents
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it would like copied and produced. During the inspection and
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before the designation, all of the material made available for
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inspection shall be deemed “HIGHLY CONFIDENTIAL –
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ATTORNEYS’ EYES ONLY.” After the inspecting Party has
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identified the documents it wants copied and produced, the
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Producing Party must determine which documents, or portions
A Party or Non-Party that makes original documents
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thereof, qualify for protection under this Order. Then, before
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producing the specified documents, the Producing Party must
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affix the appropriate legend (“CONFIDENTIAL” or
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“HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
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ONLY”) to each page that contains Protected Material. If only
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a portion or portions of the material on a page qualifies for
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protection, the Producing Party also must clearly identify the
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protected portion(s) (e.g., by making appropriate markings in
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the margins) and must specify, for each portion, the level of
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protection being asserted.
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c.
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Party identify on the record, before the close of the deposition,
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all protected testimony and specify the level of protection
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being asserted.
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d.
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documentary and for any other tangible items, that the
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Producing Party affix in a prominent place on the exterior of
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the container or containers in which the information or item is
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stored the legend “CONFIDENTIAL” or “HIGHLY
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CONFIDENTIAL – ATTORNEYS’ EYES ONLY.” If only a
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portion or portions of the information or item warrants
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protection, the Producing Party, to the extent practicable, shall
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identify the protected portion(s) and specify the level of
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protection being asserted.
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C.
For testimony given in deposition, that the Designating
For information produced in some form other than
Inadvertent Failure to Designate.
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If timely corrected, an inadvertent failure to designate qualified
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information or items does not, standing alone, waive the Designating
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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
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make reasonable efforts to assure that the material is treated in
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accordance with the provisions of this Order.
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VII. CHALLENGING CONFIDENTIALITY DESIGNATIONS
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A.
Timing of Challenges.
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confidentiality at any time that is consistent with the Court’s
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Scheduling Order.
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B.
Any Party or Non-Party may challenge a designation of
Meet and Confer.
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The Challenging Party shall initiate the dispute resolution
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process under Local Rule 37.1 et seq.
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C.
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on the Designating Party. Frivolous challenges, and those made for an
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improper purpose (e.g., to harass or impose unnecessary expenses and
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burdens on other parties) may expose the Challenging Party to sanctions.
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Unless the Designating Party has waived or withdrawn the confidentiality
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designation, all parties shall continue to afford the material in question the
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level of protection to which it is entitled under the Producing Party’s
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designation until the Court rules on the challenge.
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The burden of persuasion in any such challenge proceeding shall be
VIII. ACCESS TO AND USE OF PROTECTED MATERIAL
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Basic Principles
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A Receiving Party may use Protected Material that is disclosed
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or produced by another Party or by a Non-Party in connection with
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this Action only for prosecuting, defending, or attempting to settle
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this Action. Such Protected Material may be disclosed only to the
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categories of persons and under the conditions described in this
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Order. When the Action has been terminated, a Receiving Party must
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comply with the provisions of Section XIV below (FINAL
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DISPOSITION).
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2.
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Receiving Party at a location and in a secure manner that ensures that
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access is limited to the persons authorized under this Order.
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B.
Protected Material must be stored and maintained by a
Disclosure of “CONFIDENTIAL” Information or Items
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Unless otherwise ordered by the Court or permitted in writing
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by the Designating Party, a Receiving Party may disclose any
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information or item designated “CONFIDENTIAL” only to:
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a.
The Receiving Party’s Outside Counsel of Record in this
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Action, as well as employees of said Outside Counsel of
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Record to whom it is reasonably necessary to disclose the
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information for this Action;
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b.
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Counsel) of the Receiving Party to whom disclosure is
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reasonably necessary for this Action, and, if the Receiving
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Party is an individual, the Receiving Party himself or herself;
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c.
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to whom disclosure is reasonably necessary for this Action and
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who have signed the “Acknowledgment and Agreement to Be
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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
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Professional Vendors to whom disclosure is reasonably
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necessary for this Action and who have signed the
The officers, directors, and employees (including House
Experts (as defined in this Order) of the Receiving Party
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“Acknowledgment and Agreement to be Bound” attached as
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Exhibit A hereto;
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g.
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information or a custodian or other person who otherwise
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possessed or knew the information;
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h.
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witnesses, in the Action to whom disclosure is reasonably
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necessary provided: (i) the deposing party requests that the
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witness sign the “Acknowledgment and Agreement to Be
The author or recipient of a document containing the
During their depositions, witnesses, and attorneys for
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Bound;” and (ii) they will not be permitted to keep any
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confidential information unless they sign the
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“Acknowledgment and Agreement to Be Bound,” unless
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otherwise agreed by the Designating Party or ordered by the
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Court. Pages of transcribed deposition testimony or exhibits to
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depositions that reveal Protected Material may be separately
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bound by the court reporter and may not be disclosed to
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anyone except as permitted under this Stipulated Protective
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Order; and
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i.
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personnel, mutually agreed upon by any of the parties engaged
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in settlement discussions.
Any mediator or settlement officer, and their supporting
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C.
Disclosure of “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
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ONLY” Information or Items
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1.
Unless otherwise ordered by the Court or permitted in writing
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by the Designating Party, a Receiving Party may disclose any
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information or item designated “HIGHLY CONFIDENTIAL –
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ATTORNEYS’ EYES ONLY” only to:
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a.
The Receiving Party’s Outside Counsel of Record in this
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Action, as well as employees of said Outside Counsel of
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Record to whom it is reasonably necessary to disclose the
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information for this Action;
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b.
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to whom disclosure is reasonably necessary for this Action and
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who have signed the “Acknowledgment and Agreement to Be
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Bound” (Exhibit A);
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c.
The Court and its personnel;
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d.
Court reporters and their staff;
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e.
Professional jury or trial consultants, mock jurors, and
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Professional Vendors to whom disclosure is reasonably
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necessary for this Action and who have signed the
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“Acknowledgment and Agreement to be Bound” attached as
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Exhibit A hereto;
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f.
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information or a custodian or other person who otherwise
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possessed or knew the information;
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g.
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witnesses, in the Action to whom disclosure is reasonably
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necessary provided: (i) the deposing party requests that the
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witness sign the “Acknowledgment and Agreement to Be
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Bound;” and (ii) they will not be permitted to keep any
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confidential information unless they sign the
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“Acknowledgment and Agreement to Be Bound,” unless
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otherwise agreed by the Designating Party or ordered by the
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Court. Pages of transcribed deposition testimony or exhibits to
Experts (as defined in this Order) of the Receiving Party
The author or recipient of a document containing the
During their depositions, witnesses, and attorneys for
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depositions that reveal Protected Material may be separately
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bound by the court reporter and may not be disclosed to
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anyone except as permitted under this Stipulated Protective
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Order; and
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h.
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personnel, mutually agreed upon by any of the parties engaged
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in settlement discussions.
Any mediator or settlement officer, and their supporting
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IX.
PROTECTED MATERIAL SUBPOENAED OR ORDERED
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PRODUCED IN OTHER LITIGATION
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A.
If a Party is served with a subpoena or a court order issued in other
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litigation that compels disclosure of any information or items designated in
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this Action as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL –
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ATTORNEYS’ EYES ONLY” that Party must:
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Promptly notify in writing the Designating Party. Such
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notification shall include a copy of the subpoena or court order;
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2.
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or order to issue in the other litigation that some or all of the material
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covered by the subpoena or order is subject to this Protective Order.
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Such notification shall include a copy of this Stipulated Protective
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Order; and
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3.
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be pursued by the Designating Party whose Protected Material may
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be affected.
Promptly notify in writing the party who caused the subpoena
Cooperate with respect to all reasonable procedures sought to
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B.
If the Designating Party timely seeks a protective order, the Party
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served with the subpoena or court order shall not produce any information
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designated in this action as “CONFIDENTIAL” or “HIGHLY
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CONFIDENTIAL – ATTORNEYS’ EYES ONLY” before a determination
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by the Court from which the subpoena or order issued, unless the Party has
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obtained the Designating Party’s permission. The Designating Party shall
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bear the burden and expense of seeking protection in that court of its
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confidential material and nothing in these provisions should be construed as
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authorizing or encouraging a Receiving Party in this Action to disobey a
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lawful directive from another court.
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X.
A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
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PRODUCED IN THIS LITIGATION
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A.
The terms of this Order are applicable to information produced by a
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Non-Party in this Action and designated as “CONFIDENTIAL” or
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“HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY.” Such
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information produced by Non-Parties in connection with this litigation is
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protected by the remedies and relief provided by this Order. Nothing in
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these provisions should be construed as prohibiting a Non-Party from
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seeking additional protections.
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B.
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produce a Non-Party’s confidential information in its possession, and the
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Party is subject to an agreement with the Non-Party not to produce the Non-
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Party’s confidential information, then the Party shall:
In the event that a Party is required, by a valid discovery request, to
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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
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confidentiality agreement with a Non-Party;
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2.
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Protective Order in this Action, the relevant discovery request(s), and
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a reasonably specific description of the information requested; and
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3.
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Non-Party, if requested.
Promptly provide the Non-Party with a copy of the Stipulated
Make the information requested available for inspection by the
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C.
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14 days of receiving the notice and accompanying information, the
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Receiving Party may produce the Non-Party’s confidential information
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responsive to the discovery request. If the Non-Party timely seeks a
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protective order, the Receiving Party shall not produce any information in
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its possession or control that is subject to the confidentiality agreement with
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the Non-Party before a determination by the court. Absent a court order to
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the contrary, the Non-Party shall bear the burden and expense of seeking
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protection in this court of its Protected Material.
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XI.
If the Non-Party fails to seek a protective order from this court within
UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
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A.
If a Receiving Party learns that, by inadvertence or otherwise, it has
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disclosed Protected Material to any person or in any circumstance not
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authorized under this Stipulated Protective Order, the Receiving Party must
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immediately (1) notify in writing the Designating Party of the unauthorized
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disclosures, (2) use its best efforts to retrieve all unauthorized copies of the
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Protected Material, (3) inform the person or persons to whom unauthorized
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disclosures were made of all the terms of this Order, and (4) request such
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person or persons to execute the “Acknowledgment and Agreement to be
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Bound” that is attached hereto as Exhibit A.
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XII. INADVERTENT PRODUCTION OF PRIVILEGED OR
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OTHERWISE PROTECTED MATERIAL
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A.
When a Producing Party gives notice to Receiving Parties that certain
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inadvertently produced material is subject to a claim of privilege or other
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protection, the obligations of the Receiving Parties are those set forth in
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Federal Rule of Civil Procedure 26(b)(5)(B). This provision is not intended
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to modify whatever procedure may be established in an e-discovery order
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that provides for production without prior privilege review.
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XIII. MISCELLANEOUS
A.
Right to Further Relief.
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1.
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its modification by the Court in the future.
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B.
Nothing in this Order abridges the right of any person to seek
Right to Assert Other Objections.
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1.
By stipulating to the entry of this Protective Order, no Party
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waives any right it otherwise would have to object to disclosing or
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producing any information or item on any ground not addressed in
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this Stipulated Protective Order. Similarly, no Party waives any right
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to object on any ground to use in evidence of any of the material
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covered by this Protective Order.
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C.
Filing Protected Material
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1.
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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
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sealing of the specific Protected Material at issue. If a Party's request
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to file Protected Material under seal is denied by the Court, then the
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Receiving Party may file the information in the public record unless
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otherwise instructed by the Court.
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A Party that seeks to file under seal any Protected Material
XIV. FINAL DISPOSITION
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A.
After the final disposition of this Action, as defined in Section V,
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within sixty (60) days of a written request by the Designating Party, each
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Receiving Party must return all Protected Material to the Producing Party or
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destroy such material. As used in this subdivision, “all Protected Material”
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includes all copies, abstracts, compilations, summaries, and any other
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format reproducing or capturing any of the Protected Material. Whether the
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Protected Material is returned or destroyed, the Receiving Party must
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EXHIBIT A
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
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I,
[print or type full name], of
[print or type full address], declare under penalty of perjury
that I have read in its entirety and understand the Amended Stipulated Protective
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Order that was issued by the United States District Court for the Central District
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of California in the case of Jiae Lee v. Dong Yeoun Lee, et al., Case No. 2:19-cv-
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08814-JAK-PVC. I agree to comply with and to be bound by all the terms of this
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Amended Stipulated Protective Order and I understand and acknowledge that
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failure to so comply could expose me to sanctions and punishment in the nature of
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contempt. I solemnly promise that I will not disclose in any manner any
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information or item that is subject to this Amended Stipulated Protective Order to
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any person or entity except in strict compliance with the provisions of this Order.
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I further agree to submit to the jurisdiction of the United States District
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Court for the Central District of California for the purpose of enforcing the terms
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of this Amended Stipulated Protective Order, even if such enforcement
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proceedings occur after termination of this action. I hereby appoint
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[print or type full name] of
[print or type full address and telephone number] as my California agent for
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service of process in connection with this action or any proceedings related to
enforcement of this Amended Stipulated Protective Order.
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Date:
City and State where sworn and signed:
Printed Name:
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Signature:
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