Richard Leslie v. The Goodyear Tire and Rubber Company, et al

Filing 18

JOINT STIPULATED PROTECTIVE ORDER 17 by Magistrate Judge Maria A. Audero. [See document for details.] (es)

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JOSEPH M. LOVRETOVICH, Bar No. 73403
JARED W. BEILKE, Bar No. 195698
KARINA GODOY, Bar No. 305895
JML LAW
5855 Topanga Canyon Blvd., Suite 300
Woodland Hills, CA 91367
Telephone: [phone]
Facsimile: 818.610.3030
Attorneys for Plaintiff
RICHARD LESLIE
SARAH E. ROSS, Bar No. 252206
[e-mail]
LITTLER MENDELSON, P.C.
2049 Century Park East, 5th Floor
Los Angeles, CA 90067.3107
Telephone: [phone]
Facsimile: 310.553.5583
RAE CHUNG, Bar No. 318300
[e-mail]
LITTLER MENDELSON, P.C.
633 West 5th Street
63rd Floor
Los Angeles, CA 90071
Telephone: [phone]
Facsimile: 213.443.4299
Attorneys for Defendant
THE GOODYEAR TIRE & RUBBER COMPANY

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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LITTLE R MEND ELSO N, P .C .
D
2049 C entury Park East
5th Floor
Los Angeles, CA 90067.3107
310.553.0308

RICHARD LESLIE,
Plaintiff,
v.
THE GOODYEAR TIRE & RUBBER
COMPANY, an Ohio Corporation and
DOES 1-20, inclusive,
Defendants.

Case No.
ASSIGNED TO THE HONORABLE
JUDGE DOLLY M. GEE
JOINT STIPULATED PROTECTIVE
ORDER
Trial date: None set
Complaint filed: April 1, 2020
(filed in Los Angeles superior court)

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1.

PURPOSES AND LIMITATIONS

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

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proprietary, or private information for which special protection from public disclosure

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

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Accordingly, the parties hereby stipulate to and petition the Court to enter the following

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Stipulated Protective Order. The parties acknowledge that this Stipulated Protective

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

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the

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

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applicable legal principles. The parties further acknowledge, as set forth in Section 13.3

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

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information under seal; Local Rule 79-5 sets forth the procedures that must be followed

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and the standards that will be applied when a party seeks permission from the Court to

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file material under seal. Discovery in this action is likely to involve production of

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confidential, proprietary, or private information for which special protection from

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

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may be warranted.

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2.

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GOOD CAUSE STATEMENT
This action is likely to involve confidential, non-public, sensitive, and/or

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proprietary trade secrets, business, emp

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identifiable information, documents and other materials for which special protection

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

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action is warranted. Such confidential and proprietary materials and information consist

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of, among other things, confidential business or financial information, information

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regarding confidential business practices, or other confidential research, development,

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or commercial information (including information implicating privacy rights of third

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parties), 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, court

LITTLE R MEND ELSO N, P .C .
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5th Floor
Los Angeles, CA 90067.3107
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2.

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rules, case decisions, or common law. A

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to facilitate the prompt resolution of disputes over confidentiality of discovery

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materials, to adequately protect information the parties are entitled to keep confidential,

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to ensure that the parties are permitted reasonable necessary uses of such material in

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

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litigation, and to serve the ends of justice, a protective order for such information is

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justified in this matter. It is the intent of the parties that information will not be

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designated as confidential for tactical reasons and that nothing be so designated without

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a good 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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3.

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DEFINITIONS
3.1.

Does 1 through 20, inclusive, Case No.

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3.2.

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Challenging Party: A Party or Nonparty that challenges the designation of
information or items under this Stipulated Protective Order.

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Action: Richard Leslie v. The Goodyear Tire & Rubber Company, and

3.3.

“CONFIDENTIAL” Information or Items: Information (regardless of how

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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

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above in the Good Cause Statement.

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3.4.

their support staff).

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Counsel: Outside Counsel of Record and In-House Counsel (as well as

3.5.

Designating Party: A Party or Nonparty that designates information or

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

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“CONFIDENTIAL.”

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3.6.

Disclosure or Discovery Material: All items or information, regardless of

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the medium or manner in which it is generated, stored, or maintained

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(including, among other things, testimony, transcripts, and tangible

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things), that are produced or generated in disclosures or responses to

LITTLE R MEND ELSO N, P .C .
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discovery in this matter.

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3.7.

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pertinent to the litigation who has been retained by a Party or its counsel

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3.8.

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In-House Counsel: Attorneys who are employees of a party to this Action.

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In-House Counsel does not include Outside Counsel of Record or any other

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outside counsel.
3.9.

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Nonparty: Any natural person, partnership, corporation, association, or
other legal entity not named as a Party to this action.

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3.10. Outside Counsel of Record: Attorneys who are not employees of a party

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to this Action but are retained to represent or advise a party to this Action

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and have appeared in this Action on behalf of that party or are affiliated

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with a law firm which has appeared on behalf of that party, and includes

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support staff.

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3.11. Party: Any party to this Action, including all of its officers, directors,

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In-House Counsel, and Outside
Counsel of Record (and their support staffs).

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3.12. Producing Party:

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A Party or Nonparty that produces Disclosure or

Discovery Material in this Action.

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3.13. Professional Vendors: Persons or entities that provide litigation support

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or demonstrations, and organizing, storing, or retrieving data in any form

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or medium) and their employees and subcontractors.

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3.14. Protected Material:

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designated as “CONFIDENTIAL.”

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3.15. Receiving Party: A Party that receives Disclosure or Discovery Material

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LITTLE R MEND ELSO N, P .C .
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Los Angeles, CA 90067.3107
310.553.0308

Any Disclosure or Discovery Material that is

from a Producing Party.
4.

SCOPE
4.

The protections conferred by this Stipulated Protective Order cover not only

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Protected Material, but also (1)

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Material; (2)

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(3) any testimony, conversations, or presentations by Parties or their Counsel that might

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reveal Protected Material.

erial; and

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Any use of Protected Material at trial shall be governed by the orders of the trial

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judge. This Stipulated Protective Order does not govern the use of Protected Material

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at trial.

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5.

DURATION

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Even after final disposition of this litigation, the confidentiality obligations

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imposed by this Stipulated Protective Order shall remain in effect until a Designating

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Party agrees otherwise in writing or a court order otherwise directs. Final disposition

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shall be 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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ppeals, rehearings, remands, trials, or reviews of this Action,

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pursuant to applicable law.

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6.

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DESIGNATING PROTECTED MATERIAL
6.1.

ting Material for Protection.

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Each Party or Nonparty that designates information or items for

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protection under this Stipulated Protective Order must take care to limit

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any such designation to specific material that qualifies under the

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appropriate standards.

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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,

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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 Stipulated

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Protective Order.

LITTLE R MEND ELSO N, P .C .
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5th Floor
Los Angeles, CA 90067.3107
310.553.0308

The Designating Party must designate for

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Mass, indiscriminate, or routinized designations are prohibited.

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Designations that are shown to be clearly unjustified or that have been

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made for an improper purpose (e.g., to unnecessarily encumber the case

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he Designating Party to sanctions.

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6.2.

Manner and Timing of Designations.

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Stipulated Protective Order

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(see, e.g., Section 6.2(a)), or as otherwise stipulated or ordered, Disclosure

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or Discovery Material that qualifies for protection under this Stipulated

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Protective Order must be clearly so designated before the material is

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disclosed or produced.
Designation in conformity with this Stipulated Protective Order

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requires the following:

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(a)

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

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or

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the legend “CONFIDENTIAL” to each page that contains protected

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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

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identify the protected portion(s) (e.g., by making appropriate

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markings in the margins).

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A Party or Nonparty that makes original documents available

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for inspection need not designate them for protection until after the

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inspecting Party has indicated which documents it would like copied

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and produced. During the inspection and before the designation, all

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of the material made available for inspection shall be deemed

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“CONFIDENTIAL.” After the inspecting Party has identified the

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documents it wants copied and produced, the Producing Party must

LITTLE R MEND ELSO N, P .C .
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Los Angeles, CA 90067.3107
310.553.0308

6.

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determine which documents, or portions thereof, qualify for

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protection under this Stipulated Protective Order. Then, before

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the legend “CONFIDENTIAL” to each page that contains Protected

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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

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identify the protected portion(s) (e.g., by making appropriate

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markings in the margins).
(b)

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For testimony given in depositions, that the Designating Party

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identify the Disclosure or Discovery Material on the record, before

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the close of the deposition, all protected testimony.
(c)

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For information produced in nondocumentary form, and for any
other tangible items,

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information is stored the legend “CONFIDENTIAL.” If only a

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portion or portions of the information warrants protection, the

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protected portion(s).

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6.3.

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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 Stipulated Protective Order for

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such material. Upon timely correction of a designation, the Receiving

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Party must make reasonable efforts to assure that the material is treated in

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accordance with the provisions of this Stipulated Protective Order.

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LITTLE R MEND ELSO N, P .C .
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2049 C entury Park East
5th Floor
Los Angeles, CA 90067.3107
310.553.0308

7.

CHALLENGING CONFIDENTIALITY DESIGNATIONS
7.1.

Timing of Challenges.
Any Party or Nonparty may challenge a designation of
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confidentiality at any time that is consistent with the Court’s Scheduling

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Order.
7.2.

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Meet and Confer.
The Challenging Party shall initiate the dispute resolution process,

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which shall comply with Local Rule 37.1 et seq., and with

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Section 4 of Judge Audero’s Procedures (“Mandatory Telephonic

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Conference for Discovery Disputes”). 1
7.3.

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Burden of Persuasion.

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The burden of persuasion in any such challenge proceeding shall be

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on the Designating Party. Frivolous challenges, and those made for an

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improper purpose (e.g.

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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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8.

ACCESS TO AND USE OF PROTECTED MATERIALS
8.1.

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Basic Principles.

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A Receiving Party may use Protected Material that is disclosed or

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produced by another Party or by a Nonparty in connection with this Action

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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

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under the conditions described in this Stipulated Protective Order. When

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the Action reaches a final disposition, a Receiving Party must comply with

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the provisions of Section 14 below (FINAL DISPOSITION).
Protected Material must be stored and maintained by a Receiving

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LITTLE R MEND ELSO N, P .C .
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2049 C entury Park East
5th Floor
Los Angeles, CA 90067.3107
310.553.0308

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Judge Audero’s Procedures are available at
https://www.cacd.uscourts.gov/honorable-maria-audero.
8.

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Party at a location and in a secure manner that ensures that access is limited

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to the persons authorized under this Stipulated Protective Order.

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8.2.

Disclosure of “CONFIDENTIAL” Information or Items.

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Unless otherwise ordered by the Court or permitted in writing by the

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Designating Party, a Receiving Party may disclose any information or item

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designated “CONFIDENTIAL” only to:

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(a)

The Receiving Party’s Outside Counsel of Record, as well as

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employees of said Outside Counsel of Record to whom it is

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reasonably necessary to disclose the information for this Action;

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(b)

The officers, directors, and employees (including In-House

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Counsel) of the Receiving Party to whom disclosure is reasonably

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necessary for this Action;

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(c)

disclosure is reasonably
necessary

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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 or this Action

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and who have signed the “Acknowledgment and Agreement to be

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(g)

The author or recipient of a document containing the information or

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a custodian or other person who otherwise possessed or knew the

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information;

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(h)

During their depositions, witnesses, and attorneys for witnesses, in

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the Action to whom disclosure is reasonably necessary provided:

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(i) the deposing party requests that the witness sign the

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“Acknowledgment and Agreement to Be Bound

LITTLE R MEND ELSO N, P .C .
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Los Angeles, CA 90067.3107
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and

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(ii) the witness will not be permitted to keep any confidential

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information unless they sign the “Acknowledgment and Agreement

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to Be Bound,” unless otherwise agreed by the Designating Party or

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ordered by the Court. Pages of transcribed deposition testimony or

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separately bound by the court reporter and may not be disclosed to

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under this Stipulated Protective Order;
and

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(i)

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Any mediator or settlement officer, and their supporting personnel,

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mutually agreed upon by any of the parties engaged in settlement

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discussions.

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9.

PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED

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IN OTHER LITIGATION

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

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

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“CONFIDENTIAL,” that Party must:

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(a)

include a copy of the subpoena or court order;

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Promptly notify in writing the Designating Party. Such notification shall

(b)

Promptly notify in writing the party who caused the subpoena or order to

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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 Stipulated Protective Order. Such

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notification shall include a copy of this Stipulated Protective Order; and

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(c)

Cooperate with respect to all reasonable procedures sought to be pursued

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by the Designating Party whose Protected Material may be affected.

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

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subpoena or court order shall not produce any information designated in this action as

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“CONFIDENTIAL” before a determination by the Court from which the subpoena or

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order issued, unless the Party has obtained the Designating Party’s permission. The

LITTLE R MEND ELSO N, P .C .
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10.

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of its 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 lawful directive

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from another court.

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10.

A

NONPARTY’S

PROTECTED

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SOUGHT

TO

BE

PRODUCED IN THIS LITIGATION

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MATERIAL

10.1. Application.

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The terms of this Stipulated Protective Order are applicable to

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information produced by a Nonparty in this Action and designated as

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“CONFIDENTIAL.”

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connection with this litigation is protected by the remedies and relief

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provided by this Stipulated Protective Order. Nothing in these provisions

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should be construed as prohibiting a Nonparty from seeking additional

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protections.

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Such information produced by Nonparties in

10.2. Notification.

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

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produce a Nonparty’s confidential information in its possession, and the

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Party is subject to an agreement with the Nonparty not to produce the

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Nonparty’s confidential information, then the Party shall:

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(a)

Promptly notify in writing the Requesting Party and the Nonparty

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

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confidentiality agreement with a Nonparty;

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(b)

Promptly provide the Nonparty with a copy of the Stipulated

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

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and a reasonably specific description of the information requested;

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and

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LITTLE R MEND ELSO N, P .C .
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(c)

Make the information requested available for inspection by the
Nonparty, if requested.
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10.3. Conditions of Production.

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If the Nonparty fails to seek a protective order from this Court within

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fourteen (14) days after receiving the notice and accompanying

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information, the Receiving Party may produce the Nonparty’s confidential

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information responsive to the discovery request. If the Nonparty timely

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seeks a protective order, the Receiving Party shall not produce any

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information in its possession or control that is subject to the confidentiality

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agreement with the Nonparty before a determination by the Court. Absent

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a court order to the contrary, the Nonparty shall bear the burden and
s Court of its Protected Material.

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11.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

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

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Stipulated Protective Order, the Receiving Party immediately must (1) notify in writing

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the Designating Party of the unauthorized disclosures, (2) use its best efforts to retrieve

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all unauthorized copies of the Protected Material, (3) inform the person or persons to

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whom unauthorized disclosures were made of all the terms of this Stipulated Protective

18

Order, and (4) request

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12.

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

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the obligations of the Receiving Parties are those set forth in Federal Rule of Civil

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Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure

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

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privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the

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parties reach an agreement on the effect of disclosure of a communication or

LITTLE R MEND ELSO N, P .C .
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12.

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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 to

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the Court.

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13.

MISCELLANEOUS
13.1. Right to Further Relief.

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Nothing in this Stipulated Protective Order abridges the right of any

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

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13.2. Right to Assert Other Objections.

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By stipulating to the entry of this Stipulated Protective Order, no

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Party 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 this

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Stipulated Protective Order. Similarly, no Party waives any right to object

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on any ground to use in evidence of any of the material covered by this

14

Stipulated Protective Order.
13.3. Filing Protected Material.

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A Party that seeks to file under seal any Protected Material must

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comply with Local Rule 79-5. Protected Material may only be filed under

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seal pursuant to a court order authorizing the sealing of the specific

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

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

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information in the public record unless otherwise instructed by the Court.

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14.

FINAL DISPOSITION

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request by the Designating Party, each Receiving Party must return all Protected

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Material to the Producing Party or destroy such material. As used in this subdivision,

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“all Protected Material” includes all copies, abstracts, compilations, summaries, and

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any other 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 submit a written

LITTLE R MEND ELSO N, P .C .
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Los Angeles, CA 90067.3107
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13.

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certification to the Producing Party (and, if not the same person or entity, to the

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Designating Party) by the 60-day deadline that (1) identifies (by category, where

3

appropriate) all the Protected Material that was returned or destroyed and (2) affirms

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that the Receiving Party has not retained any copies, abstracts, compilations, summaries

5

or any other format reproducing or capturing any of the Protected Material.

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Notwithstanding this provision, Counsel is entitled to retain an archival copy of all

7

pleadings; motion papers; trial, deposition, and hearing transcripts; legal memoranda;

8

correspondence;

;

; attorney work product;

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10

Material. Any such archival copies that contain or constitute Protected Material remain

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subject to this Stipulated Protective Order as set forth in Section 5.

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15.

VIOLATION

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

14

measures including, without limitation, contempt proceedings and/or monetary

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sanctions.

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14.

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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
Dated: October 9, 2020

JOSEPH M. LOVRETOVICH
JARED W. BEILKE
KARINA GODOY
JML LAW
Attorneys for Plaintiff
RICHARD LESLIE
CHARD

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Dated: October 12, 2020

SARAH E. ROSS
ARAH
AE
RAE Y. CHUNG
LITTLER MENDELSON, P.C.
Attorneys for Defendant
THE GOODYEAR TIRE & RUBBER
COMPANY

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FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
Dated: 10/14/20

Maria A. Audero
United States Magistrate Judge

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LITTLE R MEND ELSO N, P .C .
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5th Floor
Los Angeles, CA 90067.3107
310.553.0308

15.

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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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[address], declare under penalty of perjury that I have read in its

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entirety and understand the Stipulated Protective Order that was issued by the United

6

States District Court for the Central District of California on

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the case of RICHARD LESLIE v. THE GOODYEAR TIRE & RUBBER COMPANY,

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and DOES 1-20, Case No.

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to be bound by all the terms of this Stipulated Protective Order, and I understand and

[date] in

I agree to comply with and

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11

the nature of contempt. I solemnly promise that I will not disclose in any manner any

12

information or item that is subject to this Stipulated Protective Order to any person or

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Stipulated Protective Order.

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I further agree to submit to the jurisdiction of the United States District Court for
the Central District of California for the purpose of enforcing the terms of this Stipulated
Protective Order, even if such enforcement proceedings occur after termination of this
action. I hereby appoint

[full name] of
[address and telephone number] as my California

agent for service of process in connection with this action or any proceedings related to
enforcement of this Stipulated Protective Order.
Signature:
Printed Name:
Date:
City and State Where Sworn and Signed:

27
28
LITTLE R MEND ELSO N, P .C .
D
2049 C entury Park East
5th Floor
Los Angeles, CA 90067.3107
310.553.0308

16.