Joseph Oratov v. Rexnord Industries, LLC et al

Filing 40

PROTECTIVE ORDER [CHANGES MADE BY COURT] by Magistrate Judge Jacqueline Chooljian re Stipulation for Protective Order 38 . (see document for details) (hr)

1 David Payab, Esq.

[e-mail]

2 Matthew T. Hale, Esq.

[e-mail]

3 THE LAW OFFICE OF PAYAB & ASSOCIATES

5850 Canoga Avenue, Suite 400

4 Woodland Hills, CA 91367

Telephone: [phone]
818-888-4547

5 Facsimile:

6 Attorneys for Plaintiff Joseph Oratov
7 Angela Pak CA Bar No. 240177

[e-mail]

8 Robert R. Vorhees CA Bar No. 297936

[e-mail]

9 OGLETREE, DEAKINS, NASH,

SMOAK & STEWART, P.C.

10 Park Tower, Fifteenth Floor

695 Town Center Drive

11 Costa Mesa, CA 92626

Telephone: [phone]
714-754-1298

12 Facsimile:

13 Attorneys for Defendant
14

Rexnord Industries, LLC

15

UNITED STATES DISTRICT COURT

16

CENTRAL DISTRICT OF CALIFORNIA – WESTERN DISTRICT

17
18 JOSEPH ORATOV, an individual,

Case No. 2:20-cv-05941 ODW (JCx)

19

STIPULATED PROTECTIVE ORDER

20
21
22
23
24
25
26
27

Plaintiff,
v.
REXNORD INDUSTRIES, LLC, a
Delaware Corporation; REXNORD, a
business entity of unknown form;
REXNORD AEROSPACE, a business
entity of unknown form; REXNORD
PSI BEARINGS, a business entity of
unknown form; REXNORD
ASSOCIATES, a business entity of
unknown form; DOES 1-50,

Complaint Filed:
Trial Date:
District Judge:
Magistrate Judge:

February 7, 2020
December 14, 2021
Otis D. Wright, II
Jacqueline Chooljian

[CHANGES MADE BY COURT TO
PARAGRAPHS 3, 8, 9]

Defendants.

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Case No. 2:20-cv-05941 ODW (JCx)

STIPULATED PROTECTIVE ORDER

1

1.

A.

PURPOSES AND LIMITATIONS

2

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

3

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

4

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

5

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

6

following Stipulated Protective Order. The parties acknowledge that this Order does

7

not confer blanket protections on all disclosures or responses to discovery and that the

8

protection it affords from public disclosure and use extends only to the limited

9

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

10

legal principles. The parties further acknowledge, as set forth in Section 12.3, below,

11

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

12

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

13

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

14

the court to file material under seal.

15

B.

16

This action is likely to involve trade secrets, customer and pricing lists and other

17

valuable research, development, commercial, financial, technical and/or proprietary

18

information for which special protection from public disclosure and from use for any

19

purpose other than prosecution of this action is warranted. Such confidential and

20

proprietary materials and information consist of, among other things, confidential

21

business or financial information, information regarding confidential business

22

practices, or other confidential research, development, or commercial information

23

(including information implicating privacy rights of third parties), information

24

otherwise generally unavailable to the public, or which may be privileged or otherwise

25

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

26

common law. Accordingly, to expedite the flow of information, to facilitate the prompt

27

resolution of disputes over confidentiality of discovery materials, to adequately protect

28

information the parties are entitled to keep confidential, to ensure that the parties are
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STIPULATED PROTECTIVE ORDER

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GOOD CAUSE STATEMENT

1

permitted reasonable necessary uses of such material in preparation for and in the

2

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

3

of justice, a protective order for such information is justified in this matter. It is the

4

intent of the parties that information will not be designated as confidential for tactical

5

reasons and that nothing be so designated without a good faith belief that it has been

6

maintained in a confidential, non-public manner, and there is good cause why it should

7

not be part of the public record of this case.

8

2.

2.1.

9
10

DEFINITIONS
Action: this case entitled Joseph Oratov v. Rexnord Industries, LLC, et

al. Case No. 2:20-cv-05941 ODW(JCx), currently pending in the Central District of

11 California.

2.2.

12
13

Challenging Party: a Party or Non-Party that challenges the designation

of information or items under this Order
2.3.

14

“CONFIDENTIAL” Information or Items: information (regardless of

15

how it is generated, stored or maintained) or tangible things that qualify for protection

16

under Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause

17

Statement.

18

2.4.

19

Counsel: Outside Counsel of Record and House Counsel (as well as their

support staff).
2.5.

20

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

21

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

22

“CONFIDENTIAL.”
2.6.

23

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

24

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

25

among other things, testimony, transcripts, and tangible things), that are produced or

26

generated in disclosures or responses to discovery in this matter.

27

///

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///

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STIPULATED PROTECTIVE ORDER

2.7.

1

Expert: a person with specialized knowledge or experience in a matter

2

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

3

an expert witness or as a consultant in this Action.
2.8.

4

House Counsel: attorneys who are employees of a party to this Action.

5

House Counsel does not include Outside Counsel of Record or any other outside

6

counsel.
2.9.

7
8

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

other legal entity not named as a Party to this action.

9

2.10. Outside Counsel of Record: attorneys who are not employees of a party

10

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

11

appeared in this Action on behalf of that party or are affiliated with a law firm which

12

has appeared on behalf of that party, and includes support staff.

13

2.11. Party: any party to this Action, including all of its officers, directors,

14

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

15

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

16
17

Discovery Material in this Action.

18

2.13. Professional Vendors: persons or entities that provide litigation support

19

services (e.g., photocopying, videotaping, translating, preparing exhibits or

20

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

21

their employees and subcontractors.
2.14. Protected Material: any Disclosure or Discovery Material that is

22
23

designated as “CONFIDENTIAL.”
2.15. Receiving Party: a Party that receives Disclosure or Discovery Material

24
25

from a Producing Party.

26

3.

SCOPE

27

The protections conferred by this Stipulation and Order cover not only Protected

28

Material (as defined above), but also (1) any information copied or extracted from
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Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected

2

Material; and (3) any deposition testimony, conversations, or presentations by Parties

3

or their Counsel that might reveal Protected Material, other than during a court hearing

4

or at trial.

5

Any use of Protected Material during a court hearing or at trial shall be governed

6

by the orders of the presiding judge. This Order does not govern the use of Protected

7

Material during a court hearing or at trial.

8

4.

DURATION

9

Even after final disposition of this litigation, the confidentiality obligations

10

imposed by this Order shall remain in effect until a Designating Party agrees otherwise

11

in writing or a court order otherwise directs. Final disposition shall be deemed to be

12

the later of (1) dismissal of all claims and defenses in this Action, with or without

13

prejudice; and (2) final judgment herein after the completion and exhaustion of all

14

appeals, rehearings, remands, trials, or reviews of this Action, including the time limits

15

for filing any motions or applications for extension of time pursuant to applicable law.

16

5.

17

DESIGNATING PROTECTED MATERIAL
5.1.

Exercise of Restraint and Care in Designating Material for Protection.

18

Each Party or Non-Party that designates information or items for protection under this

19

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

20

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

21

only those parts of material, documents, items, or oral or written communications that

22

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

23

for which protection is not warranted are not swept unjustifiably within the ambit of

24

this Order.

25

Mass, indiscriminate, or routinized designations are prohibited. Designations

26

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

27

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

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

2

to sanctions.

3

If it comes to a Designating Party’s attention that information or items that it

4 designated for protection do not qualify for protection, that Designating Party must
5 promptly notify all other Parties that it is withdrawing the inapplicable designation.
6

5.2.

Manner and Timing of Designations. Except as otherwise provided in this

7

Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated

8

or ordered, Disclosure or Discovery Material that qualifies for protection under this

9

Order must be clearly so designated before the material is disclosed or produced.

10
11

Designation in conformity with this Order requires:
(a)

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

12

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

13

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

14

“CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that

15

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

16

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

17

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

18

A Party or Non-Party that makes original documents available for inspection

19

need not designate them for protection until after the inspecting Party has indicated

20

which documents it would like copied and produced. During the inspection and before

21

the designation, all of the material made available for inspection shall be deemed

22

“CONFIDENTIAL.” After the inspecting Party has identified the documents it wants

23

copied and produced, the Producing Party must determine which documents, or

24

portions thereof, qualify for protection under this Order. Then, before producing the

25

specified documents, the Producing Party must affix the “CONFIDENTIAL legend”

26

to each page that contains Protected Material. If only a portion or portions of the

27

material on a page qualifies for protection, the Producing Party also must clearly

28

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

1

for testimony given in depositions that the Designating Party

2

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

3

deposition all protected testimony.
(c)

4

for information produced in some form other than documentary

5

and for any other tangible items, that the Producing Party affix in a prominent place

6

on the exterior of the container or containers in which the information is stored the

7

legend “CONFIDENTIAL.” If only a portion or portions of the information warrants

8

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

9

portion(s).

10

5.3.

Inadvertent Failures to Designate. If timely corrected, an inadvertent

11

failure to designate qualified information or items does not, standing alone, waive the

12

Designating Party’s right to secure protection under this Order for such material. Upon

13

timely correction of a designation, the Receiving Party must make reasonable efforts

14

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

15

6.

CHALLENGING CONFIDENTIALITY DESIGNATIONS
6.1.

16

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

17

designation of confidentiality at any time that is consistent with the Court’s Scheduling

18

Order.
6.2.

19
20

Meet and Confer. The Challenging Party shall initiate the dispute

resolution process under Local Rule 37.1 et seq.
6.3.

21

The burden of persuasion in any such challenge proceeding shall be on

22

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

23

(e.g., to harass or impose unnecessary expenses and burdens on other parties) may

24

expose the Challenging Party to sanctions. Unless the Designating Party has waived

25

or withdrawn the confidentiality designation, all parties shall continue to afford the

26

material in question the level of protection to which it is entitled under the Producing

27

Party’s designation until the Court rules on the challenge.

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///

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STIPULATED PROTECTIVE ORDER

1

7.

ACCESS TO AND USE OF PROTECTED MATERIAL
7.1.

2

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

3

disclosed or produced by another Party or by a Non-Party in connection with this

4

Action only for prosecuting, defending, or attempting to settle this Action. Such

5

Protected Material may be disclosed only to the categories of persons and under the

6

conditions described in this Order. When the Action has been terminated, a Receiving

7

Party must comply with the provisions of section 13 below (FINAL DISPOSITION).

8

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

9

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

10

authorized under this Order.
7.2.

11

Disclosure of “CONFIDENTIAL” Information or Items. Unless

12

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

13

Receiving Party may disclose any information or item designated “CONFIDENTIAL”

14

only to:
(a)

15

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

16

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

17

necessary to disclose the information for this Action;
(b)

18
19

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

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

20

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

21

disclosure is reasonably necessary for this Action and who have signed the

22

“Acknowledgment and Agreement to Be Bound” (Exhibit A);

23

(d)

the court and its personnel;

24

(e)

court reporters and their staff;

25

(f)

professional jury or trial consultants, mock jurors, and Professional

26

Vendors to whom disclosure is reasonably necessary for this Action and who have

27

signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);

28

///

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Case No. 2:20-cv-05941 ODW (JCx)
STIPULATED PROTECTIVE ORDER

(g)

1
2

the author or recipient of a document containing the information or

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

3

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

4

the Action to whom disclosure is reasonably necessary provided: (1) the deposing

5

party requests that the witness sign the form attached as Exhibit A hereto; and (2) they

6

will not be permitted to keep any confidential information unless they sign the

7

“Acknowledgment and Agreement to Be Bound” (Exhibit A), and it is agreed to by

8

the Designating Party or ordered by the court. Pages of transcribed deposition

9

testimony or exhibits to depositions that reveal Protected Material may be separately

10

bound by the court reporter and may not be disclosed to anyone except as permitted

11

under this Stipulated Protective Order; and
(i)

12

any mediator or settlement officer, and their supporting personnel,

13

mutually agreed upon by any of the parties engaged in settlement discussions.

14

8.

15

OTHER LITIGATION

PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN

16

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

17

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

18

“CONFIDENTIAL,” that Party must:

19
20
21

(a)

promptly notify in writing the Designating Party. Such notification

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

promptly notify in writing the party who caused the subpoena or

22

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

23

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

24

copy of this Stipulated Protective Order; and

25
26

(c)

cooperate with respect to all reasonable procedures sought to be

pursued by the Designating Party whose Protected Material may be affected.

27

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

28

the subpoena or court order shall not produce any information designated in this action
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as “CONFIDENTIAL” before a determination by the court from which the subpoena

2 or order issued, unless the Party has obtained the Designating Party’s permission or
3 unless otherwise required by the law or court order. The Designating Party shall bear
4 the burden and expense of seeking protection in that court of its confidential material
5 and nothing in these provisions should be construed as authorizing or encouraging a
6 Receiving Party in this Action to disobey a lawful directive from another court.
7

9.

8

IN THIS LITIGATION

9

A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED
(a)

The terms of this Order are applicable to information produced by

10

a Non-Party in this Action and designated as “CONFIDENTIAL.” Such information

11

produced by Non-Parties in connection with this litigation is protected by the remedies

12

and relief provided by this Order. Nothing in these provisions should be construed as

13

prohibiting a Non-Party from seeking additional protections.

14

(b)

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

15

to produce a Non-Party’s confidential information in its possession, and the Party is

16

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

17

confidential information, then the Party shall:
(i)

18

promptly notify in writing the Requesting Party and the

19

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

20

agreement with a Non-Party;
(ii)

21

promptly provide the Non-Party with a copy of the

22

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

23

reasonably specific description of the information requested; and
(iii)

24

make the information requested available for inspection by

25

the Non-Party, if requested.

26

(c)

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

27

within 14 days of receiving the notice and accompanying information, the Receiving

28

Party may produce the Non-Party’s confidential information responsive to the
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1

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

2

shall not produce any information in its possession or control that is subject to the

3

confidentiality agreement with the Non-Party before a determination by the court

4 unless otherwise required by the law or court order. Absent a court order to the
5 contrary, the Non-Party shall bear the burden and expense of seeking protection in this
6

court of its Protected Material.

7

10.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

8

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

9

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

10

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

11

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

12

to retrieve all unauthorized copies of the Protected Material, (c) inform the person or

13

persons to whom unauthorized disclosures were made of all the terms of this Order,

14

and (d) request such person or persons to execute the “Acknowledgment and

15

Agreement to Be Bound” that is attached hereto as Exhibit A.

16

11.

17

PROTECTED MATERIAL

INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

18

When a Producing Party gives notice to Receiving Parties that certain

19

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

20

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

21

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

22

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

23

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

24

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

25

information covered by the attorney-client privilege or work product protection, the

26

parties may incorporate their agreement in the stipulated protective order submitted to

27

the court.

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1

12.

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

2
3

MISCELLANEOUS

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

4

12.2. Right to Assert Other Objections. By stipulating to the entry of this

5

Protective Order no Party waives any right it otherwise would have to object to

6

disclosing or producing any information or item on any ground not addressed in this

7

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

8

ground to use in evidence of any of the material covered by this Protective Order.

9

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

10

Protected Material must comply with Civil Local Rule 79-5. Protected Material may

11

only be filed under seal pursuant to a court order authorizing the sealing of the specific

12

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

13

denied by the court, then the Receiving Party may file the information in the public

14

record unless otherwise instructed by the court.

15

13.

FINAL DISPOSITION

16

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

17

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

18

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

19

subdivision, “all Protected Material” includes all copies, abstracts, compilations,

20

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

21

Material. Whether the Protected Material is returned or destroyed, the Receiving Party

22

must submit a written certification to the Producing Party (and, if not the same person

23

or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by

24

category, where appropriate) all the Protected Material that was returned or destroyed

25

and (2) affirms that the Receiving Party has not retained any copies, abstracts,

26

compilations, summaries or any other format reproducing or capturing any of the

27

Protected Material. Notwithstanding this provision, Counsel are entitled to retain an

28

archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts,
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1

legal memoranda, correspondence, deposition and trial exhibits, expert reports,

2

attorney work product, and consultant and expert work product, even if such materials

3

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

4

Protected Material remain subject to this Protective Order as set forth in Section 4

5

(DURATION).

6

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

7

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

8

sanctions.

9

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

10
11

DATED: July 9, 2021

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

12
13

By:

14
15
16
17
18

DATED: July 9, 2021

/s/
Angela Pak
Robert R. Vorhees
Attorneys for Defendant
Rexnord Industries, LLC

THE LAW OFFICE OF PAYAB &
ASSOCIATES

19
20

By:

21
22
23
24
25
26
27

/s/
David Payab, Esq.
Matthew T. Hale, Esq.
Attorneys for Plaintiff Joseph Oratov

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED AS MODIFIED.
DATED: July 14, 2021

___________/s/________________
Hon. Jacqueline Chooljian
United States Magistrate Judge

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1

EXHIBIT A

2

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3

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

4

___________________ [print or type full address], declare under penalty of perjury

5

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

6

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

7

14, 2021 in the case of Joseph Oratov v. Rexnord Industries LLC, et al., Case No.

8

2:20-cv-05941 ODW (JCx). I agree to comply with and to be bound by all the terms

9

of this Stipulated Protective Order and I understand and acknowledge that failure to

10

so comply could expose me to sanctions and punishment in the nature of contempt. I

11

solemnly promise that I will not disclose in any manner any information or item that

12

is subject to this Stipulated Protective Order to any person or entity except in strict

13

compliance with the provisions of this Order.

14

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

15

for the Central District of California for the purpose of enforcing the terms of this

16

Stipulated Protective Order, even if such enforcement proceedings occur after

17

termination of this action. I hereby appoint________________ [print or type full

18

name] of ___________________________ [print or type full address and telephone

19

number] as my California agent for service of process in connection with this action

20

or any proceedings related to enforcement of this Stipulated Protective Order.

21
22

Date: _________________________

23

City and State where sworn and signed: ____________________________

24

Printed name: __________________

25

Signature: _____________________

26
27

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