Keith Dorsey v. Ace Rent A Car Reservations, Inc. et al
Filing
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STIPULATED PROTECTIVE ORDER by Magistrate Judge Maria A. Audero re Stipulation for Protective Order 51 . [See order for details.] (es)
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Youssef H. Hammoud (SBN: 321934)
Lauren Tegan Rodkey (SBN: 275830)
PRICE LAW GROUP, APC
6345 Balboa Blvd., Suite 247
Encino, CA 91316
T: (818) 600-5596
F: (818) 600-5496
E: youssef@pricelawgroup.com
E: tegan@pricelawgroup.com
Attorneys for Plaintiff,
Keith Dorsey
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
KEITH DORSEY,
Case No.: 2:21-cv-06840-RGK-MAA
STIPULATED PROTECTIVE
Plaintiff,
ORDER
v.
ACE RENT A CAR
RESERVATIONS, INC. d/b/a ACE
RENT A CAR; ROCKPORT AUTO
CLAIMS; ACCOUNT SERVICES
COLLECTIONS, INC.; and
VANRENTALS-R-US LLC d/b/a ACE
RENT A CAR – LA.,
Defendants.
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
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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 to
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enter the following Stipulated Protective Order. The parties acknowledge that this
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Stipulated Protective Order does not confer blanket protections on all disclosures or
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responses to discovery and that the protection it affords from public disclosure and
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use extends only to the limited information or items that are entitled to confidential
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treatment under the applicable legal principles. The parties further acknowledge, as
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set forth in Section 14.3 below, that this Stipulated Protective Order does not entitle
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them to file confidential information under seal; Local Rule 79-5 sets forth the
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procedures that must be followed and the standards that will be applied when a party
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seeks permission from the Court to file material under seal. Discovery in this action
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is likely to involve production of confidential, proprietary, or private information for
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which special protection from public disclosure and from use for any purpose other
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than prosecuting this litigation may be warranted.
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2. GOOD CAUSE STATEMENT
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This action is likely to involve trade secrets, private financial information, or
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company specific policies and procedure and/or proprietary information for which
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special protection from public disclosure and from use for any purpose other than
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prosecution of this action is warranted. Such confidential and proprietary materials
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and information consist of, among other things, confidential business or financial
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information, information regarding confidential business practices, or other
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confidential research, development, or commercial information (including
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information implicating privacy rights of third parties), information otherwise
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generally unavailable to the public, or which may be privileged or otherwise
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protected from disclosure under state or federal statutes, court rules, case decisions,
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or common law. Accordingly, to expedite the flow of information, to facilitate the
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prompt resolution of disputes over confidentiality of discovery materials, to
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adequately protect information the parties are entitled to keep confidential, to ensure
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that the parties are permitted reasonable necessary uses of such material in
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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
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without a good faith belief that it has been maintained in a confidential, non-public
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manner, and there is good cause why it should not be part of the public record of this
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case.
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3. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL
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The parties further acknowledge, as set forth in Section 14.3, below, that this
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Stipulation Protective Order does not entitle them to file confidential information
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under seal; Local Civil 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
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to file material under seal.
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There is a strong presumption that the public has a right of access to judicial
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proceedings and records in civil cases. In connection with non-dispositive motions,
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good cause must be shown to support a filing under seal. See Kamakana v. City and
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County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006); Phillips v. Gen. Motors
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Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002); Makar-Welbon v. Sony Electrics,
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Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require
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good cause showing), and a specific showing of good cause or compelling reasons
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with proper evidentiary support and legal justification, must be made with respect to
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Protected Material that a party seeks to file under seal. The parties’ mere designation
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of Disclosure or Discovery Material as CONFIDENTIAL does not— without the
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submission of competent evidence by declaration, establishing that the material
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sought to be filed under seal qualifies as confidential, privileged, or otherwise
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protectable—constitute good cause.
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Further, if a party requests sealing related to a dispositive motion or trial, then
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compelling reasons, not only good cause, for the sealing must be shown, and the
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relief sought shall be narrowly tailored to serve the specific interest to be protected.
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See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For each
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item or type of information, document, or thing sought to be filed or introduced
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under seal in connection with a dispositive motion or trial, the party seeking
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protection must articulate compelling reasons, supported by specific facts and legal
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justification, for the requested sealing order. Again, competent evidence supporting
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the application to file documents under seal must be provided by declaration.
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Any document that is not confidential, privileged, or otherwise protectable in its
entirety will not be filed under seal if the confidential portions can be redacted. If
documents can be redacted, then a redacted version for public viewing, omitting only
the confidential, privileged, or otherwise protectable portions of the document shall
be filed. Any application that seeks to file documents under seal in their entirety
should include an explanation of why redaction is not feasible.
4. DEFINITIONS
4.1. Action: Dorsey v. Ace Rent A Car Reservations, Inc., et al.; No. 2:21cv-06840-RGK-MAA
4.2. Challenging Party: A Party or Nonparty that challenges the designation
of information or items under this Stipulated Protective Order
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4.3. “CONFIDENTIAL” Information or Items: Information (regardless of
how it is generated, stored or maintained) or tangible things that qualify
for protection under Federal Rule of Civil Procedure 26(c), and as
specified above in the Good Cause Statement.
4.4. Counsel: Outside Counsel of Record and In-House Counsel (as well as
their support staff).
4.5. Designating Party: A Party or Nonparty that designates information or
items that it produces in disclosures or in responses to discovery as
“CONFIDENTIAL.”
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4.6. Disclosure or Discovery Material: All items or information, regardless
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of the medium or manner in which it is generated, stored, or maintained
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(including, among other things, testimony, transcripts, and tangible
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things), that is produced or generated in disclosures or responses to
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discovery in this matter.
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4.7. Expert: A person with specialized knowledge or experience in a matter
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pertinent to the litigation who has been retained by a Party or its counsel
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to serve as an expert witness or as a consultant in this Action.
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4.8. In-House Counsel: Attorneys who are employees of a party to this
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Action. In-House Counsel does not include Outside Counsel of Record
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or any other outside counsel.
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4.9. Nonparty: Any natural person, partnership, corporation, association, or
other legal entity not named as a Party to this action.
4.10. Outside Counsel of Record: Attorneys who are not employees of a party
to this Action but are retained to represent or advise a party to this Action
and have appeared in this Action on behalf of that party or are affiliated
with a law firm which has appeared on behalf of that party, and includes
support staff.
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4.11. Party: Any party to this Action, including all of its officers, directors,
employees, consultants, retained experts, In-House Counsel, and
Outside Counsel of Record (and their support staffs).
4.12. Producing Party: A Party or Nonparty that produces Disclosure or
Discovery Material in this Action.
4.13. Professional Vendors: Persons or entities that provide litigation support
services (e.g., photocopying, videotaping, translating, preparing exhibits
or demonstrations, and organizing, storing, or retrieving data in any
form or medium) and their employees and subcontractors.
4.14. Protected Material: Any Disclosure or Discovery Material that is
designated as “CONFIDENTIAL.”
4.15. Receiving Party: A Party that receives Disclosure or Discovery Material
from a Producing Party
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5. SCOPE
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The protections conferred by this Stipulated Protective Order cover not only
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Protected Material, but also (1) any information copied or extracted from Protected
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Material; (2) all copies, excerpts, summaries, or compilations of Protected Material;
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and (3) any testimony, conversations, or presentations by Parties or their Counsel
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that might reveal Protected Material.
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Any use of Protected Material at trial shall be governed by the orders of the
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trial judge. This Stipulated Protective Order does not govern the use of Protected
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Material at trial.
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6. 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
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Action, with or without prejudice; and (2) final judgment herein after the completion
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and 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 time
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pursuant to applicable law.
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7. DESIGNATING PROTECTED MATERIAL
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Exercise of Restraint and Care in Designating Material for Production
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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. The Designating Party must designate for
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protection only those parts of material, documents, items, or oral or
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written communications that qualify so that other portions of the
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material, documents, items, or communications for which protection is
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not warranted are not swept unjustifiably within the ambit of this
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Stipulated Protective Order.
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Mass, indiscriminate, or routinized designations are prohibited.
Designations that are shown to be clearly unjustified or that have been
made for an improper purpose (e.g., to unnecessarily encumber the case
development process or to impose unnecessary expenses and burdens
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on other parties) may expose the Designating Party to sanctions.
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If it comes to a Designating Party’s attention that information or
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items that it designated for protection do not qualify for protection, that
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Designating Party must promptly notify all other Parties that it is
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withdrawing the inapplicable designation.
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7.2
Manner and Timing of Designations.
Except as otherwise provided in this Stipulated Protective
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Order (see, e.g., Section 7.2(a)), or as otherwise stipulated or ordered,
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Disclosure or Discovery Material that qualifies for protection under
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this Stipulated Protective Order must be clearly so designated before
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the material is disclosed or produced.
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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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documents, but excluding transcripts of depositions or other
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pretrial or trial proceedings), that the Producing Party affix at a
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minimum, the legend “CONFIDENTIAL” to each page that
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contains protected material. If only a portion or portions of the
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material on a page qualifies for protection, the Producing Party
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also must clearly identify the protected portion(s) (e.g., by
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making appropriate markings in the margins).
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A Party or Nonparty that makes original documents
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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 it
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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 “CONFIDENTIAL.” After the
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inspecting Party has identified the documents it wants copied and
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produced, the Producing Party must determine which documents,
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or portions thereof, qualify for protection under this Stipulated
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Protective Order. Then, before producing the specified
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documents, the Producing Party must affix the legend
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“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
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before the close of the deposition, all protected testimony.
c)
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For information produced in nondocumentary form, and for any
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other tangible items, that the Producing Party affix in a
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prominent place on the exterior of the container or containers in
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which the information is stored the legend “CONFIDENTIAL.”
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If only a portion or portions of the information warrants
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protection, the Producing Party, to the extent practicable, shall
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identify the protected portion(s)
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7.3
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
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for such material. Upon timely correction of a designation, the
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Receiving Party must make reasonable efforts to assure that the
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material is treated in accordance with the provisions of this Stipulated
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Protective Order.
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8. CHALLENGING CONFIDENTIALITY DESIGNATIONS
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8.1
Timing of Challenges.
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Any Party or Nonparty may challenge a designation of
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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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8.2
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Meet and Confer.
The Challenging Party shall initiate the dispute resolution
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process, 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
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8.3.
Burden of Persuasion.
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The burden of persuasion in any such challenge proceeding shall
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be on the Designating Party. Frivolous challenges, and those made for
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an improper purpose (e.g., to harass or impose unnecessary expenses
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and burdens on other parties) may expose the Challenging Party to
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Judge Audero’s Procedures are available at
https://www.cacd.uscourts.gov/honorable-maria-audero
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sanctions. Unless the Designating Party has waived or withdrawn the
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confidentiality designation, all parties shall continue to afford the
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material in question the level of protection to which it is entitled under
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the Producing Party’s designation until the Court rules on the challenge.
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9. ACCESS TO AND USE OF PROTECTED MATERIALS
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Basic Principles.
A Receiving Party may use Protected Material that is disclosed
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or produced by another Party or by a Nonparty in connection with this
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Action only for prosecuting, defending, or attempting to settle this
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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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Stipulated Protective Order. When the Action reaches a final
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disposition, a Receiving Party must comply with the provisions of
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Section 15 below.
Protected Material must be stored and maintained by a
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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 Stipulated
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Protective Order.
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9.2.
Disclosure of “CONFIDENTIAL” Information or Items.
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, as well as
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employees of said Outside Counsel of Record to whom it is reasonably
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necessary to disclose the information for this Action;
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b) The officers, directors, and employees (including In-House Counsel) of
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the Receiving Party to whom disclosure is reasonably necessary for this
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Action;
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c) Experts of the Receiving Party to whom disclosure is reasonably
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necessary for this Action and who have signed the “Acknowledgment
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and Agreement to Be Bound” (Exhibit A)
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d) The Court, its personnel and any juror or alternate juror;
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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 and
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who have signed the “Acknowledgment and Agreement to be Bound”
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(Exhibit A);
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g) The author or recipient of a document containing the information or a
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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 the
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Action to whom disclosure is reasonably necessary provided: (i) the
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deposing party requests that the witness sign the “Acknowledgment and
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Agreement to Be Bound” (Exhibit A); and (ii) the witness will not be
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permitted to keep any confidential information unless they sign the
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“Acknowledgment and Agreement to Be Bound,” unless otherwise
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agreed by the Designating Party or ordered by the Court. Pages of
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transcribed deposition testimony or exhibits to depositions that reveal
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Protected Material may be separately bound by the court reporter and
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may not be disclosed to anyone except as permitted under this
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Stipulated Protective Order; and (iii) Any mediator or settlement
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officer, and their supporting personnel, mutually agreed upon by any of
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the parties engaged in settlement discussions.
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10.PROTECTED MATERIAL SUBPOENAED OR ORDERED
PRODUCED IN OTHER LITIGATION
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If a Party is served with a subpoena or a court order issued in other litigation
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that compels disclosure of any information or items designated in this Action as
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“CONFIDENTIAL,” that Party must:
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a) Promptly notify in writing the Designating Party. Such notification
shall include a copy of the subpoena or court order;
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b) Promptly notify in writing the party who cased the subpoena or order
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to issue in the other litigation that some or all of the material covered
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by the subpoena or order is subject to this Stipulated 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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c) Cooperate with respect to all reasonable procedures sought to be
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pursued by the Designating Party whose Protected Material may be
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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
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as “CONFIDENTIAL” before a determination by the Court from which the
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subpoena or order issued, unless the Party has obtained the Designating Party’s
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permission. The Designating Party shall bear the burden and expense of seeking
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protection in that court of its confidential material and nothing in these provisions
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should be construed as authorizing or encouraging a Receiving Party in this Action
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to disobey a lawful directive from another court.
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11.A NONPARTY’S PROTECTED MATERIAL SOUGHT TO BE
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PRODUCED IN THIS LITIGATION
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11.1. 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.” Such information produced by Nonparties in
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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
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provisions should be construed as prohibiting a Nonparty from seeking
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additional protections.
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11.2. Notification.
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In the event that a Party is required, by a valid discovery request,
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to produce a Nonparty’s confidential information in its possession, and
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the Party is subject to an agreement with the Nonparty not to produce
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the 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), and
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a reasonably specific description of the information requested; and
c) Make the information requested available for inspection by the
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Nonparty, if requested.
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11.3. Conditions of Production.
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If the Nonparty fails to seek a protective order from this Court
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within fourteen (14) days after receiving the notice and accompanying
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information, the Receiving Party may produce the Nonparty’s
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confidential information responsive to the discovery request. If the
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Nonparty timely seeks a protective order, the Receiving Party shall not
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produce any information in its possession or control that is subject to
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the confidentiality agreement with the Nonparty before a determination
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by the Court. Absent a court order to the contrary, the Nonparty shall
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bear the burden and expense of seeking protection in this Court of its
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Protected Material.
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12.
UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
Protected Material to any person or in any circumstance not authorized under this
Stipulated Protective Order, the Receiving Party immediately must (1) notify in
writing the Designating Party of the unauthorized disclosures, (2) use its best efforts
to retrieve all unauthorized copies of the Protected Material, (3) inform the person
or persons to whom unauthorized disclosures were made of all the terms of this
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Stipulated Protective Order, and (4) request such person or persons to execute the
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“Acknowledgment and Agreement to be Bound” (Exhibit A).
13. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
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
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information covered by the attorney-client privilege or work product protection, the
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parties may incorporate their agreement in the Stipulated Protective Order submitted
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to the Court.
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14.
MISCELLANEOUS
14.1. Right to Further Relief.
Nothing in this Stipulated Protective Order abridges the right of
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any person to seek its modification by the Court in the future.
14.2. 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
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or 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 to
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object on any ground to use in evidence of any of the material covered
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by this Stipulated Protective Order.
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14.3. 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
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under seal pursuant to a court order authorizing the sealing of the
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specific Protected Material at issue. If a Party's request to file Protected
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Material under seal is denied by the Court, then the Receiving Party
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may file the information in the public record unless otherwise instructed
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by the Court.
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15.
FINAL DISPOSITION
After the final disposition of this Action, within sixty (60) days of a written
request by the Designating Party, each Receiving Party must return all Protected
Material to the Producing Party or destroy such material. As used in this subdivision,
“all Protected Material” includes all copies, abstracts, compilations, summaries, and
any other format reproducing or capturing any of the Protected Material. Whether
the Protected Material is returned or destroyed, the Receiving Party must submit a
written certification to the Producing Party (and, if not the same person or entity, to
the Designating Party) by the 60-day deadline that (1) identifies (by category, where
appropriate) all the Protected Material that was returned or destroyed and (2) affirms
that the Receiving Party has not retained any copies, abstracts, compilations,
summaries or any other format reproducing or capturing any of the Protected
Material. Notwithstanding this provision, Counsel is entitled to retain an archival
copy of all pleadings; motion papers; trial, deposition, and hearing transcripts; legal
memoranda; correspondence; deposition and trial exhibits; expert reports; attorney
work product; and consultant and expert work product, even if such materials
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contain Protected Material. Any such archival copies that contain or constitute
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Protected Material remain subject to this Stipulated Protective Order as set forth in
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Section 6.
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VIOLATION
Any violation of this Stipulated Order may be punished by any and all
appropriate measures including, without limitation, contempt proceedings and/or
monetary sanctions.
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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
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DATED: January 10, 2022
By: /s/Youssef H. Hammoud
Youssef H. Hammoud (SBN: 321934)
PRICE LAW GROUP, APC
6345 Balboa Blvd., Suite 247
Encino, CA 91316
T: (818) 600-5596
F: (818) 600-5496
E: youssef@pricelawgroup.com
Attorneys for Plaintiff Keith Dorsey
DATED: January 10, 2022
By: /s/ John A. Kelly
THOMAS F. LANDERS [SBN 207335]
tlanders@swsslaw.com
JOHN A. KELLY [SBN 324463]
jkelly@swsslaw.com
SOLOMON WARD SEIDENWURM
SMITH, LLP
401 B Street, Suite 1200
San Diego, California 92101
(t) 619.231.0303
(f) 619.231.4755
Attorneys for Defendants,
Ace Rent A Car Reservations, Inc.
d/b/a Ace Rent A Car and
VAN-RENTALS-R-US LLC
d/b/a Ace Rent A Car – LA
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DATED: January 10, 2022
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By: /s/ Mark Ellis
Mark E. Ellis - 127159
ELLIS LAW GROUP LLP
1425 River Park Drive, Suite 400
Sacramento, CA 95815
Tel: (916) 283-8820
Fax: (916) 283-8821
mellis@ellislawgrp.com
Attorneys for Defendant
Rockport Auto Claims
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P:01512115.2:63223.004
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FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
January 10, 2022
Dated: ___________________
_________________________
Maria A. Audero
United States Magistrate Judge
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P:01512115.2:63223.004
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EXHIBIT A
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ACKNOWLEDGMENT AND AGREEMENT TO COMPLY
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I, _____________________[full name], of
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_________________________[address], declare under penalty of perjury that I
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have read in its entirety and understand the Stipulated Protective Order that was
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issued by the United States District Court for the Central District of California on
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[date] in the case of Dorsey v. Ace Rent A Car Reservations, Inc., et al; No. 2:21-
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cv-06840-RGK-MAA. I agree to comply with all the terms of this Stipulated
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Protective Order, and I understand and acknowledge that failure to so comply
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could expose me to sanctions and punishment in the nature of contempt. I solemnly
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promise that I will not disclose in any manner any information or item that is
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subject to this Stipulated Protective Order to any person or entity except in strict
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compliance with the provisions of this Stipulated Protective Order. I further agree
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to submit to the jurisdiction of the United States District Court for the Central
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District of California for the purpose of enforcing the terms of this Stipulated
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Protective Order, even if such enforcement proceedings occur after termination of
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this action. I hereby appoint _______________________ [full name] of
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_____________________________________[address and telephone number] as
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my California agent for service of process in connection with this action or any
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proceedings related to enforcement of this Stipulated Protective Order.
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Signature:_________________________
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Printed Name:______________________
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Date:________________
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City and State Where Sworn and Signed:________________________________
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P:01512115.2:63223.004
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