Kiri Villa v. ProCollect, Inc. et al

Filing 23

PROTECTIVE ORDER by Magistrate Judge Karen L. Stevenson re Stipulation for Protective Order 21 . (see document for details) (hr)

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Cheryl L. O’Connor (SBN 173897)
[e-mail]
JONES DAY
3161 Michelson Drive
Suite 800
Irvine, California 92612-4408
Telephone: [phone]
Facsimile: +1.949.553.7539
Katie Gonzalez (SBN 329085)
[e-mail]
JONES DAY
1755 Embarcadero Road
Palo Alto, California 94303
Telephone: [phone]
Facsimile: +1.650.739.3900
Attorneys for Defendant
Experian Information Solutions, Inc.

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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Western Division

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Plaintiff,

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Case No. 2:22-cv-05299-MWF (KSx)

Kiri Villa,
v.
ProCollect, Inc.; Convergent
Outsourcing, Inc.; and Experian
Information Solutions, Inc.,

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Hon. Michael W. Fitzgerald
Magistrate Judge Karen L. Stevenson
STIPULATED PROTECTIVE
ORDER

Defendants.

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1.

PURPOSE AND LIMITATIONS

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Discovery in this action is likely to involve trade secrets, confidential research,

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development, technology or other proprietary information belonging to the

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defendants, and/or personal income, credit and other confidential information of

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

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purpose other than prosecuting this litigation may be warranted. Accordingly, the

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parties hereby stipulate to and petition the Court to enter the following Stipulated
STIPULATED PROTECTIVE ORDER
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Protective Order. The parties acknowledge that this Order does not confer blanket

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protections on all disclosures or responses to discovery and that the protection it

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affords from public disclosure and use extends only to the limited information or

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items that are entitled to confidential treatment under the applicable legal principles.

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The parties further acknowledge, as set forth in Section 13.3, below, that this

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Stipulated Protective Order does not entitle them to file confidential information

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

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

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file material under seal.

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2.

GOOD CAUSE STATEMENT

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This action is likely to involve trade secrets, confidential consumer

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information including consumer financial account numbers, financial transaction

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logs, and personally identifiable information for which special protection from public

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

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

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among other things, proprietary software systems that log consumer disputes;

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proprietary software systems that log consumer credit history; proprietary training

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and policy manuals; personnel records; financial records; records pertaining to

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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 serve the ends of justice, a protective order for such information is
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STIPULATED PROTECTIVE ORDER
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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.

DEFINITIONS

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3.1.

Action: This pending federal lawsuit.

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3.2.

Challenging Party: A Party or Nonparty that challenges the designation

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of information or items under this Stipulated Protective Order.
3.3.

“CONFIDENTIAL” Information or Items: Information (regardless of

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

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for protection under Federal Rule of Civil Procedure 26(c), and as

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specified above in the Good Cause Statement.

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3.4.

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Counsel: Outside Counsel of Record and In-House Counsel (as well as
their support staff).

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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

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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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3.7.

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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3.8.

In-House Counsel: Attorneys who are employees of a party to this
Action. In-House Counsel does not include Outside Counsel of Record
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STIPULATED PROTECTIVE ORDER
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or any other outside counsel.

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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

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

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

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and includes support staff.

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

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employees, consultants, retained experts, In-House Counsel, and

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Outside Counsel of Record (and their support staffs).

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3.12. Producing Party: A Party or Nonparty that produces Disclosure or

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Discovery Material in this Action.

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

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

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exhibits or demonstrations, and organizing, storing, or retrieving data in

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any form 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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Any Disclosure or Discovery Material that is

from a Producing Party.
4.

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 that

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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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STIPULATED PROTECTIVE ORDER
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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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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

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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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6.

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DESIGNATING PROTECTED MATERIAL
6.1.

Exercise of Restraint and Care in Designating 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. 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.

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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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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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STIPULATED PROTECTIVE ORDER
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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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6.2.

Manner and Timing of Designations. Except as otherwise provided in

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this Stipulated Protective Order (see, e.g., Section 6.2(a)), or as

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otherwise stipulated or ordered, Disclosure or Discovery Material that

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qualifies for protection under this Stipulated Protective Order must be

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clearly so designated before 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 before

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the designation, all of the material made available for inspection

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shall be deemed “CONFIDENTIAL.” After the inspecting

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Party’s Outside Attorney Of Record has identified the documents

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it wants copied and produced, the Producing Party must

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determine which documents, or portions thereof, qualify for
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STIPULATED PROTECTIVE ORDER
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protection under this Stipulated Protective Order. Then, before

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producing the specified documents, the Producing Party must

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affix the legend “CONFIDENTIAL” to each page that contains

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Protected Material. If only a portion or portions of the material on

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a page qualifies for protection, the Producing Party also must

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

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appropriate markings in the margins).

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(b)

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For testimony given in depositions that the Designating Party
identify the Disclosure or Discovery Material on the record,

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before the close of the deposition all protected testimony.

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(c)

For information produced in nondocumentary form, and for any

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other tangible items, that the Producing Party affix in a prominent

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place on the exterior of the container or containers in which the

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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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Producing Party, to the extent practicable, shall identify the

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protected portion(s).

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6.3.

Inadvertent Failure to Designate. If timely corrected, an inadvertent

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failure to designate qualified information or items does not, standing

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alone, waive the Designating Party’s right to secure protection under

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this Stipulated Protective Order for such material. Upon timely

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correction of a designation, the Receiving Party must make reasonable

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efforts to assure that the material is treated in accordance with the

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provisions of this Stipulated Protective Order.

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7.

CHALLENGING CONFIDENTIALITY DESIGNATIONS
7.1.

Timing of Challenges. Any Party or Nonparty may challenge a

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designation of confidentiality at any time that is consistent with the

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Court’s Scheduling Order.
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STIPULATED PROTECTIVE ORDER
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7.2.

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Meet and Confer. The Challenging Party shall initiate the dispute
resolution process, which shall comply with Local Rule 37.1 et seq.

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7.3.

Burden of Persuasion. The burden of persuasion in any such challenge

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proceeding shall be on the Designating Party. Frivolous challenges, and

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those made for an improper purpose (e.g., to harass or impose

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unnecessary expenses and burdens on other parties) may expose the

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Challenging Party to sanctions. Unless the Designating Party has

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waived or withdrawn the confidentiality designation, all parties shall

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continue to afford the material in question the level of protection to

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which it is entitled under the Producing Party’s designation until the

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Court rules on the challenge.

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8.

ACCESS TO AND USE OF PROTECTED MATERIAL
8.1.

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

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disclosed or produced by another Party or by a Nonparty in connection

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with this Action only for prosecuting, defending, or attempting to settle

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this Action. Such Protected Material may be disclosed only to the

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categories of persons and under the conditions described in this

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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 14 below.

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Protected Material must be stored and maintained by a Receiving

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

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limited to the persons authorized under this Stipulated Protective Order.

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8.2.

Disclosure of “CONFIDENTIAL” Information or Items. Unless

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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

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item designated “CONFIDENTIAL” only to:

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STIPULATED PROTECTIVE ORDER
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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)

Experts of the Receiving Party to whom disclosure is reasonably

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necessary for this Action and who have signed the

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

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(d)

The Court and its personnel and the jury;

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(e)

Court reporters and their staff;

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(f)

Professional jury or trial consultants, mock jurors, and

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Professional Vendors to whom disclosure is reasonably necessary

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or this Action and who have signed the “Acknowledgment and

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Agreement to be Bound” (Exhibit A);

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(g)

The author or recipient of a document containing the information

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or a custodian or other person who otherwise possessed or knew

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the information;

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(h)

During their depositions, witnesses, and attorneys for witnesses,

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in the Action to whom disclosure is reasonably necessary

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

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

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and (ii) the witnesses will not be permitted to keep any

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confidential information unless they sign the “Acknowledgment

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and Agreement to Be Bound,” unless otherwise agreed by the

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Designating Party or ordered by the Court. Pages of transcribed

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deposition testimony or exhibits to depositions that reveal

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Protected Material may be separately bound by the court reporter
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STIPULATED PROTECTIVE ORDER
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and may not be disclosed to anyone except as permitted under this

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Stipulated Protective Order; and

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(i)

Any mediator or settlement officer, and their supporting

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personnel, mutually agreed upon by any of the parties engaged in

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settlement discussions.

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9.

PROTECTED MATERIAL SUBPOENAED OR ORDERED

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PRODUCED IN OTHER LITIGATION

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

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

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“CONFIDENTIAL,” that Party must:
(a)

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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 order

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

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the 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

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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

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

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action 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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10.

A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

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PRODUCED IN THIS LITIGATION

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10.1. Application. The terms of this Stipulated Protective Order are applicable

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to 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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10.2. Notification. In the event that a Party is required, by a valid discovery

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request, to produce a Nonparty’s confidential information in its

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possession, and the Party is subject to an agreement with the Nonparty

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not to produce the Nonparty’s confidential information, then the Party

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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

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requested; and

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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. If the Nonparty fails to seek a protective order

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from this Court within fourteen (14) days after receiving the notice and

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accompanying information, the Receiving Party may produce the

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Nonparty’s confidential information responsive to the discovery

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request. If the Nonparty timely seeks a protective order, the Receiving
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STIPULATED PROTECTIVE ORDER
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Party shall not produce any information in its possession or control that

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is subject to the confidentiality agreement with the Nonparty before a

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determination by the Court. Absent a court order to the contrary, the

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Nonparty shall bear the burden and expense of seeking protection in this

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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

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

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

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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).

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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

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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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13.

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MISCELLANEOUS
13.1. Right to Further Relief. Nothing in this Stipulated Protective Order
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STIPULATED PROTECTIVE ORDER
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abridges the right of any person to seek its modification by the Court in

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the future.

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

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Stipulated Protective Order, no Party waives any right it otherwise

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would have to object to disclosing or producing any information or item

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on any ground not addressed in this Stipulated Protective Order.

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Similarly, no Party waives any right to object on any ground to use in

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evidence of any of the material covered by this Stipulated Protective

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Order.

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

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

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Material may only be filed under seal pursuant to a court order

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authorizing the sealing of the specific Protected Material at issue. If a

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Party’s request to file Protected Material under seal is denied by the

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Court, then the Receiving Party may file the information in the public

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record unless otherwise instructed by the Court.

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14.

FINAL DISPOSITION

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After the final disposition of this Action, within sixty (60) days of a written

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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

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

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

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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,

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summaries or any other format reproducing or capturing any of the Protected
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Material. Notwithstanding this provision, Counsel is entitled to retain an archival

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copy of all pleadings; motion papers; trial, deposition, and hearing transcripts; legal

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memoranda; correspondence; deposition and trial exhibits; expert reports; attorney

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work product; and consultant and expert work product, even if such materials contain

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Protected Material. Any such files and/or 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 5.

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15.

VIOLATION

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

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

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monetary sanctions.

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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

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Dated:

November 14, 2022

JONES DAY

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By: /s/ Katie Gonzalez
Katie Gonzalez
Attorneys for Defendant
Experian Information Solutions, Inc.

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Dated:

November 14, 2022

LOKER LAW, APC
By: /s/ Matthew M. Loker
Matthew M. Loker
Attorneys for Plaintiff

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Dated:

November 14, 2022

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SESSIONS, ISRAEL & SHARTLE,
LLP
By: /s/ James K. Schultz
James K. Schultz
Attorneys for Defendant
Convergent Outsourcing, Inc.

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Dated:

November 14, 2022

PARIS AND PARIS, LLP

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By: /s/ Jeffrey Alan Paris
Jeffrey Alan Paris
Attorneys for Defendant
ProCollect, Inc.

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FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

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Dated: November 18, 2022

Karen L. Stevenson
United States Magistrate Judge

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STIPULATED PROTECTIVE ORDER
Case No. 2:22-cv-05299

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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 entirety

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

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District Court for the Central District of California on

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case of Kiri Villa v. ProCollect, Inc.et al., 2:22-cv-05299-MWF (KSx). I agree to

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

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

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

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

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

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Stipulated Protective Order.

[date] in the

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

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

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Stipulated Protective Order, even if such enforcement proceedings occur after

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termination of this action. I hereby appoint

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of

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as 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:

[full name]
[address and telephone number]

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STIPULATED PROTECTIVE ORDER
Case No. 2:22-cv-05299