DOT Operating Authority Inc. v. LAV Permit Inc. et al

Filing 34

PROTECTIVE ORDER by Magistrate Judge Patricia Donahue re Joint REQUEST for Protective Order for to protect disclosure of confidential information 33 : (See attached) (jm)

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R. Joseph Trojan, CA Bar No. 137,067
[e-mail]
Dylan C. Dang, CA Bar No. 223,455
[e-mail]
TROJAN LAW OFFICES
9250 Wilshire Blvd., Suite 325
Beverly Hills, CA 90212
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff DOT Operating Authority Inc.
Sevag Demirjian (SBN 243656)
[e-mail]
FOUNDATION LAW GROUP LLP
4605 Lankershim Boulevard, Suite 650
North Hollywood, California 91602
Telephone: [phone]
Attorney for Defendants

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UNITED STATES DISTRICT COURT
FOR THE CENTRAL DISTRICT COURT OF CALIFORNIA
DOT Operating Authority Inc.,
a California Corporation,

STIPULATED PROTECTIVE ORDER
Plaintiff,

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v.

HON. PATRICIA DONAHUE
United States Magistrate Judge

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Case No. 2:24-cv-3183 FMO (PDx)

LAV Permit Inc., a California
Corporation; Valentina Mkrtchyan,
an individual; and Rima Arakelyan,
an individual,
Defendants.

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I.

A.

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

proprietary, or private information for which special protection from public disclosure and
from use for any purpose other than prosecuting this litigation may be warranted.
Accordingly, the parties hereby stipulate to and petition the Court to enter the following

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Stipulated Protective Order. The parties acknowledge that this Order does not confer

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blanket 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 items

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that are entitled to confidential treatment under the applicable legal principles. The parties
further acknowledge, as set forth in Section XIII(C), below, that this Stipulated Protective
Order does not entitle them to file confidential information under seal; Civil Local Rule

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79-5 sets forth the procedures that must be followed and the standards that will be applied

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when a party seeks permission from the Court to file material under seal.

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II.

GOOD CAUSE STATEMENT
A.

This action is likely to involve confidential proprietary information such

trade secrets, customer and pricing lists and other valuable research, development,

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commercial, financial, technical and/or proprietary information for which special

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

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

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consist of, among other things, confidential business or financial information, information
regarding confidential business practices, or other confidential research, development, or
commercial information (including information implicating privacy rights of third

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parties), information otherwise generally unavailable to the public, or which may be

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privileged or otherwise protected from disclosure under state or federal statutes, court

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rules, case decisions, or common law. Further, the parties in this action are competitors

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and will likely exchange in discovery documents containing trade secret and/or other nonpublic information that would cause competitive injury if released to the general public.

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Accordingly, to expedite the flow of information, to facilitate the prompt resolution of

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disputes over confidentiality of discovery materials, to adequately protect information the
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parties are entitled to keep confidential, to ensure that the parties are permitted reasonable

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necessary uses of such material in preparation for and in the conduct of trial, to address

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their handling at the end of the litigation, and serve the ends of justice, a protective order
for such information is justified in this matter. It is the intent of the parties that information
will not be 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 case.

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III.

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DEFINITIONS
A.

Action: This protective order governs the following case: DOT Operating

Authority Inc. v. LAV Permit Inc., et al., Case No. 2:24-cv-3183 FMO (PDx).
B.

Challenging Party: A Party or Non-Party that challenges the designation of

information or items under this Order.
C.

“CONFIDENTIAL” Information or Items: Information (regardless 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.
D.

“HIGHLY CONFIDENTIAL-ATTORNEYS’ EYES ONLY” Information

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or Items: Information (regardless of how it is generated, stored, or maintained) or tangible

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things that qualify for protection under Federal Rule of Civil Procedure 26(c), and

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constitute trade secret and/or other non-public information that would cause competitive
injury if released to the general public as specified above in the good cause statement.
D.

Counsel: Outside Counsel of Record (as well as their support staff).

E.

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

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items that it produces in disclosures or in responses to discovery as “CONFIDENTIAL”

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or “HIGHLY CONFIDENTIAL-ATTORNEYS’ EYES ONLY.”

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F.

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

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

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

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disclosures or responses to discovery in this matter.
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G.

pertinent to the litigation who has been retained by a Party or its counsel to serve as an
expert witness or as a consultant in this Action.
H.
I.

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J.

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

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

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

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

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

K.

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

employees, consultants, retained experts, and Outside Counsel of Record (and their
support staffs).
L.

Producing Party:

A Party or Non-Party that produces Disclosure or

Discovery Material in this Action.

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M.

Professional Vendors: Persons or entities that provide litigation support

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services

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

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(e.g.,

photocopying,

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preparing

exhibits

or

Protected Material: Any Disclosure or Discovery Material that is designated

as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL-ATTORNEYS’ EYES ONLY.”
O.

Receiving Party: A Party that receives Disclosure or Discovery Material

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from a Producing Party.

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IV.

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translating,

their employees and subcontractors.

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videotaping,

SCOPE
A.

The protections conferred by this Stipulation and Order cover not only

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

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

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Counsel that might reveal Protected Material.

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B.

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

trial judge. This Order does not govern the use of Protected Material at trial.
V.

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DURATION
A.

Even after final disposition of this litigation, the confidentiality obligations

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

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

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of (1) dismissal of all claims and defenses in this Action, with or without prejudice; and
(2) final judgment herein after the completion and exhaustion of all appeals, rehearings,
remands, trials, or reviews of this Action, including the time limits for filing any motions

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or applications for extension of time pursuant to applicable law.

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VI.

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DESIGNATING PROTECTED MATERIAL
A.

Exercise of Restraint and Care in Designating Material for Protection
1.

Each Party or Non-Party that designates information or items for

protection under this Order must take care to limit any such designation to

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specific material that qualifies under the appropriate standards.

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Designating Party must designate for protection only those parts of material,

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documents, items, or oral or written communications that qualify so that

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The

other portions of the material, documents, items, or communications for
which protection is not warranted are not swept unjustifiably within the
ambit of this Order.

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2.

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

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

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Mass, indiscriminate, or routinized designations are prohibited.

development process or to impose unnecessary expenses and burdens on
other parties) may expose the Designating Party to sanctions.

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3.

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items that it designated for protection do not qualify for protection, that

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

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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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B.

Manner and Timing of Designations
1.

Except as otherwise provided in this Order (see, e.g., Section B(2)(b)

below), or as otherwise stipulated or ordered, Disclosure or Discovery

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Material that qualifies for protection under this Order must be clearly so

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designated before the material is disclosed or produced.

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2.

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Designation in conformity with this Order requires the following:
a.

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

documents, but excluding transcripts of depositions or other pretrial
or trial proceedings), that the Producing Party affix at a minimum,

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the legend “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL-

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ATTORNEYS’ EYES ONLY” (hereinafter “CONFIDENTIAL

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legend”), to each page that contains protected material. If only a
portion or portions of the material on a page qualifies for protection,
the Producing Party also must clearly identify the protected

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

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b.

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for inspection need not designate them for protection until after the

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A Party or Non-Party that makes original documents available

inspecting Party has indicated which documents it would like copied
and produced. During the inspection and before the designation, all
of the material made available for inspection shall be deemed

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“CONFIDENTIAL”

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ATTORNEYS’ EYES ONLY.”

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identified the documents it wants copied and produced, the

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or

“HIGHLY

CONFIDENTIAL-

After the inspecting Party has

Producing Party must determine which documents, or portions
thereof, qualify for protection under this Order.

Then, before

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producing the specified documents, the Producing Party must affix

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the “CONFIDENTIAL legend” 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
identify the protected portion(s) (e.g., by making appropriate

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markings in the margins).

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c.

For testimony given in depositions, that the Designating Party

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identify the Disclosure or Discovery Material on the record, before

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the close of the deposition all protected testimony.

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d.

For information produced in form other than document and

for any 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” or

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“HIGHLY CONFIDENTIAL-ATTORNEYS’ EYES ONLY.” If

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only a portion or portions of the information warrants protection, the
Producing Party, to the extent practicable, shall identify the protected

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portion(s).

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C.

Inadvertent Failure to Designate

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1.

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information or items does not, standing alone, waive the Designating Party’s

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right to secure protection under this Order for such material. Upon timely
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 provisions

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of this Order.
VII.

CHALLENGING CONFIDENTIALITY DESIGNATIONS
A.

Timing of Challenges
1.

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Any party or Non-Party may challenge a designation of

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

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If timely corrected, an inadvertent failure to designate qualified

Order.
B.

Meet and Confer

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under Local Rule 37.1 et seq.

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C.

The Challenging Party shall initiate the dispute resolution process

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

Designating Party. Frivolous challenges, and those made for an improper purpose (e.g.,
to harass or impose unnecessary expenses and burdens on other parties) may expose the

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Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn

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the confidentiality designation, all parties shall continue to afford the material in question

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the level of protection to which it is entitled under the Producing Party’s designation until

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the Court rules on the challenge.
VIII. ACCESS TO AND USE OF PROTECTED MATERIAL
A.

Basic Principles

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1.

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

A Receiving Party may use Protected Material that is disclosed or

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

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

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under the conditions described in this Order. When the Action has been

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terminated, a Receiving Party must comply with the provisions of Section

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XIV below.

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2.

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

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Protected Material must be stored and maintained by a Receiving

to the persons authorized under this Order.
B.

Disclosure of “CONFIDENTIAL” Information or Items

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

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designated “CONFIDENTIAL” only to:

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

a.

The Receiving Party’s Outside Counsel of Record in this

Action, as well as employees of said Outside Counsel of Record to

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whom it is reasonably necessary to disclose the information for this

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Action;
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b.

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Counsel) of the Receiving Party to whom disclosure is reasonably

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The officers, directors, and employees (including House

necessary for this Action;
c.

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

whom disclosure is reasonably necessary for this Action and who

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have signed the “Acknowledgment and Agreement to Be Bound”

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(Exhibit A);

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d.

The Court and its personnel;

e.

Court reporters and their staff;

f.

Professional jury or trial consultants, mock jurors, and

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Professional Vendors to whom disclosure is reasonably necessary for

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this Action and who have signed the “Acknowledgment and

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Agreement to be Bound” attached as Exhibit A hereto;

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g.

The author or recipient of a document containing the

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

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h.

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witnesses, 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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During their depositions, witnesses, and attorneys for

“Acknowledgment and Agreement to Be Bound;” and (ii) they will
not be permitted to keep any confidential information unless they
sign the “Acknowledgment and Agreement to Be Bound,” unless

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otherwise agreed by the Designating Party or ordered by the Court.

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Pages of transcribed deposition testimony or exhibits to depositions

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that reveal Protected Material may be separately bound by the court

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reporter and may not be disclosed to anyone except as permitted
under this Stipulated Protective Order; and

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i.

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

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Any mediator or settlement officer, and their supporting

settlement discussions.
C.

Disclosure of “HIGHLY CONFIDENTIAL-ATTORNEYS’ EYES ONLY”

Information or Items. Unless otherwise ordered by the Court or permitted in writing by

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the designating party, a receiving party may disclose any information or item designated

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“HIGHLY CONFIDENTIAL-ATTORNEYS’ EYES ONLY” only to:

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a.

The Receiving Party’s Outside Counsel of Record in this

Action, as well as employees of said Outside Counsel of Record to
whom it is reasonably necessary to disclose the information for this
Action;

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b.

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whom disclosure is reasonably necessary for this Action and who

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

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

The Court and its personnel;

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d.

Court reporters and their staff;

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e.

Professional jury or trial consultants, mock jurors, and

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Professional Vendors to whom disclosure is reasonably necessary for

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this Action and who have signed the “Acknowledgment and
Agreement to be Bound” attached as Exhibit A hereto;
f.

The author or recipient of a document containing the

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information or a custodian or other person who otherwise possessed

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or knew the information;

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g.

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During their depositions, witnesses, and attorneys for

witnesses, in the Action to whom disclosure is reasonably necessary
provided: (i) the deposing party requests that the witness sign the

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“Acknowledgment and Agreement to Be Bound;” and (ii) they will

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not be permitted to keep any confidential information unless they
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sign the “Acknowledgment and Agreement to Be Bound,” unless

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otherwise agreed by the Designating Party or ordered by the Court.
Pages of transcribed deposition testimony or exhibits to depositions

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that reveal Protected Material may be separately bound by the court

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reporter and may not be disclosed to anyone except as permitted

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under this Stipulated Protective Order; and

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h.

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

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Any mediator or settlement officer, and their supporting

IX.

PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED

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IN OTHER LITIGATION

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A.

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

that compels disclosure of any information or items designated in this Action as
“CONFIDENTIAL” or “HIGHLY CONFIDENTIAL-ATTORNEYS’ EYES ONLY,”
that Party must:

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1.

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shall include a copy of the subpoena or court order;

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2.

Promptly notify in writing the Designating Party. Such notification
Promptly notify in writing the party who caused the subpoena or

order 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 Protective Order.

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Such

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

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3.

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

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B.

Cooperate with respect to all reasonable procedures sought to be

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

with the subpoena or court order shall not produce any information designated in this
action as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL-ATTORNEYS’ EYES

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ONLY” before a determination by the Court from which the subpoena or order issued,

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unless the Party has obtained the Designating Party’s permission. The Designating Party
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shall bear the burden and expense of seeking protection in that court of its confidential

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material and nothing in these provisions should be construed as authorizing or

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encouraging a Receiving Party in this Action to disobey a lawful directive from another
court.
X.

A

NON-PARTY’S

PROTECTED

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PRODUCED IN THIS LITIGATION

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A.

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MATERIAL

SOUGHT

TO

BE

The terms of this Order are applicable to information produced by a Non-

Party in this Action and designated as “CONFIDENTIAL” or “HIGHLY
CONFIDENTIAL-ATTORNEYS’ EYES ONLY.” Such information produced by NonParties in connection with this litigation is protected by the remedies and relief provided
by this Order. Nothing in these provisions should be construed as prohibiting a Non-Party
from seeking additional protections.
B.

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

a Non-Party’s confidential information in its possession, and the Party is subject to an
agreement with the Non-Party not to produce the Non-Party’s confidential information,
then the Party shall:

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1.

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

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agreement with a Non-Party;
2.

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Promptly notify in writing the Requesting Party and the Non-Party

Promptly provide the Non-Party with a copy of the Stipulated

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

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reasonably specific description of the information requested; and

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3.

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Party, if requested.

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C.

Make the information requested available for inspection by the Non-

If the Non-Party fails to seek a protective order from this court within 14

days of receiving the notice and accompanying information, the Receiving Party may
produce the Non-Party’s confidential information responsive to the discovery request. If

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

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information in its possession or control that is subject to the confidentiality agreement
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with the Non-Party before a determination by the court. Absent a court order to the

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contrary, the Non-Party shall bear the burden and expense of seeking protection in this

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court of its Protected Material.
XI.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
A.

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

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

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

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

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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 Order, and (4) request
such person or persons to execute the “Acknowledgment and Agreement to be Bound”

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that is attached hereto as Exhibit A.

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XII.

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INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
PROTECTED MATERIAL
A.

When a Producing Party gives notice to Receiving Parties that certain

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

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

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

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

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review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the parties reach
an agreement on the effect of disclosure of a communication or information covered by
the attorney-client privilege or work product protection, the parties may incorporate their

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agreement in the Stipulated Protective Order submitted to the Court.

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XIII. MISCELLANEOUS

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A.

1.

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Right to Further Relief
Nothing in this Order abridges the right of any person to seek its

modification by the Court in the future.
B.

Right to Assert Other Objections

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any right it otherwise would have to object to disclosing or producing any
information or item on any ground not addressed in this Stipulated

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

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

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By stipulating to the entry of this Protective Order, no Party waives

Order.
C.

Filing Protected Material
1.

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

comply with Civil 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 specific

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

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

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

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XIV. FINAL DISPOSITION
A.

After the final disposition of this Action, as defined in Section V, within

sixty (60) days of a written request by the Designating Party, each Receiving Party must

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

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

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

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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

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

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

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

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provision, Counsel are entitled to retain an archival copy of all pleadings, motion papers,
trial, deposition, and hearing transcripts, legal memoranda, correspondence, deposition

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and trial exhibits, expert reports, attorney work product, and consultant and expert work

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product, even if such materials contain Protected Material. Any such archival copies that
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contain or constitute Protected Material remain subject to this Protective Order as set forth

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in Section V.

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B.

Any willful violation of this 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.
Dated: September 24, 2024

/s/R. Joseph Trojan
R. Joseph Trojan
TROJAN LAW OFFICES
9250 Wilshire Blvd., Suite 325
Beverly Hills, CA 90212
Telephone: [phone]
Facsimile: [phone]
Attorney for Plaintiff
DOT Operating Authority Inc.

Dated: September 24, 2024

/s/Sevag Demirjian
SEVAG DEMIRJIAN (SBN 243656)
[e-mail]
FOUNDATION LAW GROUP LLP
4605 Lankershim Boulevard, Suite 650
North Hollywood, California 91602
Telephone: [phone]
Attorney for Defendants
LAV Permit Inc.,
Valentina Mkrtchyan, and
Rima Arakelyan

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FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

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Dated: September 24, 2024
HON. PATRICIA DONAHUE
United States Magistrate Judge

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EXHIBIT A

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ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

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I,

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[print or type full name], of
[print or type full 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 issue by

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the United States District Court for the Central District of California on

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____________[DATE] in the case of DOT Operating Authority Inc. v. LAV Permit Inc.,
et al. (Case No. 2:24-cv-3183 FMO (PDx)). I agree to comply with and to be bound by
all the terms of this Stipulated Protective Order and I understand and acknowledge that

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failure to so comply could expose me to sanctions and punishment in the nature of

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

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item that is subject to this Stipulated Protective Order to any person or entity except in
strict compliance with the provisions of this Order.
I further agree to submit to the jurisdiction of the United States District Court for

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the Central 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 this

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action. I hereby appoint

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[print or type full name] of
[print or type full address and telephone number] as

my California agent for service of process in connection with this action or any
proceedings related to enforcement of this Stipulated Protective Order.

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Date:

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City and State where sworn and signed:

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Printed Name:

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Signature:

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