Eric Pearson v. The Cincinnati Insurance Company et al

Filing 38

STIPULATED PROTECTIVE ORDER [37 by Magistrate Judge Patricia Donahue. See document for details. (es)

1 LEWIS BRISBOIS BISGAARD & SMITH LLP
JULIAN J. PARDINI, SB# 133878
Email: [e-mail]
2
RODOLFO OROZCO BEAS, SB# 320459
Email: [e-mail]
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45 Fremont Street, Suite 3000
4 San Francisco, California 94105
Telephone: [phone]
5 Facsimile: 415.434.0882
6 ANGELA A. ZANIN, SB# 229149
E-Mail: [e-mail]
7 633 West 5th Street, Suite 4000
Los Angeles, California 90071
8 Telephone: [phone]
Facsimile: 213.250.7900
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Attorneys for Defendant, THE CINCINNATI INSURANCE COMPANY
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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION

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ERIC PEARSON, an individual,

Case No. 2:24-cv-03370-SB-PD

Plaintiff,

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STIPULATED PROTECTIVE ORDER

vs.

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(PD Version)

THE CINCINNATI INSURANCE
19 COMPANY, an OHIO corporation, and
DOES 1 TO 20, INCLUSIVE,
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Defendants.
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? Check if submitted without material
modifications to PD form

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LEWIS

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1.

INTRODUCTION
1.1

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

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1 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to
2 enter the following Stipulated Protective Order. The parties acknowledge that this
3 Order does not confer blanket protections on all disclosures or responses to
4 discovery and that the protection it affords from public disclosure and use extends
5 only to the limited information or items that are entitled to confidential treatment
6 under the applicable legal principles. The parties further acknowledge, as set forth
7 in Section 12.3, below, that this Stipulated Protective Order does not entitle them to
8 file confidential information under seal; Civil Local Rule 79-5 sets forth the
9 procedures that must be followed and the standards that will be applied when a party
10 seeks permission from the court to file material under seal.
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1.2

GOOD CAUSE STATEMENT

12

This case involves a dispute between Plaintiff Eric Pearson (“Plaintiff’) and

13 Defendant The Cincinnati Insurance Company (“Defendant”) regarding alleged
14 coverage benefits owed to Plaintiff under the policy issued to him by Defendant.
15 Documents for which this protective order is sought include internal documents
16 maintained by Plaintiff and Defendant, as well as internal documents maintained by
17 the various third parties involved in the underlying claim. Such confidential and
18 proprietary materials and information constitute, among other things, confidential
19 business information, information regarding confidential business practices, or other
20 commercial information, information otherwise generally unavailable to the public,
21 or which may be privileged or otherwise protected from disclosure.
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In addition, Defendant notes that one third party has requested that all parties

23 enter into a protective order prior to that third party’s production of documents
24 responsive to the document subpoena issued by Defendant.

LEWIS

25 2.

DEFINITIONS

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2.1

Action: this pending federal law suit.

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2.2

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

28 of information or items under this Order.

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1

2.3

“CONFIDENTIAL” Information or Items: information (regardless of

2 how it is generated, stored or maintained) or tangible things that qualify for protection
3 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good
4 Cause Statement.
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2.4

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

6 support staff).
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2.5

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

8 items that it produces in disclosures or in responses to discovery as
9 “CONFIDENTIAL.”
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2.6

Disclosure or Discovery Material: all items or information, regardless

11 of the medium or manner in which it is generated, stored, or maintained (including,
12 among other things, testimony, transcripts, and tangible things), that are produced or
13 generated in disclosures or responses to discovery in this matter.
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2.7 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 to serve as
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an expert witness or as a consultant in this Action.
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2.8 House Counsel: attorneys who are employees of a party to this Action.
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House Counsel does not include Outside Counsel of Record or any other outside
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counsel.
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2.9 Non-Party: any natural person, partnership, corporation, association, or
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other legal entity not named as a Party to this action.
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2.10 Outside Counsel of Record: attorneys who are not employees of a party
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24 to this Action but are retained to represent or advise a party to this Action and have
25 appeared in this Action on behalf of that party or are affiliated with a law firm which
26 has appeared on behalf of that party, and includes support staff.
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LEWIS

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1

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

2 employees, consultants, retained experts, and Outside Counsel of Record (and their
3 support staffs).
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2.12 Producing Party: a Party or Non-Party that produces Disclosure or

5 Discovery Material in this Action.
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2.13 Professional Vendors: persons or entities that provide litigation support

7 services (e.g., photocopying, videotaping, translating, preparing exhibits or
8 demonstrations, and organizing, storing, or retrieving data in any form or medium)
9 and their employees and subcontractors.
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2.14 Protected Material: any Disclosure or Discovery Material that is
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designated as “CONFIDENTIAL.”
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2.15 Receiving Party: a Party that receives Disclosure or Discovery Material
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from a Producing Party.
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15 3.

SCOPE

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The protections conferred by this Stipulation and Order cover not only

17 Protected Material (as defined above), but also (1) any information copied or
18 extracted from Protected Material; (2) all copies, excerpts, summaries, or
19 compilations of Protected Material; and (3) any testimony, conversations, or
20 presentations by Parties or their Counsel that might reveal Protected Material.
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Any use of Protected Material at trial will be governed by the orders of the

22 trial judge. This Order does not govern the use of Protected Material at trial.
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DURATION
24 4.
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Once a case proceeds to trial, all of the information that was designated as

26 confidential or maintained pursuant to this protective order becomes public and will
27 be presumptively available to all members of the public, including the press, unless

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28 compelling reasons supported by specific factual findings to proceed otherwise are

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1 made to the trial judge in advance of the trial. See Kamakana v. City and County of
2 Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing “good cause”
3 showing for sealing documents produced in discovery from “compelling reasons”
4 standard when merits-related documents are part of court record). Accordingly, the
5 terms of this protective order do not extend beyond the commencement of the trial.
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DESIGNATING PROTECTED MATERIAL
5.1

Exercise of Restraint and Care in Designating Material for Protection.

Each Party or Non-Party that designates information or items for protection under this
Order must take care to limit any such designation to specific material that qualifies
under the appropriate standards. The Designating Party must designate for protection
only those parts of material, documents, items, or oral or written communications that
qualify so that 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.
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 on other parties) may expose the Designating
Party to sanctions.
If it comes to a Designating Party’s attention that information or items that it
designated for protection do not qualify for protection, that Designating Party must
promptly notify all other Parties that it is withdrawing the inapplicable designation.
5.2

Manner and Timing of Designations. Except as otherwise provided in

this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
under this Order must be clearly so designated before the material is disclosed or
produced.

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Designation in conformity with this Order requires:

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

3 but excluding transcripts of depositions or other pretrial or trial proceedings), that
4 the Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter
5 “CONFIDENTIAL legend”), to each page that contains protected material. If only a
6 portion or portions of the material on a page qualifies for protection, the Producing
7 Party also must clearly identify the protected portion(s) (e.g., by making appropriate
8 markings in the margins).
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A Party or Non-Party that makes original documents available for

10 inspection need not designate them for protection until after the inspecting Party has
11 indicated which documents it would like copied and produced. During the inspection
12 and before the designation, all of the material made available for inspection will be
13 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents
14 it wants copied and produced, the Producing Party must determine which documents,
15 or portions thereof, qualify for protection under this Order. Then, before producing
16 the specified documents, the Producing Party must affix the “CONFIDENTIAL
17 legend” to each page that contains Protected Material. If only a portion or portions
18 of the material on a page qualifies for protection, the Producing Party also must clearly
19 identify the protected portion(s) (e.g., by making appropriate markings in the
20 margins).
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(b) for testimony given in depositions that the Designating Party identify the

22 Disclosure or Discovery Material on the record, before the close of the deposition all
23 protected testimony.
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(c) for information produced in some form other than documentary and for any

25 other tangible items, that the Producing Party affix in a prominent place on the exterior
26 of the container or containers in which the information

is stored the legend

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

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1 protection, the Producing Party, to the extent practicable, will identify the protected
2 portion(s).
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5.3

Inadvertent Failures to Designate. If timely corrected, an inadvertent

4 failure to designate qualified information or items does not, standing alone, waive the
5 Designating Party’s right to secure protection under this Order for such material.
6 Upon timely correction of a designation, the Receiving Party must make reasonable
7 efforts to assure that the material is treated in accordance with the provisions of this
8 Order.
9 6.

CHALLENGING CONFIDENTIALITY DESIGNATIONS

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6.1

Timing of Challenges.

Any Party or Non-Party may challenge a

11 designation of confidentiality at any time that is consistent with the Court’s
12 Scheduling Order.
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6.2

Meet and Confer.

The Challenging Party will initiate the dispute

resolution process (and, if necessary, file a discovery motion) under Local Rule 37.1
et seq.
6.3

The burden of persuasion in any such challenge proceeding will 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 Challenging Party to sanctions. Unless the Designating
Party has waived or withdrawn the confidentiality designation, all parties will
continue to afford the material in question the level of protection to which it is
entitled under the Producing Party’s designation until the Court rules on the
challenge.
7.

ACCESS TO AND USE OF PROTECTED MATERIAL
7.1

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

disclosed or produced by another Party or by a Non-Party in connection with this
Action only for prosecuting, defending, or attempting to settle this Action. Such

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1 Protected Material may be disclosed only to the categories of persons and under the
2 conditions described in this Order. When the Action has been terminated, a Receiving
3 Party must comply with the provisions of section 13 below (FINAL DISPOSITION).
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Protected Material must be stored and maintained by a Receiving Party at a

5 location and in a secure manner that ensures that access is limited to the persons
6 authorized under this Order.
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7.2

Disclosure of “CONFIDENTIAL” Information or Items. Unless

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

Party

may

disclose

any

information

or

item

designated

10 “CONFIDENTIAL” only to:
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(a) the Receiving Party’s Outside Counsel of Record in this Action, as well as

12 employees of said Outside Counsel of Record to whom it is reasonably necessary to
13 disclose the information for this Action;
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(b) the officers, directors, and employees (including House Counsel) of the

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

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

17 disclosure is reasonably necessary for this Action and who have signed the
18 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
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LEWIS

(d) the Court and its personnel;
(e) court reporters and their staff;
(f) professional jury or trial consultants, mock jurors, and Professional Vendors
to whom disclosure is reasonably necessary for this Action and who have signed the
“Acknowledgment and Agreement to Be Bound” (Exhibit A);
(g) the author or recipient of a document containing the information or a
custodian or other person who otherwise possessed or knew the information;
(h) during their depositions, witnesses ,and attorneys for witnesses, in the

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

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1 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will
2 not be permitted to keep any confidential information unless they sign the
3 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
4 agreed by the Designating Party or ordered by the court. Pages of transcribed
5 deposition testimony or exhibits to depositions that reveal Protected Material may be
6 separately bound by the court reporter and may not be disclosed to anyone except as
7 permitted under this Stipulated Protective Order; and
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(i) any mediator or settlement officer, and their supporting personnel, mutually

9 agreed upon by any of the parties engaged in settlement discussions.
10 8.
PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN
11 OTHER LITIGATION
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If a Party is served with a subpoena or a court order issued in other litigation

14 that compels disclosure of any information or items designated in this Action as
15 “CONFIDENTIAL,” that Party must:
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(a) promptly notify in writing the Designating Party. Such notification will

17 include a copy of the subpoena or court order;
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(b) promptly notify in writing the party who caused the subpoena or order to

19 issue in the other litigation that some or all of the material covered by the subpoena
20 or order is subject to this Protective Order. Such notification will include a copy of
21 this Stipulated Protective Order; and
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(c) cooperate with respect to all reasonable procedures sought to be pursued

23 by the Designating Party whose Protected Material may be affected.
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If the Designating Party timely seeks a protective order, the Party served with

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

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27 or order issued, unless the Party has obtained the Designating Party’s permission. The
28 Designating Party will bear the burden and expense of seeking protection in that court
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1 of its confidential material and nothing in these provisions should be construed as
2 authorizing or encouraging a Receiving Party in this Action to disobey a lawful
3 directive from another court.
4 9.

A

NON-PARTY’S

PROTECTED

MATERIAL

SOUGHT

TO

BE

5 PRODUCED IN THIS LITIGATION
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(a) The terms of this Order are applicable to information produced by a NonParty in this Action and designated as “CONFIDENTIAL.”

Such information

produced by Non-Parties 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

13 a Non-Party’s confidential information in its possession, and the Party is subject to an
14 agreement with the Non-Party not to produce the Non-Party’s confidential
15 information, then the Party will:
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(1) promptly notify in writing the Requesting Party and the Non-Party

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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;

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(2) promptly provide the Non-Party with a copy of the Stipulated

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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) make the information requested available for inspection by the Non-

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Party, if requested.

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

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

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27 If the Non-Party timely seeks a protective order, the Receiving Party will not produce
28 any information in its possession or control that is subject to the confidentiality
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1 agreement with the Non-Party before a determination by the court. Absent a court
2 order to the contrary, the Non-Party will bear the burden and expense of seeking
3 protection in this court of its Protected Material.
4 10.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

6 Protected Material to any person or in any circumstance not authorized under this
7 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
8 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
9 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
10 persons to whom unauthorized disclosures were made of all the terms of this Order,
11 and (d) request such person or persons to execute the “Acknowledgment and
12 Agreement to Be Bound” that is attached hereto as Exhibit A.
13 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
14 PROTECTED MATERIAL
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When a Producing Party gives notice to Receiving Parties that certain

16 inadvertently produced material is subject to a claim of privilege or other protection,
17 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
18 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
19 may be established in an e-discovery order that provides for production without prior
20 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
21 parties reach an agreement on the effect of disclosure of a communication or
22 information covered by the attorney-client privilege or work product protection, the
23 parties may incorporate their agreement in the stipulated protective order submitted

LEWIS

24 to the court.
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12. MISCELLANEOUS
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12.1 Right to Further Relief. Nothing in this Order abridges the right of any
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person to seek its modification by the Court in the future.
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12.2 Right to Assert Other Objections. By stipulating to the entry of this

2 Protective Order no Party waives any right it otherwise would have to object to
3 disclosing or producing any information or item on any ground not addressed in this
4 Stipulated Protective Order. Similarly, no Party waives any right to object on any
5 ground to use in evidence of any of the material covered by this Protective Order.
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12.3 Filing Protected Material. A Party that seeks to file under seal any

7 Protected Material must comply with Civil Local Rule 79-5. Protected Material may
8 only be filed under seal pursuant to a court order authorizing the sealing of the specific
9 Protected Material at issue. If a Party's request to file Protected Material under seal
10 is denied by the court, then the Receiving Party may file the information in the public
11 record unless otherwise instructed by the court.
12 13.

FINAL DISPOSITION

13

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

14 days of a written request by the Designating Party, each Receiving Party must return
15 all Protected Material to the Producing Party or destroy such material. As used in this
16 subdivision, “all Protected Material” includes all copies, abstracts, compilations,
17 summaries, and any other format reproducing or capturing any of the Protected
18 Material. Whether the Protected Material is returned or destroyed, the Receiving
19 Party must submit a written certification to the Producing Party (and, if not the same
20 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies
21 (by category, where appropriate) all the Protected Material that was returned or
22 destroyed and (2) affirms that the Receiving Party has not retained any copies,
23 abstracts, compilations, summaries or any other format reproducing or capturing any
24 of the Protected Material. Notwithstanding this provision, Counsel are entitled to
25 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing
26 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
27 reports, attorney work product, and consultant and expert work product, even if such

LEWIS

28 materials contain Protected Material. Any such archival copies that contain or

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1 constitute Protected Material remain subject to this Protective Order as set forth in
2 Section 4 (DURATION).
3 14.

Any willful violation of this Order may be punished by civil or criminal

4 contempt proceedings, financial or evidentiary sanctions, reference to disciplinary
5 authorities, or other appropriate action at the discretion of the Court.
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7 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
8
9 DATED: November 19, 2024 __________/s/ David C. Gentry (PHV)
___________________________
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Attorneys for Plaintiff
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DATED: November 21, 2024___________ _/s/ Julian J. Pardini
13 ___________________________
Attorneys for Defendant
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FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

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DATED: November 22, 2024
20 _____________
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PATRICIA DONAHUE

__________________________________
HON. PATRICIA DONAHUE
United States Magistrate Judge

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EXHIBIT A
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

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I, _____________________________ [full name], of _________________
[full address], declare under penalty of perjury that I have read in its entirety and
understand the Stipulated Protective Order that was issued by the United States
District Court for the Central District of California on [date] in the case of Eric
Pearson v. Cincinnati Insurance Co., Case No. 2-24-cv-03370 (C.D. Cal.). I agree to
comply with and to be bound by all the terms of this Stipulated Protective Order and
I understand and acknowledge that failure to so comply could expose me to sanctions
and punishment in the nature of contempt. I solemnly promise that I will not disclose
in any manner any information or 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 the Central District of California for the purpose of enforcing the terms of this
Stipulated Protective Order, even if such enforcement proceedings occur after
termination of this action. I hereby appoint __________________________ [full
name] of _______________________________________ [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.
Date: ______________________________________
City and State where signed: _________________________________
Printed Name: ______________________________

25 Signature: ________________________________
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FEDERAL COURT PROOF OF SERVICE
Eric Pearson v. The Cincinnati Insurance Company, et al.
USDC-Central District, Western Division, Case No. 2:24-cv-03370-SB-PD

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3 STATE OF CALIFORNIA, COUNTY OF SAN FRANCISCO
At the time of service, I was over 18 years of age and not a party to the action.
My business address is 45 Fremont Street, Suite 3000, San Francisco, CA 94105. I
5 am employed in the office of a member of the bar of this Court at whose direction the
service was made.
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On November 21, 2024, I served the following document(s):
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I served the documents on the following persons at the following addresses
8 (including fax numbers and e-mail addresses, if applicable):
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SEE ATTACHED SERVICE LIST

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The documents were served by the following means:

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(BY COURT’S CM/ECF SYSTEM) Pursuant to Local Rule, I electronically
filed the documents with the Clerk of the Court using the CM/ECF system,
which sent notification of that filing to the persons listed above.

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I declare under penalty of perjury under the laws of the United States of
America and the State of California that the foregoing is true and correct.
Executed on November 21, 2024, at San Francisco, California.

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/s/ Maureen Liu
Maureen Liu

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CERTIFICATE OF SERVICE

Case No. 2:24-cv-03370-SB-PD

SERVICE LIST
Eric Pearson v. The Cincinnati Insurance Company, et al.
2 USDC-Central District, Western Division, Case No. 2:24-cv-03370-SB-PD
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Tel: [phone]
David J. Furtado
Email: [e-mail];
Regina A. Spurley
[e-mail];
David Gentry
[e-mail];
Furtado Law PC
3773 Chery Creek North Drive, Suite [e-mail];
755
Denver, Co 80209; and
9959 Robbins Drive, #B
Beverly Hills, CA 90212
Attorneys for Plaintiff

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LEWIS

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BRISBOIS
BISGAARD
& SMITH LLP
ATTORNEYS AT LAW

149176141.1

2

CERTIFICATE OF SERVICE

Case No. 2:24-cv-03370-SB-PD