Andrew Grant v. Wells Fargo Bank, N.A. et al

Filing 17

PROTECTIVE ORDER by Magistrate Judge Pedro V. Castillo re Stipulation for Protective Order 16 . (see document for details) (hr)

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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11 ANDREW GRANT, an individual;
Plaintiff,

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vs.

Case No. 2:24-CV-05628-SPG-PVCx
STIPULATED PROTECTIVE
ORDER

14 WELLS FARGO BANK, N.A., a
Delaware corporation; JEFF
15 RADEMANN, an individual; and
DOES 1 through 50, inclusive.
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Defendants.
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SMRH:4865-1510-0391.1

STIPULATED PROTECTIVE ORDER

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TO THE HONORABLE COURT, ALL PARTIES AND THEIR

2 ATTORNEYS OF RECORD:
In order to facilitate discovery in the above-caption matter, Plaintiff Andrew

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4 Grant (“Plaintiff”) and Defendants Wells Fargo Bank, N.A. (“Wells Fargo”) and
5 Jeff Rademann (“Rademann”) (Wells Fargo and Rademann are referred to
6 collectively as “Defendants”) hereby agree to the following Jointly Stipulated
Protective Order concerning the CONFIDENTIAL treatment of certain documents
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and information.
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1.
PURPOSES AND LIMITATIONS
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Disclosure and discovery activity in this action are likely to involve
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production of confidential, proprietary, or private information for which special
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protection from public disclosure and from use for any purpose other than
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prosecuting this litigation may be warranted. Accordingly, the parties hereby
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stipulate to and petition the court to enter the following Stipulated Protective Order.
14 The parties acknowledge that this Order does not confer blanket protections on all
15 disclosures or responses to discovery and that the protection it affords from public
16 disclosure and use extends only to the limited information or items that are entitled
17 to confidential treatment under the applicable legal principles. The parties further
18 acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective
19 Order does not entitle them to file confidential information under seal; Civil Local
20 Rule 79-5 sets forth the procedures that must be followed and the standards that will
21 be applied when a party seeks permission from the court to file material under seal.
It is the intent of the parties that information will not be designated as
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23 confidential for tactical reasons and that nothing be so designated without a good
24 faith belief that it has been maintained in a confidential, non-public manner, and
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there is good cause why it should not be part of the public record of this case.
2.

DEFINITIONS
2.1

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

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STIPULATED PROTECTIVE ORDER

1 designation of information or items under this Order.
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2.2

“CONFIDENTIAL” Information or Items: information (regardless of

3 how it is generated, stored or maintained) or tangible things that qualify for
4 protection under Federal Rule of Civil Procedure 26(c).
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2.3

Counsel (without qualifier): Outside Counsel of Record and House

6 Counsel (as well as their support staff).
2.4 Designating Party: a Party or Non-Party that designates information or
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items that it produces in disclosures or is otherwise disclosed in discovery through
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responses, subpoenas, etc. as “CONFIDENTIAL.”
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2.5 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 (including,
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among other things, testimony, transcripts, and tangible things), that are produced
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or generated in disclosures or or is otherwise disclosed in discovery through
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responses, subpoenas, etc. discovery in this matter.
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2.6 Expert: a person with specialized knowledge or experience in a matter
15 pertinent to the litigation who has been retained by a Party or its counsel to serve as
16 an expert witness or as a consultant in this action.
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2.7

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

18 House Counsel does not include Outside Counsel of Record or any other outside
19 counsel.
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2.8

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

21 or other legal entity not named as a Party to this action.
2.9 Outside Counsel of Record: attorneys who are not employees of a party
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23 to this action but are retained to represent or advise a party to this action and have
24 appeared in this action on behalf of that party or are affiliated with a law firm which
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has appeared on behalf of that party.
2.10 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).

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STIPULATED PROTECTIVE ORDER

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2.11 Producing Party: a Party or Non-Party that produces Disclosure or

2 Discovery Material in this action.
2.12 Professional Vendors: persons or entities that provide litigation

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4 support services (e.g., photocopying, videotaping, translating, preparing exhibits or
5 demonstrations, and organizing, storing, or retrieving data in any form or medium)
6 and their employees and subcontractors.
2.13 Protected Material: any Disclosure or Discovery Material that is
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designated as “CONFIDENTIAL.”
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2.14 Receiving Party: a Party that receives Disclosure or Discovery
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Material from a Producing Party.
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3.
SCOPE
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The protections conferred by this Stipulation and Order cover not only

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13 Protected Material (as defined above), but also (1) any information copied or
14 extracted from Protected Material; (2) all copies, excerpts, summaries, or
15 compilations of Protected Material; and (3) any testimony, conversations, or
16 presentations by Parties or their Counsel that might reveal Protected Material.
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However, the protections conferred by this Stipulation and Order do not cover the
following information: (a) any information that is in the public domain at the time
of disclosure to a Receiving Party or becomes part of the public domain after its
disclosure to a Receiving Party as a result of publication not involving a violation
of this Order, including becoming part of the public record through trial or
otherwise. Any use of Protected Material at trial shall be governed by a separate
agreement or order.
4.

DURATION

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Even after final disposition of this litigation, the confidentiality obligations
imposed by this Order shall remain in effect until a Designating Party agrees
otherwise in writing or a court order otherwise directs. Final disposition shall be
deemed to be the later of (1) dismissal of all claims and defenses in this action, with

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STIPULATED PROTECTIVE ORDER

1 or without prejudice; and (2) final judgment herein after the completion and
2 exhaustion of all appeals, rehearings, remands, trials, or reviews of this action,
3 including the time limits for filing any motions or applications for extension of time
4 pursuant to applicable law.
5 5.

DESIGNATING PROTECTED MATERIAL

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5.1

Exercise of Restraint and Care in Designating Material for Protection.

7 Each Party or Non-Party that designates information or items for protection under
8 this Order must take care to limit any such designation to specific material that
9 qualifies under the appropriate standards. The Designating Party must designate for
10 protection only those parts of material, documents, items, or oral or written
11 communications that qualify – so that other portions of the material, documents,
12 items, or communications for which protection is not warranted are not swept
13 unjustifiably within the ambit of this Order.
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Mass, indiscriminate, or routinized designations are prohibited. Designations

15 that are shown to be clearly unjustified or that have been made for an improper
purpose (e.g., to unnecessarily encumber or retard the case development process or
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to impose unnecessary expenses and burdens on other parties) expose the
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Designating Party to sanctions.
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If it comes to a Designating Party’s attention that information or items that it
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designated for protection do not qualify for protection, that Designating Party must
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promptly notify all other Parties that it is withdrawing the mistaken designation.
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5.2 Manner and Timing of Designations. Except as otherwise provided in
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this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
23 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
24 under this Order must be clearly so designated before the material is disclosed or
25 produced.
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Designation in conformity with this Order requires:

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STIPULATED PROTECTIVE ORDER

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(a)

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

2 documents, but excluding transcripts of depositions or other pretrial or trial
3 proceedings), that the Producing Party affix the legend “CONFIDENTIAL” to each
4 page that contains protected material. If only a portion or portions of the material on
5 a page qualifies for protection, the Producing Party also must clearly identify the
6 protected portion(s) (e.g., by making appropriate markings in the margins).
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A Party or Non-Party that makes original documents or materials
available for inspection need not designate them for protection until after the
inspecting Party has indicated which material it would like copied and produced.
During the inspection and before the designation, all of the material made available
for inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has
identified the documents it wants copied and produced, the Producing Party must
determine which documents, or portions thereof, qualify for protection under this
Order. Then, before producing the specified documents, the Producing Party must

14 affix the “CONFIDENTIAL” legend to each page that contains Protected Material.
15 If only a portion or portions of the material on a page qualifies for protection, the
16 Producing Party also must clearly identify the protected portion(s) (e.g., by making
17 appropriate markings in the margins).
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(b) for testimony given in deposition or in other pretrial proceedings,

19 that the Designating Party identify on the record, before the close of the deposition,
20 hearing, or other proceeding, all protected testimony, or at any time within 30 days
21 after the date of receipt of the deposition transcript.
(c) for information produced in some form other than documentary and
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23 for any other tangible items, that the Producing Party affix in a prominent place on
24 the exterior of the container or containers in which the information or item is stored
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the legend “CONFIDENTIAL.” If only a portion or portions of the information or
item warrant protection, the Producing Party, to the extent practicable, shall identify
the protected portion(s).

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STIPULATED PROTECTIVE ORDER

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5.3

Inadvertent Failures to Designate. If timely corrected, an inadvertent

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

CHALLENGING CONFIDENTIALITY DESIGNATIONS
6.1

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

designation of confidentiality at any time that is consistent with the Court’s
Scheduling Order. Unless a prompt challenge to a Designating Party’s
confidentiality designation is necessary to avoid foreseeable, substantial unfairness,
unnecessary economic burdens, or a significant disruption or delay of the litigation,
a Party does not waive its right to challenge a confidentiality designation by electing
not to mount a challenge promptly after the original designation is disclosed.
6.2

Meet and Confer. The Challenging Party shall initiate the dispute

15 resolution process by providing written notice of each designation it is challenging
16 and describing the basis for each challenge. To avoid ambiguity as to whether a
17 challenge has been made, the written notice must recite that the challenge to
18 confidentiality is being made in accordance with this specific paragraph of the
19 Protective Order. The parties shall attempt to resolve each challenge in good faith
20 and must begin the process by conferring directly (in voice to voice dialogue; other
21 forms of communication are not sufficient) within 14 days of the date of service of
22 notice. In conferring, the Challenging Party must explain the basis for its belief that
23 the confidentiality designation was not proper and must give the Designating Party
24 an opportunity to review the designated material, to reconsider the circumstances,
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and, if no change in designation is offered, to explain the basis for the chosen
designation. A Challenging Party may proceed to the next stage of the challenge
process only if it has engaged in this meet and confer process first or establishes
that the Designating Party is unwilling to participate in the meet and confer process

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STIPULATED PROTECTIVE ORDER

1 in a timely manner.
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6.3

Judicial Intervention. If the Parties cannot resolve a challenge

3 without court intervention, the Designating Party shall file and serve a motion to
4 retain confidentiality under Civil Local Rules 7-4 through 7-8 (and in compliance
5 with Civil Local Rule 79-5, if applicable) within 21 days of the initial notice of
6 challenge or within 14 days of the parties agreeing that the meet and confer process
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will not resolve their dispute, whichever is earlier. Each such motion must be
accompanied by a competent declaration affirming that the movant has complied
with the meet and confer requirements imposed in the preceding paragraph. Failure
by the Designating Party to make such a motion including the required declaration
within 21 days (or 14 days, if applicable) shall automatically waive the
confidentiality designation for each challenged designation. In addition, the
Challenging Party may file a motion challenging a confidentiality designation at
any time if there is good cause for doing so, including a challenge to the designation

14 of a deposition transcript or any portions thereof. Any motion brought pursuant to
15 this provision must be accompanied by a competent declaration affirming that the
16 movant has complied with the meet and confer requirements imposed by the
17 preceding paragraph.
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The burden of persuasion in any such challenge proceeding shall be on the

19 Designating Party. Frivolous challenges, and those made for an improper purpose
20 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may
21 expose the Challenging Party to sanctions. Unless the Designating Party has waived
22 or withdrawn the confidentiality designation, all parties shall continue to afford the
23 material in question the level of protection to which it is entitled under the
24 Producing Party’s designation until the Court rules on the challenge.
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STIPULATED PROTECTIVE ORDER

1 7.
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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
case only for prosecuting, defending, or attempting to settle this litigation. Such
Protected Material may be disclosed only to the categories of persons and under the

6 conditions described in this Order. When the litigation has been terminated, a
7 Receiving Party must comply with the provisions of section 13 below (FINAL
8 DISPOSITION).
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Protected Material must be stored and maintained by a Receiving Party at a

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

Disclosure of “CONFIDENTIAL” Information or Items.

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

14 Designating Party, a Receiving Party may disclose any information or item
15 designated “CONFIDENTIAL” only to:
(a)

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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 litigation;
(b)

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

the Receiving Party to whom disclosure is reasonably necessary for this litigation
and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit
A);
(c)

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

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

24 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
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(d) the court and its personnel;
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(e)

court reporters and their staff, professional jury or trial consultants,

27 mock jurors, and Professional Vendors to whom disclosure is reasonably necessary
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STIPULATED PROTECTIVE ORDER

1 for this litigation and who have signed the “Acknowledgment and Agreement to Be
2 Bound” (Exhibit A); during their depositions, witnesses in the action to whom
3 disclosure is reasonably necessary and who have signed the “Acknowledgment and
4 Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating
5 Party or ordered by the court. Pages of transcribed deposition testimony or exhibits to
6 depositions that reveal Protected Material must 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.
(f)

the author or recipient of a document containing the information or

a custodian or other person who otherwise possessed or knew the information.
(g)

any mediator or settlement officer, and their supporting personnel,

mutually agreed upon by any of the parties engaged in settlement discussions.
8.

PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
IN OTHER LITIGATION
If a Party is served with a subpoena or a court order issued in other litigation

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

notification shall include a copy of the subpoena or court order;

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(b) promptly notify in writing the party who caused the subpoena or

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order 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 Protective Order. Such notification shall

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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 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
action as “CONFIDENTIAL” before a determination by the court from which the
subpoena or order issued, unless the Party has obtained the Designating Party’s

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STIPULATED PROTECTIVE ORDER

1 permission. The Designating Party shall bear the burden and expense of seeking
2 protection in that court of its confidential material – and nothing in these provisions
3 should be construed as authorizing or encouraging a Receiving Party in this action
4 to disobey a lawful directive from another court.
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A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
PRODUCED IN THIS LITIGATION
(a)

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produced

The terms of this Order are applicable to information

by

a

Non-Party

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

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the Non-Party’s confidential information, then the Party shall:

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(1)

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

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confidentiality agreement with a Non-Party;

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(2)

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Protective Order in this litigation, 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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Non-Party.

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

make the information requested available for inspection by the
(c)

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promptly notify in writing the Requesting Party and the Non-

If the Non-Party fails to object or 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 the Non-Party timely
seeks a protective order, the Receiving Party shall not produce any

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STIPULATED PROTECTIVE ORDER

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information in its possession or control that is subject to the confidentiality

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agreement with the Non-Party before a determination by the court. Absent a

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court order to the contrary, the Non-Party shall bear the burden and expense

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of seeking protection in this court of its Protected Material.

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UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

7 Protected Material to any person or in any circumstance not authorized under this
Stipulated Protective Order, the Receiving Party must immediately (a) notify in
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writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
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to retrieve all unauthorized copies of the Protected Material, (c) inform the person
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or persons to whom unauthorized disclosures were made of all the terms of this
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Order, and (d) request such person or persons to execute the “Acknowledgment and
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Agreement to Be Bound” that is attached hereto as Exhibit A.
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11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
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
24 to the court.
25 12. MISCELLANEOUS
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12.1 Right to Further Relief. Nothing in this Order abridges the right of
any 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.
12.3 Filing Protected Material. Without written permission from the
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Designating Party or a court order secured after appropriate notice to all interested
persons for pleadings or documents filed in connection with a dispositive motion (see
Dkt. 8 (Sect. 4)), a Party may not file in the public record in this action any Protected
Material. 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 under seal pursuant
to a court order authorizing the sealing of the specific Protected Material at issue.
Pursuant to Civil Local Rule 79-5, a sealing order will issue only upon a request
establishing that the Protected Material at issue is privileged, protectable as a trade

14 secret, or otherwise entitled to protection under the law. If a Receiving Party's request
15 to file Protected Material under seal pursuant to Civil Local Rule 79-5.2.2 is denied
16 by the court, then the Receiving Party may file the information in the public record
17 pursuant to Civil Local Rule 79-5.2.2(b)(ii) unless otherwise instructed by the Court.
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12.4

The Parties shall meet and confer regarding the procedures for use

19 of any Confidential Materials at trial and shall move the Court for entry of an
20 appropriate order.
21 13.

FINAL DISPOSITION

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Within 60 days after the final disposition of this action, as defined in

23 paragraph 4, each Receiving Party must return all Protected Material to the
24 Producing Party or destroy such material. As used in this subdivision, “all Protected
25 Material” includes all copies, abstracts, compilations, summaries, and 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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1 the Designating Party) by the 60 day deadline that (1) identifies (by category, where
2 appropriate) all the Protected Material that was returned or destroyed and (2)
3 affirms that the Receiving Party has not retained any copies, abstracts, compilations,
4 summaries or any other format reproducing or capturing any of the Protected
5 Material. Notwithstanding this provision, Counsel are entitled to retain an archival
6 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
work product, and consultant and expert work product, even if such materials
contain Protected Material. Any such archival copies that contain or constitute
Protected Material remain subject to this Protective Order as set forth in Section 4
(DURATION).

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GOOD CAUSE SHOWN BY THE PARTIES’ STIPULATION, IT IS

14 SO ORDERED.
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DATED: September 25, 2024

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___________________________________
+213('529&$67,//2
UNITED STATES MAGISTRATE JUDGE

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EXHIBIT A

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CONFIDENTIALITY AGREEMENT

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I, ______________________, hereby declare:

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1.

My address is

6 _____________________________________________. My telephone number is
7 (_____) ______-____________.
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2.

I have read in its entirety and understand the Stipulation and

9 Protective Order that was issued by the United States District Court for the Central
10 District of California in the case of Andrew Grant v. Wells Fargo Bank, N.A.,
11 United States District Court, Central District of California, Case No. 2:24-CV12 05628-SPG-PVC. I hereby agree to comply with and to be bound by all the terms
13 of this Stipulation and Protective Order.
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3.

I understand that the Stipulation and Protective Order requires that I

15 not disclose in any manner any information or item that is subject to this
16 Stipulation and Protective Order to any person or entity except in strict compliance
17 with the provisions of this Stipulation and Protective Order.
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4.

I consent to the jurisdiction of the United States District Court for the

19 Central District of California for the purpose of enforcing the terms of this
20 Stipulation and Protective Order, even if such enforcement proceedings occur after
21 termination of this action.
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I declare under penalty of perjury that the foregoing is true and correct.
Executed on _____________, 2024 at _____________________________ .
_________________________________

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