Richard Sinohui v. CEC Entertainment, Inc.

Filing 29

STIPULATED PROTECTIVE ORDER by Magistrate Judge Kenly Kiya Kato re Stipulation for Protective Order 28 . See Order for Details. (vp)

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GARY M. MCLAUGHLIN (SBN 217832)
CHRISTOPHER K. PETERSEN (SBN 260631)
JONATHAN S. CHRISTIE (SBN 294446)
[e-mail]
[e-mail]
[e-mail]
AKIN GUMP STRAUSS HAUER & FELD LLP
2029 Century Park East, Suite 2400
Los Angeles, CA 90067-3010
Telephone: [phone]
Facsimile: 310.229.1001
Attorneys for Defendant,
CEC ENTERTAINMENT, INC.

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA - SOUTHERN DIVISION

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RICHARD SINOHUI, on behalf of
himself and all others similarly
situated,

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Plaintiffs,
v.
CEC ENTERTAINMENT, INC., a
Kansas corporation; and DOES 1
through 100, inclusive,
Defendants.

Case No. 5:14-cv-02516-JLS (KKx)
[Assigned to Hon. Josephine L. Staton]
DISCOVERY MATTER
[PROPOSED] STIPULATED
PROTECTIVE ORDER

Date Action Filed: October 10, 2014
Date of Removal: December 5, 2014

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[PROPOSED] STIPULATED PROTECTIVE ORDER

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The parties represent that this Stipulated Protective Order is identical in all
material respects to the exemplar Form Protective Order provided online by Magistrate
Judge Kenly Kiya Kato, with the exception of the additional language highlighted in
Sections 3, 4, and 6 below.
I.

A. 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 Stipulated
Protective Order. The parties acknowledge that this Order does not confer blanket
protections on all disclosures or responses to discovery and that the protection it affords
from public disclosure and use extends only to the limited information or items that are
entitled to confidential treatment under the applicable legal principles. The parties
further acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective
Order does not entitle them to file confidential information under seal; Civil Local Rule
79-5 sets forth the procedures that must be followed and the standards that will be
applied when a party seeks permission from the court to file material under seal.
B. GOOD CAUSE STATEMENT
This action is likely to involve personal and confidential information regarding the
putative class and/or proprietary business information for which special protection from
public disclosure and from use for any purpose other than prosecution of this action is
warranted. Such confidential and proprietary materials and information consist of,
among other things, confidential personal, business, and financial information,
information regarding confidential company policies and practices, or other confidential
research, development, or commercial information (including information implicating
privacy rights of third parties), information otherwise generally unavailable to the
public, or which may be privileged or otherwise protected from disclosure under state or

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federal statutes, court rules, case decisions, or common law. Accordingly, to expedite
the flow of information, to facilitate the prompt resolution of disputes over
confidentiality of discovery materials, to adequately protect information the parties are
entitled to keep confidential, to ensure that the parties are permitted reasonable
necessary uses of such material in preparation for and in the conduct of trial, to address
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 without a good faith belief that it has been maintained in a confidential,
non-public manner, and there is good cause why it should not be part of the public
record of this case.
II.

DEFINITIONS
2.1

Action: The pending lawsuit, Sinohui v. CEC Entertainment, Inc., Case No.

5:14-cv-02516-JLS (KKx), originally filed in Los Angeles Superior Court as Case No.
MCC1401546.
2.2

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

information or items under this Order.
2.3

“CONFIDENTIAL” Information or Items: information (regardless of how

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

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

support staff).
2.5

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

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

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 disclosures or responses to discovery in this matter.
2.7

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

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.
2.8

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.
2.9

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

other legal entity not named as a Party to this action.
2.10 Outside Counsel of Record: attorneys who are not employees of a party to
this Action but are retained to represent or advise a party to this Action and have
appeared in this Action on behalf of that party or are affiliated with a law firm which has
appeared on behalf of that party, and includes support staff.
2.11 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).
2.12 Producing Party: a Party or Non-Party that produces Disclosure or
Discovery Material in this Action.
2.13 Professional Vendors: persons or entities that provide litigation support
services (e.g., photocopying, videotaping, translating, preparing exhibits or
demonstrations, and organizing, storing, or retrieving data in any form or medium) and
their employees and subcontractors.
2.14 Protected Material: any Disclosure or Discovery Material that is designated
as “CONFIDENTIAL.”
2.15 Receiving Party: a Party that receives Disclosure or Discovery Material
from a Producing Party.

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III.

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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
Material; and (3) any testimony, conversations, or presentations by Parties or their
Counsel that might reveal Protected Material.

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SCOPE

While the parties must exercise restraint, a Designating Party has the right to
designate as “CONFIDENTIAL” any material that the Designating Party in good faith
believes to contain non-public information that is entitled to confidential treatment under
applicable law, specifically including, but not limited to, any employee payroll data,
employee personnel data and/or contact information, or CEC Entertainment, Inc.’s
internal policies, practices, or strategies. 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.
IV.

DURATION
Once a case proceeds to trial, all of the information to be introduced that was

previously designated as confidential or maintained pursuant to this protective order
becomes public and will be presumptively available to all members of the public,
including the press, unless compelling reasons supported by specific factual findings to
proceed otherwise are made to the trial judge in advance of the trial. See Kamakana v.
City and County of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing
“good cause” showing for sealing documents produced in discovery from “compelling
reasons” standard when merits-related documents are part of court record). Accordingly,
the terms of this protective order do not extend beyond the commencement of the trial
with respect to Protected Material used at trial. With respect to all other Protected
Material, however, even after final disposition of this litigation, the confidentiality
obligations imposed by this Order shall remain in effect until a Designating Party agrees

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otherwise in writing or a court order otherwise directs.
V.

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.
Designation in conformity with this Order requires:
(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, the legend
“CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that contains
protected material. If only a portion or portions of the material on a page qualifies for

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protection, the Producing Party also must clearly identify the protected portion(s) (e.g.,
by making appropriate markings in the margins).
A Party or Non-Party that makes original documents available for inspection need
not designate them for protection until after the 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
“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 affix the “CONFIDENTIAL 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
portion(s) (e.g., by making appropriate markings in the margins).

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(b) for testimony given in depositions that the Designating Party identify
the Disclosure or Discovery Material on the record, before the close of the deposition.

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(c) for information produced in some form other than documentary and for
any other tangible items, that the Producing Party affix in a prominent place on the
exterior of the container or containers in which the information is stored the legend
“CONFIDENTIAL.” If only a portion or portions of the information warrants
protection, the Producing Party, to the extent practicable, shall identify the protected
portion(s).
5.3

Inadvertent Failures to Designate. If timely corrected, an inadvertent

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

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VI.

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, with the exception of Personal Contact Information, as explained below. Any
contact information of CEC Entertainment, Inc.’s current or former employees that CEC
Entertainment, Inc. produces at any time during the course of, or in connection with this
litigation (“Personal Contact Information”), shall be deemed Confidential, whether or
not stamped or marked as confidential. Any Personal Contact Information shall be used
by Richard Sinohui and his counsel solely for the purpose of investigating, prosecuting,
and/or settlement of this litigation.
6.2

Meet and Confer. The Challenging Party shall initiate the dispute

resolution process under Local Rule 37.1 et seq. Any discovery motion must strictly
comply with the procedures set forth in Local Rules 37-1, 37-2, and 37-3.
6.3

Burden. 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 Challenging Party to sanctions. Unless the Designating Party has
waived or withdrawn the confidentiality designation, all parties shall 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.
VII. 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 Protected
Material may be disclosed only to the categories of persons and under the conditions
described in this Order. When the Action has been terminated, a Receiving 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
location and in a secure manner that ensures that access is limited to the persons
authorized under this Order.
7.2

Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise

ordered by the court or permitted in writing by the Designating Party, a Receiving Party
may disclose any information or item designated “CONFIDENTIAL” only to:
(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;
(b) the officers, directors, and employees (including House Counsel) of the
Receiving Party to whom disclosure is reasonably 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 have signed the
“Acknowledgment and Agreement to Be Bound” (Exhibit A);
(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
Action to whom disclosure is reasonably necessary provided: (1) the deposing party
requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will not
be permitted to keep any confidential information unless they sign the
“Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed
by the Designating Party or ordered by the court. Pages of transcribed deposition

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testimony or exhibits to depositions that reveal Protected Material may be separately
bound by the court reporter and may not be disclosed to anyone except as permitted
under this Stipulated Protective Order;
(i) any mediator or settlement officer, and their supporting personnel,
mutually agreed upon by any of the parties engaged in settlement discussions; and
(j) any class action administrators and/or their supporting staff, including
their use and/or dissemination of such confidential materials to third parties and/or class
members if requested to do so by both parties as part of this action.
VIII. 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 that
compels disclosure of any information or items designated in this Action as
“CONFIDENTIAL,” that Party must:
(a) promptly notify in writing the Designating Party. Such notification shall
include a copy of the subpoena or court order;
(b) promptly notify in writing the party who caused the subpoena or order
to issue in the other litigation that some or all of the material covered by the subpoena or
order is subject to this Protective Order. Such notification shall include a copy of this
Stipulated Protective Order; and
(c) cooperate with respect to all reasonable procedures sought to be pursued
by the Designating Party whose Protected Material may be affected.
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” before a determination by the court from which the subpoena or
order issued, unless the Party has obtained the Designating Party’s permission. The
Designating Party shall bear the burden and expense of seeking protection in that court
of its confidential material and nothing in these provisions should be construed as

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authorizing or encouraging a Receiving Party in this Action to disobey a lawful directive
from another court.
IX.

A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
PRODUCED IN THIS LITIGATION
(a) The terms of this Order are applicable to information produced 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 the Non-Party’s confidential
information, then the Party shall:
(1) promptly notify in writing the Requesting Party and the NonParty that some or all of the information requested is subject to a confidentiality
agreement with a Non-Party;
(2) promptly provide the Non-Party with a copy of the Stipulated
Protective Order in this Action, the relevant discovery request(s), and a reasonably
specific description of the information requested; and
(3) make the information requested available for inspection by the
Non-Party, if requested.
(c) 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
the Non-Party timely seeks a protective order, the Receiving Party shall not produce any
information in its possession or control that is subject to the confidentiality agreement
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
court of its Protected Material.
X.

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UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed

Protected Material to any person or in any circumstance not authorized under this
Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing
the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve
all unauthorized copies of the Protected Material, (c) inform the person or persons to
whom unauthorized disclosures were made of all the terms of this Order, and (d) request
such person or persons to execute the “Acknowledgment and Agreement to Be Bound”
that is attached hereto as Exhibit A.
XI.

INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
PROTECTED MATERIAL
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
obligations of the Receiving Parties are those set forth in Federal Rule of Civil
Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
may be established in an e-discovery order that provides for production without prior
privilege 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 agreement in the stipulated protective order submitted to the court.
XII. MISCELLANEOUS
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.
12.2 Right to Assert Other Objections. By stipulating to the entry of this
Protective Order no Party waives any right it otherwise would have to object to

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disclosing or producing any information or item on any ground not addressed in this
Stipulated Protective Order. Similarly, no Party waives any right to object on any
ground to use in evidence of any of the material covered by this Protective Order.
12.3 Filing 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. If a Party's request to file Protected Material under seal is
denied by the court, then the Receiving Party may file the information in the public
record unless otherwise instructed by the court.
XIII. FINAL DISPOSITION
After the final disposition of this Action, within 60 days of a written request by the
Designating Party, each Receiving Party must return all Protected Material to the
Producing Party or destroy such material. As used in this subdivision, “all Protected
Material” includes all copies, abstracts, compilations, summaries, and any other format
reproducing or capturing any of the Protected Material. Whether the Protected Material
is returned or destroyed, the Receiving Party must submit a written certification to the
Producing Party (and, if not the same person or entity, to the Designating Party) by the
60 day deadline that (1) identifies (by category, where appropriate) all the Protected
Material that was returned or destroyed and (2) affirms that the Receiving Party has not
retained any copies, abstracts, compilations, summaries or any other format reproducing
or capturing any of the Protected Material. Notwithstanding this provision, Counsel are
entitled to retain an archival copy of all pleadings, motion papers, trial, deposition, and
hearing transcripts, legal memoranda, correspondence, deposition and trial exhibits,
expert reports, attorney work product, and consultant and expert work product, even if
such materials 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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14.

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

including, without limitation, contempt proceedings and/or monetary sanctions.
IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

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Dated: May 13, 2015

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AKIN GUMP STRAUSS HAUER &
FELD LLP
GARY M. MCLAUGHLIN1
CHRISTOPHER K. PETERSEN
JONATHAN S. CHRISTIE
By

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Dated: May 13, 2015

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TRUSH LAW OFFICE, APC
JAMES M. TRUSH
By

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Dated: May 13, 2015

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/s/ James M. Trush
James M. Trush
Attorneys for Plaintiff
Richard Sinohui

PERONA LANGER BECK SERBIN
MENDOZA, APC
TODD H. HARRISON
BRENNAN S. KAHN
By

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/s/ Gary M. McLaughlin
Gary M. McLaughlin
Attorneys for Defendant,
CEC ENTERTAINMENT, INC.

/s/ Todd H. Harrison
Todd H. Harrison
Attorneys for Plaintiff
Richard Sinohui

FOR GOOD CAUSE SHOWN, IT IS ORDERED.
Dated: May 15, 2015

By

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Hon. Kenly Kiya Kato
United States Magistrate Judge

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Pursuant to Local Rule 5-4.3.4(a)(2), the filing party has obtained the
authorization and approval of all signatories listed to file this stipulation.
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EXHIBIT A
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
I, _____________________________ [print or type full name], of
______________________________ [print or type 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 Sinohui v. CEC Entertainment, Inc., Case No. 5:14-cv-02516JLS (KKx). 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 __________________________ [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.
Date: __________________
City and State where sworn and signed: __________________

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Printed name: __________________

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Signature: __________________

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[PROPOSED] STIPULATED PROTECTIVE ORDER

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PROOF OF SERVICE
STATE OF CALIFORNIA, COUNTY OF LOS ANGELES
I am employed in the County of Los Angeles, State of California. I am over the
age of 18 and not a party to the within action; my business address is: 2029 Century
Park East, Suite 2400, Los Angeles, California 90067. On May 15, 2015, I served the
foregoing document(s) described as:
[PROPOSED] STIPULATED PROTECTIVE ORDER
on the interested party(ies) below, using the following means:
All parties identified for Notice of Electronic Filing
generated by the Court’s CM/ECF system under the
referenced case caption and number
BY ELECTRONIC MAIL OR ELECTRONIC TRANSMISSION. Based on a court order or an agreement of the
parties to accept service by e-mail or electronic transmission, I caused the document(s)
to be sent to the respective e-mail address(es) of the party(ies) as stated above. I did not
receive, within a reasonable time after the transmission, any electronic message or other
indication that the transmission was unsuccessful.
(FEDERAL) I declare that I am employed in the office of a member of the bar of this
court at whose direction the service was made.

Executed on May 15, 2015 at Los Angeles, California.

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Rebecca McNew
[Print Name of Person Executing Proof]

[Signature]

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PROOF OF SERVICE