Isiah Washington v. Sierra Aluminum Company et al

Filing 43

STIPULATED PROTECTIVE ORDER by Magistrate Judge Sheri Pym (SEE ORDER FOR DETAILS). (kca)

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Lisa Bloom, Esq. (SBN: 158458)
Jivaka Candappa, Esq. (SBN 225919)
Alyson Decker, Esq. (SBN: 252384)
THE BLOOM FIRM
20700 Ventura Blvd., Suite 301
Woodland Hills, CA 91364
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
[e-mail]
Attorneys for Plaintiff
ISIAH WASHINGTON

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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12 ISIAH WASHINGTON, an individual,
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Plaintiff,

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v.

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SIERRA ALUMINUM COMPANY;
16 MANUEL HERNANDEZ, an
17 individual, GUADALUPE SANTOS
SANCHEZ, an individual, and DOES 2
18 through 10, inclusive,
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Defendants.

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DISCOVERY MATTER
CASE NO.: 5:16-cv-00298-DMG (SPx)
STIPULATED PROTECTIVE ORDER
HON. SHERI PYM
Discovery Cut-Off: July 3, 2017
Pre-Trial Conference: October 10, 2017
Trial Date: November 7, 2017

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1. INTRODUCTION

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1.1

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

PURPOSES AND LIMITATIONS

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proprietary, or private information for which special protection from public disclosure

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and from use for any purpose other than prosecuting this litigation may be warranted.

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Accordingly, the parties hereby stipulate to and petition the Court to enter the

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following Stipulated Protective Order. The parties acknowledge that this Order does
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not confer blanket protections on all disclosures or responses to discovery and that the

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protection it affords from public disclosure and use extends only to the limited

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information or items that are entitled to confidential treatment under the applicable

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legal principles. The parties further acknowledge, as set forth in Section 12.3, below,

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that this Stipulated Protective Order does not entitle them to file confidential

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

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followed and the standards that will be applied when a party seeks permission from the

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court to file material under seal.
1.2

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GOOD CAUSE STATEMENT

This action is likely to involve the discovery and disclosure of private

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information relating to the Plaintiff, the Defendants, various employees of Defendant

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SIERRA ALUMINUM COMPANY (“Sierra Aluminum”), and other Third-Parties.

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For instance, Plaintiff has served subpoenas on two Third-Party workforce

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management companies seeking documents relating to all candidates or applicants

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referred by such companies to Sierra Aluminum, including background checks and

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documents identifying criminal convictions of the Third-Parties. Such documents and

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information are protected under the privacy rights of the various Third-Parties

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applicants and employees. See, e.g., Gehring v. Case Corp., 43 F.3d 340, 342–43 (7th

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Cir.1994); Miller v. Federal Express Corp., 186 F.R.D. 376, 384 (W.D. Tenn. 1999).

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Similarly, Defendant seeks the mental examination of the Plaintiff pursuant to Rule 35

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of the Federal Rules of Civil Procedure.

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To protect the privacy interests of both Parties and Third-Parties, to expedite the

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flow of information, to facilitate the prompt resolution of disputes over confidentiality

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of discovery materials, to adequately protect the confidential information the Parties

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and Third-Parties, to ensure that the parties are permitted reasonable necessary use of

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

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such documents at the end of the litigation, and to serve the ends of justice, a

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protective order for such information is justified in this matter. It is the intent of the
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Parties that information will not be designated as confidential for tactical reasons and

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that nothing be so designated without a good faith belief that it has been maintained in

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a confidential, non-public manner, and there is good cause why it should not be part of

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the public record of this case.

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2. DEFINITIONS

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2.1

Action: This above-captioned pending federal law suit.

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2.2

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

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of information or items under this Order.
2.3

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

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

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under Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause

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Statement.
2.4

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

support staff).
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Designating Party: a Party or Third-Party that designates information or

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items that it produces in disclosures or in responses to discovery as

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“CONFIDENTIAL.”
2.6

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

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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 or

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generated in disclosures or responses to discovery in this matter.
2.7

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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 an

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expert witness or as a consultant in this Action.
2.8

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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

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Third-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

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this Action but are retained to represent or advise a party to this Action and have

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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, and includes support staff
2.11 Party: any party to this Action, including all of its officers, directors,

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employees, consultants, retained experts, and Outside Counsel of Record (and their

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support staffs).
2.12 Producing Party: a Party or Third-Party that produces Disclosure or

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

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

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

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their employees and subcontractors.
2.14 Protected Material: any Disclosure or Discovery Material that is

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designated as “CONFIDENTIAL.”
2.15 Receiving Party: a Party that receives Disclosure or Discovery Material

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from a Producing Party.

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3. SCOPE
The protections conferred by this Stipulation and Order cover not only

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Protected Material (as defined above), but also (1) any information copied or extracted

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from Protected Material; (2) all copies, excerpts, summaries, or compilations of

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

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their Counsel that might reveal Protected Material.
Any use of Protected Material at trial shall be governed by the orders of the trial

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

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Even after final disposition of this litigation, the confidentiality obligations

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

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

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the later of (1) dismissal of all claims and defenses in this Action, with or without

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prejudice; and (2) final judgment herein after the completion and exhaustion of all

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appeals, rehearings, remands, trials, or reviews of this Action, including the time limits

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for filing any motions or applications for extension of time pursuant to applicable law.

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5. DESIGNATING PROTECTED MATERIAL
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Exercise of Restraint and Care in Designating Material for Protection.

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Each Party or Third-Party that designates information or items for protection under this

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Order must take care to limit any such designation to specific material that qualifies

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under the appropriate standards. The Designating Party must designate for protection

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only those parts of material, documents, items, or oral or written communications that

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qualify so that other portions of the material, documents, items, or communications for

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which protection is not warranted are not swept unjustifiably within the ambit of this

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Order.
Mass, indiscriminate, or routinized designations are prohibited. Designations

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that are shown to be clearly unjustified or that have been made for an improper

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purpose (e.g., to unnecessarily encumber the case development process or to impose

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unnecessary expenses and burdens on other parties) may expose the Designating

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Party to sanctions.
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, which Designating Party must

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promptly notify all other Parties that it is withdrawing the inapplicable designation.
5.2

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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
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or ordered, Disclosure or Discovery Material that qualifies for protection under this

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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,

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but excluding transcripts of depositions or other pretrial or trial proceedings), that the

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Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter

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“CONFIDENTIAL legend”), to each page that contains protected material. If only a

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portion or portions of the material on a page qualifies for protection, the Producing

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Party also must clearly identify the protected portion(s) (e.g., by making appropriate

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markings in the margins).

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A Party or Non-Party that makes original documents available for inspection

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need not designate them for protection until after the inspecting Party has indicated

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which documents it would like copied and produced. During the inspection and before

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the designation, all of the material made available for inspection shall be deemed

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“CONFIDENTIAL.” After the inspecting Party has identified the documents it wants

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copied and produced, the Producing Party must determine which documents, or

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portions thereof, qualify for protection under this Order. Then, before producing the

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specified documents, the Producing Party must affix the “CONFIDENTIAL legend” to

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each page that contains Protected Material.
If only a portion or portions of the material on a page qualifies for protection,

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the Producing Party also must clearly identify the protected portion(s) (e.g., by making

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appropriate markings in the margins).
(b) for testimony given in depositions that the Designating Party identify the

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Disclosure or Discovery Material on the record, before the close of the deposition all

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protected testimony.
(c) for information produced in some form other than documentary and for any

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

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of the container or containers in which the information is stored the legend
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“CONFIDENTIAL.” If only a portion or portions of the information warrants

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protection, the Producing Party, to the extent practicable, shall identify the protected

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portion(s).
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Inadvertent Failures to Designate. If timely corrected, an inadvertent

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failure to designate qualified information or items does not, standing alone, waive the

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Designating Party’s right to secure protection under this Order for such material. Upon

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timely correction of a designation, the Receiving Party must make reasonable efforts to

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assure that the material is treated in accordance with the provisions of this Order.

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6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
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Timing of Challenges. Any Party or Third-Party may challenge a

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

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Order.
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Meet and Confer. The Challenging Party shall initiate the dispute

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

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seq.
6.3

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

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Designating Party. Frivolous challenges, and those made for an improper purpose (e.g.,

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to harass or impose unnecessary expenses and burdens on other parties) may expose

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

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withdrawn the confidentiality designation, all parties shall continue to afford the

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material in question the level of protection to which it is entitled under the Producing

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Party’s designation until the Court rules on the challenge.

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7. ACCESS TO AND USE OF PROTECTED MATERIAL
7.1

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

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disclosed or produced by another Party or by a Third-Party in connection with this

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

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conditions prescribed in this Order. When the Action has been terminated, a Receiving

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Party must comply with the provision of section 13 below (FINAL DISPOSITION).
Protected Material must be stored and maintained by a Receiving Party at a

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location and in a secure manner that ensures that access is limited to the persons

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authorized under this Order.
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Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise

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

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Party may disclose any information or item designated “CONFIDENTIAL” only to:

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(a) the Receiving Party’s Outside Counsel of Record in this Action, as well as

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employees of said Outside Counsel of Record to whom it is reasonably necessary to

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disclose the information for this Action;
(b) the officers, directors, and employees (including House Counsel) of the

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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

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is reasonably necessary for this Action and who have signed the

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

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(d) the Court, the jury, and the Court’s personnel;

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(e) court reporters and their staff;

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(f) professional jury or trial consultants, mock jurors, and Professional

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Vendors to whom disclosure is reasonably necessary for this Action and who have

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signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
(g) the author or recipient of a document containing the information or a

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custodian or other person who otherwise possessed or knew the information;
(h) during their depositions, witnesses ,and attorneys for witnesses, in the

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

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requests that the witness sign the form attached as Exhibit A hereto; and (2) they will

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not be permitted to keep any confidential information unless they sign the
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“Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed

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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

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bound by the court reporter and may not be disclosed to anyone except as permitted

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under this Stipulated Protective Order; and
(i) any mediator or settlement officer, and their supporting personnel,

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

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8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN

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OTHER LITIGATION

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

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

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“CONFIDENTIAL,” that Party must:
(a) promptly notify in writing the Designating Party. Such notification shall

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

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

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order is subject to this Protective Order. Such notification shall include a copy of this

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Stipulated Protective Order; and
(c) cooperate with respect to all reasonable procedures sought to be pursued by

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the Designating Party whose Protected Material may be affected. If the Designating

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Party timely seeks a protective order, the Party served with the subpoena or court order

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shall not produce any information designated in this action as “CONFIDENTIAL”

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before a determination by the court from which the subpoena or order issued, unless

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the Party has obtained the Designating Party’s permission. The Designating Party shall

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bear the burden and expense of seeking protection in that court of its confidential

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

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

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9. A THIRD-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

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PRODUCED IN THIS LITIGATION

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(a) The terms of this Order are applicable to information produced by a

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Third-Party in this Action and designated as “CONFIDENTIAL.” Such information

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produced by Third Parties in connection with this litigation is protected by the

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remedies and relief provided by this Order. Nothing in these provisions should be

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construed as prohibiting a Third-Party from seeking additional protections.
(b) In the event that a Party is required, by a valid discovery request, to produce

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a Third-Party’s confidential information in its possession, and the Party is subject to an

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agreement with the Third-Party not to produce the Third-Party’s confidential

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information, then the Party shall:
(1) promptly notify in writing the Requesting Party and the Third-Party

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

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

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

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specific description of the information requested; and
(3) make the information requested available for inspection by the

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Third-Party, if requested.
(c) If the Third-Party fails to seek a protective order from this court within

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14 days of receiving the notice and accompanying information, the Receiving Party

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may produce the Third-Party’s confidential information responsive to the discovery

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request. If the Third-Party timely seeks a protective order, the Receiving Party shall

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not produce any information in its possession or control that is subject to the

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confidentiality agreement with the Third-Party before a determination by the court.

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Absent a court order to the contrary, the Third-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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10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed

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

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Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing

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the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve

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all unauthorized copies of the Protected Material, (c) inform the person or persons to

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whom unauthorized disclosures were made of all the terms of this Order, and (d)

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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

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PROTECTED MATERIAL

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When a Producing Party gives notice to Receiving Parties that certain

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

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

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

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

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privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the

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parties reach an agreement on the effect of disclosure of a communication or

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information covered by the attorney-client privilege or work product protection, the

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parties may incorporate their agreement in the stipulated protective order submitted to

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the court.

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12. MISCELLANEOUS
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

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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

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

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

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

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

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only be filed under seal pursuant to a court order authorizing the sealing of the

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

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

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in the public record unless otherwise instructed by the court.

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13. FINAL DISPOSITION

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

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days of a written request by the Designating Party, each Receiving Party must return

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

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

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

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Material. Notwithstanding this provision, Counsel are entitled to retain an archival

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

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

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

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Protected Material. Any such archival copies that contain or constitute Protected

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Material remain subject to this Protective Order as set forth in

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Section 4 (DURATION).

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14.

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

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contempt proceedings, financial or evidentiary sanctions, reference to disciplinary
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authorities, or other appropriate action at the discretion of the Court.

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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

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Dated: June 19, 2017

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By:_____________________________________

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THE BLOOM FIRM

Attorneys for Plaintiff
Dated: June 14, 2017

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GIBBS GIDEN LOCHER TURNER
SENET & WITTBRODT LLP

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By:___s/ Gary E. Scalabrini_____________
Gary E. Scalabrini
Attorneys for Plaintiff

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Signature Certification

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Pursuant to Local Rule 5-4.3.4(2)(i), I attest that all other signatories listed, and

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on whose behalf the filing is submitted, concur in the filing’s content and have

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authorized the filing.

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Dated: June 19, 2017

THE BLOOM FIRM

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By:_____________________________________

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Attorneys for Plaintiff

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FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

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DATED: June 19, 2017

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__________________________________
HON. SHERI PYM
United States Magistrate Judge
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EXHIBIT A

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ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

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I, ____________________________________________________ [full name],

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of _______________________________________________________ [full address],
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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 Washington v. Sierra Aluminum
Company, et al., United States District Court Case No. 5:16-cv-00298-DMG (SPx) . I
agree to comply with and to be bound by all the terms of this Stipulated Protective

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

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

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

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

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of this Order.
I further agree to submit to the jurisdiction of the United States District Court for

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

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Stipulated Protective Order, even if such enforcement proceedings occur after

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termination of this action. I hereby appoint __________________________________

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[full name] of _________________________________________________________

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[full address and telephone number] as my California agent for service of process in

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connection with this action or any proceedings related to enforcement of this
Stipulated Protective Order.

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Date: _________________
City and State where signed: _________________________________
Printed name: _____________________________________________
Signature: _________________________________________________

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CERTIFICATE OF SERVICE

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I hereby certify that on June 15, 2017, I electronically filed STIPULATED

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PROTECTIVE ORDER; and this certificate of service using the CM/ECF System
which will send notification of such filing to the following:

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Gary Scalabrini, Esq.
[e-mail]
GIBBS GIDEN LOCHER TURNER SENET & WITTBRODT LLP
Attorneys for Defendant
David Prager, Esq.
[e-mail]
GIBBS GIDEN LOCHER TURNER SENET & WITTBRODT LLP
Attorneys for Defendant
Jerry Griffin, Esq.
[e-mail]
GIBBS GIDEN LOCHER TURNER SENET & WITTBRODT LLP
Attorneys for Defendant

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Robert Wennagel, Esq.
990 Knox Street
Torrance, CA 90502
Attorneys for AppleOne Employment Services

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DATED: June 19, 2017

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/s/ Alyson Decker

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Alyson Decker, Esq.
THE BLOOM FIRM
20700 Ventura Blvd., Suite 301
Woodland Hills, CA 91436
Phone: [phone]
Fax:
[phone]
E-Mail: [e-mail]

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THE
BLOOM FIRM

STIPULATED PROTECTIVE ORDER
1905708.1

CASE NO. 2:16-CV-00298-DMG (SPX)