V.N. v. Upland Unified School District et al

Filing 27

ORDER APPROVING STIPULATION FOR PROTECTIVE ORDER by Magistrate Judge Kenly Kiya Kato re Stipulation for Protective Order 26 . (vp)

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2017-01-07 A. JOEL RICHLIN, CA Bar No. 246318
[e-mail]
KIMBERLY A. KLINSPORT, CA Bar No. 259018
[e-mail]
JOHN J. ATALLAH, CA Bar No. 294116
[e-mail]
FOLEY & LARDNER LLP
555 SOUTH FLOWER STREET, SUITE 3500
LOS ANGELES, CA 90071-2411
TEL: [phone]; FAX: [phone]

MARONEL BARAJAS, CA Bar No. 242044
[e-mail]
ANNA RIVERA, CA Bar No. 239601
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[e-mail]
DISABILITY RIGHTS LEGAL CENTER
9 350 SOUTH GRAND AVENUE, SUITE 1520
LOS ANGELES, CALIFORNIA 90071
10 TEL: [phone]; FAX: [phone]
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Attorneys for Plaintiff V.N., a Minor,
12 by and through her Guardian Ad Litem
HECTOR NUÑO
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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA - EASTERN DIVISION
)
)
)
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Plaintiff,
)
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vs.
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UPLAND UNIFIED SCHOOL
)
DISTRICT; DR. NANCY KELLY, in her )
official capacity as Superintendent of
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Upland Unified School District; and
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DOES 1-10, inclusive,
)
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Defendants.
)
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)
)
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V.N., a Minor, by and through her
17 Guardian Ad Litem HECTOR NUÑO,

Case No. 5:16-CV-1958 GHK (KKx)

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PROTECTIVE ORDER

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ORDER GRANTING STIPULATED

[DISCOVERY MATTER REFERRED TO
U.S. MAGISTRATE JUDGE]
Complaint Filed: September 12, 2016
FAC Filed: November 4, 2016
U.S. Magistrate Judge Kenly Kiya Kato
Location:
George E. Brown Jr.
Federal Building and
United States Courthouse
3470 Twelfth Street
Courtroom 3 or 4, 3rd Fl
Riverside, CA 92501-3801

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4835-1854-1118.1

STIPULATED PROTECTIVE ORDER
Case No. 5:16-CV-1958 GHK (KKx)

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1.

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

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or private information for which special protection from public disclosure and from use

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for any purpose other than prosecuting this litigation may be warranted. Accordingly, the

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parties hereby stipulate to and petition the Court to enter the following Stipulated

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

7 protections on all disclosures or responses to discovery and that the protection it affords
8 from public disclosure and use extends only to the limited information or items that are
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entitled to confidential treatment under the applicable legal principles. The parties

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further acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective

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Order does not entitle them to file confidential information under seal; Civil Local Rule

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

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

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B. GOOD CAUSE STATEMENT

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This action is likely to involve certain confidential information related to minors,

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as well as medical information relating to the Plaintiff’s disabilities, and employment and

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personnel records pertaining to Defendants and their employees. Such confidential

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materials and information consist of, among other things, academic records, medical

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records, Section 504 plans, employment records, and personnel records. Accordingly, to

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

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confidentiality of discovery materials, to adequately protect information the parties are

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entitled to keep confidential, to ensure that the parties are permitted reasonably necessary

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

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handling at the end of the litigation, and serve the ends of justice, a protective order for

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such information is justified in this matter. It is the intent of the parties that information

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will not be designated as confidential for tactical reasons and that nothing be so

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designated without a good faith belief that it has been maintained in a confidential, non-

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public manner, and there is good cause why it should not be part of the public record of

4835-1854-1118.1

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STIPULATED PROTECTIVE ORDER
Case No. 5:16-CV-1958 GHK (KKx)

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this case.

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2.

DEFINITIONS

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2.1

Action: This pending federal law suit.

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2.2

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

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information or items under this Order.
2.3

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

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

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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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support staff).
2.5

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

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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, among

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

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disclosures or responses to discovery in this matter.
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 does not include Outside Counsel of Record or any other outside counsel.
2.9

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

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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 has

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appeared on behalf of that party, and includes support staff.

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STIPULATED PROTECTIVE ORDER
Case No. 5:16-CV-1958 GHK (KKx)

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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 Non-Party that produces Disclosure or

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Discovery Material 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 designated

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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

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The protections conferred by this Stipulation and Order cover not only Protected

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

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

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

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Counsel that might reveal Protected Material.
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 in

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

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

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and (2) final judgment herein after the completion and exhaustion of all appeals,

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

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STIPULATED PROTECTIVE ORDER
Case No. 5:16-CV-1958 GHK (KKx)

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

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5.

DESIGNATING PROTECTED MATERIAL

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5.1

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

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Party or Non-Party that designates information or items for protection under this Order

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

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appropriate standards. The Designating Party must designate for protection only those

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parts of material, documents, items, or oral or written communications that qualify so that

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other portions of the material, documents, items, or communications for which protection

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is not warranted are not swept unjustifiably within the ambit of this Order.
Mass, indiscriminate, or routinized designations are prohibited. Designations that

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to unnecessarily encumber the case development process or to impose unnecessary

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expenses and burdens on other parties) may expose the 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 inapplicable designation.
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Manner and Timing of Designations. Except as otherwise provided in this

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Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or

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

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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, but

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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 Party

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

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STIPULATED PROTECTIVE ORDER
Case No. 5:16-CV-1958 GHK (KKx)

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

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

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

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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 portions

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

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

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that contains Protected Material. If only a portion or portions of the material on a page

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qualifies for protection, the Producing Party also must clearly identify the protected

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portion(s) (e.g., by making 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 of

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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 protection,

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the Producing Party, to the extent practicable, shall identify the protected portion(s).
5.3

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Inadvertent Failures to Designate. If timely corrected, an inadvertent failure

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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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6.1

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

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

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4835-1854-1118.1

6.2

Meet and Confer. The Challenging Party shall initiate the dispute resolution
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STIPULATED PROTECTIVE ORDER
Case No. 5:16-CV-1958 GHK (KKx)

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process under Local Rule 37.1, et 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 the

5 Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn
6 the confidentiality designation, all parties shall continue to afford the material in question
7 the level of protection to which it is entitled under the Producing Party’s designation until
8 the Court rules on the challenge.
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7.

ACCESS TO AND USE OF PROTECTED MATERIAL

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7.1

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

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

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

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Material may be disclosed only to the categories of persons and under the conditions

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described in this Order. When the Action has been terminated, a Receiving Party must

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comply with the provisions 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 Party

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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

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23 employees of said Outside Counsel of Record to whom it is reasonably necessary to
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(b) the officers, directors, and employees (including House Counsel) of the

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26 Receiving Party to whom disclosure is reasonably necessary for this Action;

(c) Experts (as defined in this Order) of the Receiving Party who have signed the

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

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STIPULATED PROTECTIVE ORDER
Case No. 5:16-CV-1958 GHK (KKx)

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(d) the court and its 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 Vendors to

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whom disclosure is reasonably necessary for this Action and who have signed the

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

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

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

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the witness sign the form attached as Exhibit A hereto; and (2) they will not be permitted

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to keep any confidential information unless they sign the “Acknowledgment and

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Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party

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or ordered by the court. Pages of transcribed deposition testimony or exhibits to

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depositions that reveal Protected Material may be separately bound by the court reporter

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

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Order; and
(i) any mediator or settlement officer, and their supporting personnel, mutually

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

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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

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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;

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

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

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

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STIPULATED PROTECTIVE ORDER
Case No. 5:16-CV-1958 GHK (KKx)

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

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

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5 subpoena or court order shall not produce any information designated in this action as
6 “CONFIDENTIAL” before a determination by the court from which the subpoena or
7 order issued, unless the Party has obtained the Designating Party’s permission. The
8 Designating Party shall bear the burden and expense of seeking protection in that court of
9 its confidential material and nothing in these provisions should be construed as
10 authorizing or encouraging a Receiving Party in this Action to disobey a lawful directive
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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

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in this Action and designated as “CONFIDENTIAL.” Such information produced by

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Non-Parties in connection with this litigation is protected by the remedies and relief

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provided by this Order. Nothing in these provisions should be construed as prohibiting a

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

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

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agreement with the Non-Party not to produce the Non-Party’s confidential information,

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then the Party shall:

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(1) promptly notify in writing the Requesting Party and the Non-Party that some

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or all of the information requested is subject to a confidentiality agreement with a Non-

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

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in this Action, the relevant discovery request(s), and a reasonably specific description of

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the information requested; and

4835-1854-1118.1

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STIPULATED PROTECTIVE ORDER
Case No. 5:16-CV-1958 GHK (KKx)

(3) make the information requested available for inspection by the Non-Party, if

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requested.

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

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of receiving the notice and accompanying information, the Receiving Party may produce

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the Non-Party’s confidential information responsive to the discovery request. If the Non-

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

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

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

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

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court of its Protected Material.

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10.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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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) request

18 such person or persons to execute the “Acknowledgment and Agreement to Be Bound”
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11.

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INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

PROTECTED MATERIAL
When a Producing Party gives notice to Receiving Parties that certain inadvertently

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

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the Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B).

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This provision is not intended to modify whatever procedure may be established in an e-

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discovery order that provides for production without prior privilege review. Pursuant to

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Federal Rule of Evidence 502(d) and (e), insofar as the parties reach an agreement on the

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effect of disclosure of a communication or information covered by the attorney-client

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STIPULATED PROTECTIVE ORDER
Case No. 5:16-CV-1958 GHK (KKx)

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privilege or work product protection, the parties may incorporate their agreement in the

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stipulated protective order submitted to the court.

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12.

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12.1 Right to Further Relief. Nothing in this Order abridges the right of any

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MISCELLANEOUS

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

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Protective Order no Party waives any right it otherwise would have to object to disclosing

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or producing any information or item on any ground not addressed in this Stipulated

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

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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

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

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under seal pursuant to a court order authorizing the sealing of the specific Protected

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Material at issue. If a Party’s request to file Protected Material under seal is denied by

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the court, then the Receiving Party may file the information in the public record unless

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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 days

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

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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 Material.

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Whether the Protected Material is returned or destroyed, the Receiving Party must submit

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a written certification to the Producing Party (and, if not the same person or entity, to the

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Designating Party) by the 60 day deadline that (1) identifies (by category, where

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

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

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

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STIPULATED PROTECTIVE ORDER
Case No. 5:16-CV-1958 GHK (KKx)

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Notwithstanding this provision, Counsel are entitled to retain an archival copy of all

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pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda,

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correspondence, deposition and trial exhibits, expert reports, attorney work product, and

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consultant and expert work product, even if such materials contain Protected Material.

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Any such archival copies that contain or constitute Protected Material remain subject to

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this Protective Order as set forth in Section 4 (DURATION).
14.

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

measures including, without limitation, contempt proceedings and/or monetary sanctions.

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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

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DATED: January 6, 2017

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FOLEY & LARDNER LLP
A. Joel Richlin
Kimberly A. Klinsport
John J. Atallah
/S/ A. JOEL RICHLIN
A. Joel Richlin
Attorneys for Plaintiff V.N., a Minor,
by and through her Guardian Ad Litem
HECTOR NUÑO

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DATED: January 6, 2017

POLLAK, VIDA & FISHER
Judy L. McKelvey

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/S/ JUDY L. McKELVEY
Judy L. McKelvey
Attorneys for Defendants Upland Unified
School District and Nancy Kelley, Ed.D.

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25 *Pursuant to Local Rule 5-4.3.4(a)(2)(i), I (A. Joel Richlin) attest that the other
26 signatories listed, and on whose behalf this filing is submitted, concur in the filing
27 content and have authorized this filing.
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STIPULATED PROTECTIVE ORDER
Case No. 5:16-CV-1958 GHK (KKx)

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FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

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Dated: January 9, 2017

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_____________________________________
HONORABLE KENLY KIYA KATO
UNITED STATES MAGISTRATE JUDGE

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STIPULATED PROTECTIVE ORDER
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EXHIBIT A

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ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

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I, _____________________________ [print or type full name], of

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_________________ [print or type full address], declare under penalty of perjury that I

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have read in its entirety and understand the Stipulated Protective Order that was issued by

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

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[date] in the case of V.N. v. Upland Unified School District, et al., Case No. 5:16-CV-

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1958 GHK (KKx). I agree to comply with and to be bound by all the terms of this

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Stipulated Protective Order and I understand and acknowledge that failure to so comply

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could expose me to sanctions and punishment in the nature of contempt. I solemnly

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promise that I will not disclose in any manner any information or item that is subject to

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this Stipulated Protective Order to any person or entity except in strict compliance with

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

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

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Protective Order, even if such enforcement proceedings occur after termination of this

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action. I hereby appoint __________________________ [print or type full name] of

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_______________________________________ [print or type full address and telephone

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number] as my California agent for service of process in connection with this action or

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any proceedings related to enforcement of this Stipulated Protective Order.

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Date: ______________________________________

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City and State where sworn and signed: _________________________________

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Printed name: _______________________________

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Signature: __________________________________

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STIPULATED PROTECTIVE ORDER
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