Andra Jay v. Navient Solutions, Inc. et al

Filing 40

PROTECTIVE ORDER by Magistrate Judge Alicia G. Rosenberg re Stipulation for Protective Order 39 . ***** SEE ORDER FOR DETAILS. ***** (mp)

Case 5~~16-cv-02026-MWF-AGR Document 39 Filed 09/28!17 Page 1 of 14 Page ID #:156

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VEDDER PRICE(CA), LLP
LISA M. SIMONETTI(SB# 165996)
lsimonetti(a~vedderprice.com
CHRISTOPHER R. RAMOS(SB# 301556)
[e-mail]
1925 Century Park East, Suite 1900
Los Angeles, California 90067
T: [phone]
F: [phone]

IT iS SO ORDERED.
DATED: ' I ~ ~ aO ~~
°
G
U NITED STATES MAGISTRATE JUG

Attorneysfor Defendant
Navient Solutions, LLC,
f
ormerly known as Navient Solutions, Inc.

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UNITED STATES DISTRICT COURT
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CENTRAL DISTRICT OF CALIFORNIA
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ANDRA JAY AS EXECUTOR OF
THE ESTATE OF RITA CUTLER,

Case No. 5:16-cv-02026-MWF-AGR

Plaintiff,

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STIPULATED PROTECTIVE
ORDER

v.

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15 ~ NAVIENT SOLUTIONS,INC.,
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Defendant.

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1.

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

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0

proprietary, or private information for which special protection from public

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disclosure and from use for any purpose other than prosecuting this litigation may

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be warranted. Accordingly, the parties hereby stipulate to and petition the Court to

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enter the following Stipulated Protective Order. The parties acknowledge that this

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Order does not confer blanket protections on all disclosures or responses to

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discovery and that the protection it affords from public disclosure and use extends

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only to the limited information or items that are entitled to confidential treatment

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under the applicable legal principles. The parties further acknowledge, as set forth

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in Section 12.3, below, that this Stipulated Protective Order does not entitle them to

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STIPULATED PROTECTIVE ORDER
CASE NO.5:16-CV-02026-MWF-AGR

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file confidential information under seal; Civil Local Rule 79-5 sets forth the

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procedures that must be followed and the standards that will be applied when a

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

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B. GOOD CAUSE STATEIYIENT

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This action is likely to involve commercial, financial, technical and/or

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proprietary information for which special protection from public disclosure and

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from use for any purpose other than prosecution of this action is warranted. Such

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confidential and proprietary materials and information consist of, among other

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things, confidential business or financial information, information regarding

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confidential business practices, or other confidential research, development, or

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commercial information (including information implicating privacy rights of third

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parties), information otherwise generally unavailable to the public, or which may be

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privileged or otherwise protected from disclosure under state or federal statutes,

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court rules, case decisions, or common law. Accordingly, to expedite the flow of

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

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discovery materials, to adequately protect information the parties are entitled to

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keep confidential, to ensure that the parties are permitted reasonable necessary uses

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

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handling at the end ofthe litigation, and serve the ends ofjustice, a protective order

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

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information will not be designated as confidential for tactical reasons and that

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

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

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of the public record of 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

Challen~in~rty: A Party or Non-Party that challenges the

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designation of information or items under this Order.

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2.3

"CONFIDENTIAL" Information or Items: Information (regardless of

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

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

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the Good Cause Statement.

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2.4

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

their support staff.
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Desi gnatin~Party: A Party or Non-Party that designates information

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

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CONFIDENTIAL."
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Disclosure or Discovery Material: All items or information, regardless

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of the medium or manner in which it is generated, stored, or maintained (including,

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among other things, testimony, transcripts, and tangible things), that are produced

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

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Exert: A person with specialized knowledge or experience in a

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matter pertinent to the litigation who has been retained by a Party or its counsel to

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serve as an expert witness or as a consultant in this Action.

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

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Action. House Counsel does not include Outside Counsel of Record or any other

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outside counsel.

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

or other legal entity not named as a Party to this action.
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.10 Outside Counsel of Record: Attorneys who are not employees of a

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

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have appeared in this Action on behalf of that party or are affiliated with a law firm

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

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: 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).

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.12 Producin~rtv: A Party or Non-Party that produces Disclosure or
Discovery Material in this Action.

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.13 Professional Vendors: Persons or entities that provide litigation

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support 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)

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and their employees and subcontractors.

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.14 Protected Material: Any Disclosure or Discovery Material that is
designated as "CONFIDENTIAL."

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.15 Receivin~rty: A Party that receives Disclosure or Discovery

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Material from a Producing Pariy.

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3.

SCOPE

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The protections conferred by this Stipulation and Order cover not only

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

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

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compilations of Protected Material; and(3)any testimony, conversations, or

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presentations by Parties or their Counsel that might reveal Protected Material.

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Any use of Protected Material at trial shall be governed by the orders ofthe

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

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4.

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DURATION
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

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

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deemed to be the later of(1)dismissal of all claims and defenses in this Action,

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with or without prejudice; and (2)final judgment herein after the completion and

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exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action,

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including the time limits for filing any motions or applications for extension of time

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pursuant to applicable law.

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5.

DESIGNATING PROTECTED MATERIAL
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Exercise of Restraint and Care in Desi gnatin~ Material for Protection.

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Each Party or Non-Party that designates information or items for protection under

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

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qualifies under the appropriate standards. The Designating Pariy must designate for

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protection only those parts of material, documents, items, or oral or written

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communications that qualify so that other portions of the material, documents,

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items, or communications for which protection is not warranted are not swept

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unjustifiably within the ambit of this Order.

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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

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

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Designating Party to sanctions.

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If it comes to a Designating Pariy'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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5.2

Manner and Timing of Desi nations. Except as otherwise provided in

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

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stipulated or ordered, Disclosure or Discovery Material that qualifies for protection

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under this Order must be clearly so designated before the material is disclosed or

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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

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documents, but excluding transcripts of depositions or other pretrial or trial

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6

proceedings), that the Producing Party affix at a minimum, the legend

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7 "CONFIDENTIAL"(hereinafter "CONFIDENTIAL legend"), to each page that
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contains protected material. If only a portion or portions ofthe material on a

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1 ~ ~ page qualifies for protection, the Producing Party also must clearly identify the
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protected portions)(e.g., by making appropriate 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

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

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deemed "CONFIDENTIAL." After the inspecting Party has identified the

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documents it wants copied and produced, the Producing Party must determine

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which documents, or portions thereof, qualify for protection under this Order.

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Then, before producing the specified documents, the Producing Party must affix the

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CONFIDENTIAL legend" to each page that contains Protected Material. If only a
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portion or portions ofthe material on a page qualifies for protection, the Producing

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Party also must clearly identify the protected portions)(e.g., by making

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appropriate markings in the margins).

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(
b)

For testimony given in depositions that the Designating Party identify

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the Disclosure or Discovery Material on the record, before the close ofthe

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deposition all protected testimony.

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(
c)

For information produced in some form other than documentary and

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f any other tangible items, that the Producing Party affix in a prominent place on
or

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the exterior ofthe container or containers in which the information is stored the

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legend "CONFIDENTIAL." If only a portion or portions ofthe information

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

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protected portion(s).

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5.3

Inadvertent Failures to Designate. Iftimely corrected, an inadvertent

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

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the Designating Party's right to secure protection under this Order for such

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material. Upon timely correction of a designation, the Receiving Party must make

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1 ~~ reasonable efforts to assure that the material is treated in accordance with the
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provisions of this Order.

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6.

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CHALLENGING CONFIDENTIALITY DESIGNATIONS
6.1

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

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

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Scheduling Order.

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6.2

Meet and Confer. The Challenging Party shall initiate the dispute

resolution process under Civil Local Rule 37.1 et seq.

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6.3
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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.

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ACCESS TO AND USE OF PROTECTED MATERIAL
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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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2
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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

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authorized under this Order.
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7.2

Disclosure of"CONFIDENTIAL" Information or Items. Unless

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

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Receiving Party may disclose any information or item designated

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"CONFIDENTIAL" only to:

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(a)

the Receiving Party's Outside Counsel of Record in this Action, as

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well as employees of said Outside Counsel of Record to whom it is reasonably

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necessary to disclose the information for this Action;

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(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

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disclosure 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 and its personnel;

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(e)

court reporters and their staff;

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(~

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);

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(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

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

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party requests that the witness sign the form attached as Exhibit 1 hereto; and

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(2)they will not be permitted to keep any confidential information unless they sign

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the "Acknowledgment and Agreement to Be Bound"(Exhibit A), unless otherwise

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agreed by the Designating Pariy or ordered by the court. Pages of transcribed

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6

deposition testimony or exhibits to depositions that reveal Protected Material may

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be separately bound by the court reporter and may not be disclosed to anyone

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except as permitted under this Stipulated Protective Order; and

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(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.

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IN OTHER LITIGATION

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6

PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED

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

7 "CONFIDENTIAL," that Party must:
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9

(a)

promptly notify in writing the Designating Pariy. Such notification

shall include a copy ofthe subpoena or court order;

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(b)

promptly notify in writing the party who caused the subpoena or order

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

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subpoena or order is subject to this Protective Order. Such notification shall

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include a copy of this Stipulated Protective Order; and

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15

(c)

cooperate with respect to all reasonable procedures sought to be

pursued by the Designating Party whose Protected Material may be affected.

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If the Designating Party timely seeks a protective order, the Party served with

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the subpoena or court order shall not produce any information designated in this

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action as "CONFIDENTIAL" before a determination by the court from which the

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subpoena or order issued, unless the Party has obtained the Designating Party's

2
0

permission. The Designating Party shall bear the burden and expense of seeking

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protection in that court of its confidential material and nothing in these provisions

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should be construed as authorizing or encouraging a Receiving Party in this Action

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to disobey a lawful directive from another court.

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4

9.

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PRODUCED IN THIS LITIGATION

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ANON-PARTY' PROTECTED MATERIAL SOUGHT TO BE
S

(a)

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

27

Non-Party in this Action and designated as "CONFIDENTIAL." Such information

28

produced by Non-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

2

construed as prohibiting allon-Party from seeking additional protections.

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(b)

In the event that a Party is required, by a valid discovery request, to

4

produce allon-Party's confidential information in its possession, and the Party is

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subject to an agreement with the Non-Party not to produce the Non-Party's

6

confidential information, then the Party sha1L•

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(1)

promptly notify in writing the Requesting Party and the Non-

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

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agreement with allon-Party;

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(2)

promptly provide the Non-Party. with a copy ofthe Stipulated

11

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

12

specific description of the information requested; and

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(3)

make the information requested available for inspection by the

Non-Party, if requested.

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(c)

If the Non-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

17

may produce the Non-Party's confidential information responsive to the discovery

18

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

19

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

2
0

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

21

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

22

expense of seeking protection in this court of its Protected Material.

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10.

24

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

25

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

2
6

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

27

writing the Designating Party of the unauthorized disclosures,(b)use its best

28

efforts to retrieve all unauthorized copies of the Protected Material,(c)inform the

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person or persons to whom unauthorized disclosures were made of all the terms of

2

this Order, and (d)request such person or persons to execute the "Acknowledgment

3

and Agreement to Be Bound" that is attached hereto as E~chibit A.

4

1 1.

5

PROTECTED MATERIAL

INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

When a Producing Party gives notice to Receiving Parties that certain

6
7

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

8

protection, the obligations of the Receiving Parties are those set forth in Federal

9

Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify

10

whatever procedure may be established in an e-discovery order that provides for

11

production without prior privilege review. Pursuant to Federal Rule of Evidence

12

502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure

13

of a communication or information covered by the attorney-client privilege or work

14

product protection, the parties may incorporate their agreement in the stipulated

15

protective order submitted to the court.

16

12.

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19

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

2
0

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

21

disclosing or producing any information or item on any ground not addressed in

2
2

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

23

any ground to use in evidence of any ofthe material covered by this Protective

2
4

Order.

25

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

2
6

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

27

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

28

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

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2026-MWF-AGR Document 39 Filed 09/28/17 Page 12 of 14 Page ID #:167

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

2

in the public record unless otherwise instructed by the court.

3

13.

4

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

5 ~~ days of a written request by the Designating Party, each Receiving Party must
6

return all Protected Material to the Producing Party or destroy such material. As

7

used in this subdivision, "all Protected Material" includes all copies, abstracts,

8

compilations, summaries, and any other format reproducing or capturing any ofthe

9

Protected Material. Whether the Protected Material is returned or destroyed, the

10

Receiving Party must submit a written certification to the Producing Party (and, if

11

not the same person or entity, to the Designating Party) by the 60 day deadline that

12 ( identifies(by category, where appropriate) all the Protected Material that was
1)
13

returned or destroyed and (2)affirms that the Receiving Party has not retained any

14

copies, abstracts, compilations, summaries or any other format reproducing or

15

capturing any of the Protected Material. Notwithstanding this provision, Counsel

16

are entitled to retain an archival copy of all pleadings, motion papers, trial,

17

deposition, and hearing transcripts, legal memoranda, correspondence, deposition

18

and trial exhibits, expert reports, attorney work product, and consultant and expert

19

work product, even if such materials contain Protected Material. Any such archival

2
0

copies that contain or constitute Protected Material remain subject to this Protective

21

Order as set forth in Section 4(DURATION).

22

14.

23

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

4
2

sanctions.

25

/
//

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

2
6
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STIPULATED PROTECTIVE ORDER
CASE NO.5:16-CV-02026-MWF-AGR

Case 5

1
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02026-MWF-AGR Document 39 Filed 09/28/17 Page 13 of 14 Page ID #:168

IT IS SO STIPULATED,THROUGH COUNSEL OF RECORD.
Dated: September 28, 2017

Dated: September 28, 2017

By: /s/Matthew M. Loker

By: /s/Lisa M. Simonetti

3
4
5

MATTHEW M.LOKER

LISA M.SIMONETTI

6

KAZEROUNI LAW GROUP,APC

VEDDER PRICE (CA),LLP

7

ABBAS KAZEROUNIAN
MATTHEW M.LOKER

LISA M.SIMONETTI
CHRISTOPHER R. RAMOS

245 Fischer Avenue, Unit D1
Costa Mesa, CA 92626
Telephone:[phone]
Facsimile:[phone]

1925 Century Park East, Suite 1900
Los Angeles, California 90067
Telephone: [phone]
Facsimile: [phone]

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HYDE & SWIGART

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JOSHUA B. SWIGART
DAVID MCGLOTHLIN

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Attorneysfor Defendant
Navient Solutions, LLC,
f
ormerly known as Navient Solutions,
Inc.

2221 Camino Del Rio South, Suite 101
San Diego, CA 92108
Telephone:(_619) 233-7770
Facsimile:[phone]
AttoYneysfor Plaintiff
Andra Jay As Executor OfThe Estate Of
Rita Cutler

* * *ATTESTATION PURSUANT TO LOCAL RULE 5-4.3.4(2)(1)
I, Lisa M. Simonetti, am the registered CM/ECF filer whose login and
password is being used to file this Stipulated Protective Order. I hereby attest that
all other signatories listed, and on whose behalf this filing is being submitted,
concur in the filing's content and have authorized the filing.

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VEDDER PRICE(C A), LLP
ATfI~RNFYG AT LAW

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STIPULATED PROTECTIVE ORDER
CASE NO.5:16-CV-02026-MWF-AGR

Case 5:~6-cv-02026-MWF-AGR Document 39 Filed 09/28/17 Page 14 of 14 Page ID #:169

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ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

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I,

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[print or type full name], of

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entirety and understand the Stipulated Protective Order that was issued by the

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United States District Court for the Central District of California on [date] in the

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case of

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initials assigned to it by the court]. I agree to comply with and to be bound by all

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the terms of this Stipulated Protective Order and I understand and acknowledge that

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failure to so comply could expose me to sanctions and punishment in the nature of

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contempt.

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information or item that is subject to this Stipulated Protective Order to any person

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or entity except in strict compliance with the provisions of this Order.

[insert formal name of the case and the number and

I solemnly promise that I will not disclose in any manner any

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I further agree to submit to the jurisdiction of the United States District Court

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for 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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type full name] of

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and telephone number] as my California agent for service of process in connection

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with this action or any proceedings related to enforcement of this Stipulated

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Protective Order.

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Date:

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City and State where sworn and signed:

[print or
sprint or type full address

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Printed name:

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Signature:

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VEDDER PRICE(CA~,LLP

STIPULATED PROTECTIVE ORDER
CASE NO.5:16-CV-02026-MWF-DTB

Arri~uNrvs at Law
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LOS_ANGELES/#25241