Platinum Properties Investor Network, Inc. et al v. AMCO Insurance Company

Filing 41

STIPULATED PROTECTIVE ORDER REGARDING PRIVILEGED DOCUMENTS PRODUCED BY LEE HARDEE, ESQ. AND THE HARDEE LAW FIRM LLC AND JEFF BAKER, ESQ. AND SANDERS, WARREN & RUSSELL, LLP AND DEPOSITIONS OF LEE HARDEE, ESQ. AND JEFF BAKER, ESQ. by Magistrate Judge Jay C. Gandhi re Stipulation for Protective Order 36 . (kh)

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MARC S. HINES (SBN 140065)
[e-mail]
CHRISTINE M. EMANUELSON (SBN 221269)
cemanuelson@ hineshamptonllp.com
MONICA D. DIB, (SBN 222106)
[e-mail]
HINES HAMPTON LLP
3090 Bristol Street, Suite 300
Costa Mesa, California 92626
Tel.: [phone]
Fax: [phone]
Attorneys for Defendant, AMCO INSURANCE COMPANY, erroneously sued
herein as NATIONWIDE INSURANCE

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DOUG ILER (SBN 235350)
ILER LAW FIRM
2192 Dupont Drive, Ste 105 B
Irvine, CA 92612
Tel: [phone]
Fax: [phone]
[e-mail]
Attorneys for Plaintiffs, PLATINUM PROPERTIES INVESTOR NETWORK,
INC. and JASON HARTMAN

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THE UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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CASE NO. 8:14-cv-01321-AG-JCG

PLATINUM PROPERTIES
INVESTOR NETWORK, INC., a
California corporation; and JASON
HARTMAN, an individual,

Hon. Jay C. Gandhi
Courtroom: 6A

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STIPULATED PROTECTIVE
ORDER REGARDING
PRIVILEGED DOCUMENTS
PRODUCED BY LEE HARDEE,
ESQ. AND THE HARDEE LAW
FIRM LLC AND JEFF BAKER,
ESQ. AND SANDERS, WARREN &
RUSSELL, LLP AND
DEPOSITIONS OF LEE HARDEE,
ESQ. AND JEFF BAKER, ESQ.

Plaintiffs,
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vs.
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NATIONWIDE INSURANCE, and
DOES 1 through 100,
Defendants.

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Discovery Cutoff: January 5, 2016
Pretrial Conference: March 21, 2016
Trial Date:
April 5, 2016

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STIPULATED PROTECTIVE ORDER

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1. A. PURPOSES AND LIMITATIONS
Plaintiffs, Platinum Properties Investor Network, Inc. and Jason Hartman

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(“Plaintiffs”), Defendant, AMCO Insurance, Co. (“AMCO”) and Third Parties,
Lee R. Hardee III, Esq. and The Hardee Law Firm LLC (collectively referred to as
“Hardee”) and Jeff Baker, Esq. and Sanders, Warren

& Russell, LLP

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(“collectively referred to as “Baker”) (hereinafter, the “Parties”) agree that they

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each may possess information relating to the subject matter of this case which is

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or could be confidential or proprietary. The Parties agree that protection of the

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categories of confidential information and attorney-client privileged information,

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identified in this Stipulated Protective Order (“Protective Order”), is necessary

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because it is anticipated that in this case documents and information will be

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requested which relate to the previous representation of the Plaintiffs and non-

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parties, Karen Karanickolas, Brittney Roberts and David Toombs by Hardee, and

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of the Plaintiffs by Baker in the case styled Results Property Management, LLC et
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al., v. Platinum Properties Investor Network, Inc. et al, Case No. 1016-CV35390,

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in the Circuit Court of Jackson County, Missouri. The requested discovery and

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information, including deposition testimony of Hardee and Baker, will require
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disclosure of confidential information, including but not limited to, documents and

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information protected by the attorney-client privilege and attorney work-product

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privilege.
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STIPULATED PROTECTIVE ORDER

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///
The Parties recognize that in the course of discovery proceedings, it may be

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necessary to disclose to other parties certain confidential information, but each
wishes to ensure that such information is not be used for any purpose other than
this lawsuit and is not made public or be otherwise disseminated, beyond the

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extent necessary for the purposes of this action. To expedite discovery and permit

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discovery to proceed without the delay occasioned by possible disputes regarding

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claims of confidentiality, the Parties wish to produce documents and things

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subject to the protective provisions set forth below.
Hardee and Baker’s disclosure of information pursuant to the subpoenas
served by AMCO relative to this lawsuit and in their depositions is made in

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reliance on the provisions of this Protective Order permitting them to designate

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documents, testimony, information, and things as “Confidential” as defined

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below, and thereby protect such designated information from unauthorized use or
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disclosure.
The Parties acknowledge, as set forth in Section 11, below, that this

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Protective Order does not entitle them to file confidential information under seal;
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Civil Local Rule 79-5 sets forth the procedures that must be followed and the

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standards that will be applied when a party seeks permission from the court to file

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material under seal.
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STIPULATED PROTECTIVE ORDER

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The Parties therefore agree to the terms and conditions set forth below and
entry by the Court of this Protective Order.

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B.

GOOD CAUSE STATEMENT

This action involves information and documents that Hardee and Baker
claim are protected by the attorney-client privilege and the attorney-work product

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for which special protection from public disclosure and from use for any purpose

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other than prosecution of this action is warranted. Such confidential materials and

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information consist of attorney-client privileged communications and documents,

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and documents that constitute attorney work-product in the “Underlying Action”,

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(as defined below) that are unavailable to the public and which may be privileged

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or otherwise protected from disclosure under state or federal statutes, court rules,

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case decisions, or common law.
Accordingly, to allow and expedite the flow of information from Hardee

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and Baker, that Plaintiffs claim are in possession of the documents supporting
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Plaintiffs’ claims in this case, as well as any additional relevant documents

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requested by AMCO in discovery of this case from these third-party witnesses, to

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facilitate the prompt resolution of disputes over confidentiality of discovery
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materials, to adequately protect information these third-parties contend are entitled

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to keep confidential, to ensure that the parties are permitted reasonable 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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STIPULATED PROTECTIVE ORDER

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handling at the end of the litigation, and serve the ends of justice, a protective
order for such information is justified in this matter. It is the Parties’ intent that

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information will not be designated as confidential for tactical reasons and that
nothing be so designated without a good faith belief that it has been maintained in
a confidential, non-public manner, and there is good cause why it should not be

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part of the public record of this case.
3.

SCOPE

All documents and materials produced by Hardee and Baker in response to

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the subpoenas served on them and in giving their depositions in this case

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(hereinafter collectively “Documents”), are subject to this Protective Order as set

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forth below. As there is a presumption in favor of open and public judicial

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proceedings in the federal courts, this Protective Order will be strictly construed in

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favor of public disclosure and open proceedings wherever possible. Any disputes

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that arise under this Protective Order will be resolved by this Court after the
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obligation to meet and confer between the parties is met. Any use of the protected

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material at trial shall be governed by the orders of the trial judge. This Protective

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Order does not govern the use of protected material at trial. However, the parties
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agree that Plaintiffs and AMCO will seek to have any Confidential Information

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disclosed or provided by Hardee or Baker that is used at trial by requesting that

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those portions of the record be sealed.
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STIPULATED PROTECTIVE ORDER

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4.

DEFINITION OF CONFIDENTIAL INFORMATION.

As used in this Protective Order, “Confidential Information” is defined as
information that Hardee and Baker designate in good faith, that has been

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previously maintained in a confidential manner, that should be protected from

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disclosure and use outside the litigation because its disclosure and use is restricted

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by statute or could potentially cause harm to the interests of the disclosing party or

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nonparties, and that has been designated as “CONFIDENTIAL.” For purposes of

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this Protective Order, Confidential Information is limited to the following

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categories of information and documents, and the Parties will limit their

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Confidential designations to the below-described categories:
a.

Documents relating to communications between attorneys and the

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attorneys’ respective clients;
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b.

Drafts of letters, pleadings, reports, summaries, memoranda, or other

written documents contained within any attorney’s litigation file;

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c.

Other information or tangible things that qualify for protection under

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Federal Rule of Civil Procedure 26(c), including, but not limited to, information

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which constitutes, reflects, contains, or concerns non-public, confidential or

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STIPULATED PROTECTIVE ORDER

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proprietary information, the disclosure of which could be potentially prejudicial to
the business or operations of the Designating Party.

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The Designating Party shall not designate as Confidential Information,
documents, or things that are known by the Designating Party to be available to
members of the general public.

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5.

DESIGNATION OF DOCUMENTARY MATERIAL.

Documentary material may be designated as CONFIDENTIAL by
stamping or otherwise marking each page with the appropriate confidentiality

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designation and with the identity of the classifying party unless it is indicated as

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part of the production number (e.g., “Plaintiff P00001”) contained on the

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document. Except with respect to documents produced by any party prior to the

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execution by the Parties of this Protective Order, the identification and designation

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of Confidential Information shall be made at the time when a copy of the

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document is provided to the requesting party.
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Unless otherwise designated or agreed by the Parties, all documents made

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available for inspection prior to copying and production shall be presumed to have

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been marked CONFIDENTIAL.

No documents of the party or third party

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producing documents shall be removed from the site of the inspection or copied

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until such producing party or third party has had an opportunity to review and

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designate such documents in the manner previously explained.
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STIPULATED PROTECTIVE ORDER

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With regard to non-written material, such as recordings, magnetic media,
photographs and things, the designation of any information as CONFIDENTIAL

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for purposes of this Protective Order shall be made by affixing a
CONFIDENTIAL designation to the material, or a container for the material, in
any suitable manner at the time of copying (if any).

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6.

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Inadvertent failure to designate any document or material as containing

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INADVERTENT FAILURE TO DESIGNATE.

CONFIDENTIAL information will not constitute a waiver of an otherwise valid

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claim of confidentiality pursuant to this Order, so long as a claim of

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confidentiality is asserted within 14 days after discovery of the inadvertent failure.

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DESIGNATION OF DEPOSITIONS

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Deposition or other oral testimony given in this case by Hardee or Baker

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may be designated as CONFIDENTIAL by them either (a) during the deposition

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or proceeding during which the testimony is given, or (b) by written notice to the
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court reporter and to all counsel of record, within ten (10) days of receipt, either

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by mail or email, of the deposition transcript. Unless otherwise ordered by the

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Court, pending the expiration of this ten (10) day period, all parties and persons
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shall treat the testimony as if it has been designated CONFIDENTIAL. Unless

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otherwise ordered by the Court, the designating party shall have the right to have

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all persons, except the witness, his or her counsel, the court reporter, and such
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STIPULATED PROTECTIVE ORDER

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other persons authorized to receive the designating party’s Confidential
Information pursuant to this Protective Order, excluded from a deposition or

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proceeding, or any portion thereof, before the taking therein of testimony that has
been so designated. The court reporter shall mark the cover of the original and all
copies of the transcript or the portion of the transcript containing testimony

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designated as either CONFIDENTIAL with the appropriate legend.
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BELATED DESIGNATION.

Notwithstanding

the

obligations

to

timely

designate

Confidential

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Information under the foregoing paragraphs, nothing contained in this Order

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precludes a party or a third party from later changing that designation and

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notifying the other parties in writing of that change; provided, however, that it

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shall not be deemed a breach of this Protective Order for any action to have been

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taken by a party or its counsel with respect to such information consistent with the

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original designation of such information prior to receipt of such notice. A party
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receiving such written notice shall make every reasonable effort to retrieve any

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such materials from persons not authorized to receive them pursuant to this

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Protective Order and to avoid any further unauthorized disclosure. Any party that
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changes the designation of any materials under this Protective Order shall timely

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provide the other parties to this action with new copies of the materials with the

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new designation(s).
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STIPULATED PROTECTIVE ORDER

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9.

NON-USE.

Plaintiffs and AMCO shall use the Confidential Information only for

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purposes of this litigation and pursuant to this protective order.
10.

PROTECTION OF CONFIDENTIAL MATERIAL.

(a) General Protections. Designated Confidential Information must be

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used or disclosed solely for purposes of prosecuting or defending this lawsuit,

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including any appeals [or any other related legal proceeding brought by one of the

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parties to this litigation].

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(b) Who May View Designated Confidential Information. Except with

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the prior written consent of the designating party or prior order of the court,

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designated Confidential Information may only be disclosed to the following

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persons:

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a.

The parties to this litigation, including any employees, agents, and

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representatives of the parties;
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b.

Counsel for the parties and employees and agents of counsel;

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c.

The court and court personnel, including any special master

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appointed by the court, and members of the jury;
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d.

Court

reporters,

recorders,

and

videographers

depositions;

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STIPULATED PROTECTIVE ORDER

engaged

for

e.

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Any mediator appointed by the court or jointly selected by the

parties;

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f.

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Any expert witness, outside consultant, or investigator retained

specifically in connection with this litigation, but only after such persons have
completed the certification contained in Attachment A, Acknowledgment and

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Agreement to be Bound;
g.

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Any potential, anticipated, or actual fact witness and his or her

counsel, but only to the extent such confidential documents or information will

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assist the witness in recalling, relating, or explaining facts or in testifying, and

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only after such persons have completed the certification contained in Attachment

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A;

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h.

The author or recipient of the document (not including a person who

received the document in the course of the litigation);

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i.

Independent

providers

of

document

reproduction,

electronic

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discovery, or other litigation services retained or employed specifically in

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connection with this litigation; and

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j.

Other persons only upon consent of the producing party and on such

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conditions as the parties may agree.
This Protective Order has no effect upon and shall not apply to (1) any

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party’s use of its own Confidential Information for any purpose, or (2) any party’s
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STIPULATED PROTECTIVE ORDER

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use of documents or other information developed or obtained independently of
discovery in this action for any purpose.

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Nothing in this Protective Order shall bar or otherwise restrict an attorney,
who is a qualified recipient under the terms of paragraph 10(b) of this Protective
Order, from rendering advice to his or her client with respect to this action, and in

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the course thereof, from generally relying upon his or her examination of

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Confidential Information. In rendering such advice or in other communications

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with the client, the attorney shall not disclose any Confidential Information of

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another party or third party where such disclosure would not otherwise be

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permitted under the terms of this Protective Order.

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11.

FILING CONFIDENTIAL INFORMATION.

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In the event a party seeks to file any document containing Confidential

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Information subject to protection under this Order with the court, that party must

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take appropriate action to insure that the document receives proper protection
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from public disclosure including: (a) where appropriate (e.g., in relation to

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discovery and evidentiary motions), submitting the document solely for in camera

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review; or (b) when the preceding measures are inadequate, seeking permission to
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file the document under seal by filing a motion for leave to file under seal. A

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party that seeks to file under seal any material designated as “Confidential” must

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comply with Civil Local Rule 79-5. This material may only be filed under seal
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STIPULATED PROTECTIVE ORDER

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pursuant to a court order authorizing the sealing of the specific material at issue.
If a party’s request to file material designated as “confidential” under seal is

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denied by the court, then the receiving party may file the information in the public
record unless otherwise instructed by the court.
Nothing in this Order will be construed as a prior directive to allow any

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document to be filed under seal. The Parties understand that the requested

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documents may be filed under seal only with the permission of this court after

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proper motion. If the motion is granted and the requesting party is permitted to file

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the requested documents under seal, only counsel of record and unrepresented

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parties will have access to the sealed documents. Pro hac vice attorneys must

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obtain sealed documents from local counsel.

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12.

INADVERTENT DISCLOSURE OF PRIVILEGED
MATERIALS

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Federal Rule of Civil Procedure 26(b)(5)(B) governs the inadvertent or
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mistaken production of information that is subject to a claim of privilege or of

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protection as trial-preparation material. The inadvertent disclosure of information

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that is privileged shall not, by itself, constitute a waiver of the privilege. If a party
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inadvertently discloses any document or thing containing information that it

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deemed confidential without designating it as CONFIDENTIAL, the disclosing

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party shall promptly upon discovery of such inadvertent disclosure inform the
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STIPULATED PROTECTIVE ORDER

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receiving party in writing and the receiving party shall thereafter treat the
information as CONFIDENTIAL under this Order.

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13.

CHALLENGES TO A CONFIDENTIAL DESIGNATION.

The designation of any material or document as Confidential Information is
subject to challenge by any party. Before filing any motion or objection to a

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confidential designation, the objecting party must meet and confer in good faith to

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resolve the objection informally without judicial intervention. The challenging

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party shall initiate the dispute resolution process under Local Rule 37.1, et seq.

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and in the event a resolution is not reached, the challenging party, after making a

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good faith effort to meet and confer, shall file a noticed motion. A party that

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elects to challenge a confidentiality designation may file and serve a motion in

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this court that identifies the challenged material and sets forth in detail the basis

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for the challenge. The burden of proving the necessity of a confidentiality

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designation remains with the party asserting confidentiality. Until the court rules
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on the challenge, all parties must continue to treat the materials as Confidential

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Information under the terms of this Protective Order.

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14.

USE OF CONFIDENTIAL DOCUMENTS OR INFORMATION

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AT TRIAL OR HEARING.
Nothing in this Order will be construed to affect the use of any document,

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material, or information at any trial or hearing. A party that intends to present or
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STIPULATED PROTECTIVE ORDER

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that anticipates that another party may present Confidential Information at a
hearing or trial must bring that issue to the attention of the Court and the other

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parties, including

Hardee and Baker, without disclosing the Confidential

Information. The court may thereafter make such orders as are necessary to
govern the use of such documents or information at the hearing or trial.

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///

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///

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15.

DISCLOSURE OF CONFIDENTIAL INFORMATION TO

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UNAUTHORISED PERSON(S).

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If Confidential Information is disclosed to any person other than those
authorized to receive such information by this Order, the party responsible for the

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disclosure shall immediately inform the designating party of all pertinent facts

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relating to such disclosure and shall make every reasonable effort to prevent

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disclosure by each unauthorized person who received such information and to
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obtain the return of such information.
16.

CONCLUSION OF LITIGATION

(a)

Order Remains in Effect. Unless otherwise agreed or ordered, all

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provisions of this Order will remain in effect until this action is concluded by

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judgment, dismissal and/or order of this Court.

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STIPULATED PROTECTIVE ORDER

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(b)

Return of Confidential Documents.

Within 90 days after this

litigation concludes by settlement, final judgment, or final order, including all

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appeals, all documents designated as containing Confidential Information,
including copies as defined above, must be returned to the party who previously
produced the document unless: (1) the document has been offered into evidence or

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filed without restriction as to disclosure; (2) the parties agree to destruction of the

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document to the extent practicable in lieu of return; or (3) as to documents bearing

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the notations, summations, or other mental impressions of the receiving party, that

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party elects to destroy the documents and certifies to the producing party that it

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has done so.

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(c)

Retention

of

Work

Product.

Notwithstanding

the

above

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requirements to return or destroy documents, counsel may retain attorney work

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product, including an index which refers or relates to designated Confidential

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Information, so long as that work product does not duplicate verbatim substantial
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portions of the text or images of designated documents. This work product will

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continue to be confidential under this Protective Order. An attorney may use his or

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her own work product in subsequent litigation provided that its use does not
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disclose Confidential Information.
17.

MODIFICATION.

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STIPULATED PROTECTIVE ORDER

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Stipulations may be made between counsel for the respective parties as to
the application of this Protective Order to specific situations provided that such

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stipulations are recorded in writing or contained in the record of any oral
proceeding. Nothing contained herein shall preclude any party from seeking an
order of the Court modifying or supplementing this Protective Order.

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18.

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This Order is entered based on the representations and agreements of the

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NO PRIOR JUDICIAL DETERMINATION.

parties and for the purpose of facilitating discovery. Nothing in this Protective

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Order will be construed or presented as a judicial determination that any document

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or material designated as Confidential Information by counsel or the parties is

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entitled to protection under Fed. R. Civ. P. 26(c) or otherwise until such time as

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the court
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PERSONS BOUND BY PROTECTIVE ORDER.

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This Protective Order will take effect when entered and is binding upon all
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counsel of record and their law firms, the parties, and persons made subject to this

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Protective Order by its terms.

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20.

APPLICABILITY TO PARTIES LATER JOINED.

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If additional persons or entities become parties to this lawsuit, they must not

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be given access to any Confidential Information until they execute and file with

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STIPULATED PROTECTIVE ORDER

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the court their written agreement to be bound by the provisions of this Protective
Order.

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21.

ORDERED PRODUCED IN OTHER LITIGTION.

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CONFIDENTIAL INFORMATION SUBPOENAD OR

If a receiving party is served with a subpoena or an order issued in other

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litigation that would compel disclosure of any material or document designated in

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this action as Confidential Information, the receiving party must so notify the

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designating party, in writing, immediately and in no event more than three (3)

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business days after receiving the subpoena or order. Such notification must

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include a copy of the subpoena or court order. The receiving party also must

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immediately inform 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

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order is the

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subject of this Protective Order. In addition, the receiving party must deliver a
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copy of this Protective Order promptly to the party in the other action that caused

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the subpoena to issue. The purpose of imposing these duties is to alert the

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interested persons to the existence of this Protective Order and to afford the
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designating party in this case an opportunity to try to protect its Confidential

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Information in the court from which the subpoena or order issued. The designating

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party bears the burden and the expense of seeking protection in that court of its
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STIPULATED PROTECTIVE ORDER

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Confidential Information, and nothing in these provisions should be construed as
authorizing or encouraging a receiving party in this action to disobey a lawful

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directive from another court. The obligations set forth in this paragraph remain in
effect while the party has in its possession, custody, or control Confidential
Information by the other party to this case.

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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

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Respectfully submitted,
HINES HAMPTON LLP

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Dated: November ___, 2015

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By:
Christine M. Emanuelson, Esq.
Attorneys for Defendant, AMCO
INSURANCE COMPANY
ILER LAW FIRM

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Dated: November ___, 2015

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By:
Doug Iler, Esq.
Attorneys for Plaintiffs, PLATINUM
PROPERTIES INVESTOR NETWORK,
INC. and JASON HARTMAN
THIRD PARTY SIGNATURES & AGREEEMENT TO PROTECTIVE ORDER

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Lee R. Hardee III
The Hardee Law Firm LLC

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Dated: November, _____ 2015

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or

___________________________________

Lee R. Hardee III
Signing as Third-Party and not as attorney
counsel in this litigation
110 South Cherry Street, Suite 103
Olathe, Kansas 66061
Phone:[phone]
Fax: [phone]
[e-mail]
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STIPULATED PROTECTIVE ORDER

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Jeff Baker
Sanders, Warren & Russell, LLP

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Dated: November, _____ 2015
Jeff Baker
Signing as Third-Party and not as attorney
counsel in this litigation
40 Corporate Woods, Ste. 1250
9401 Indian Creek Parkway,
Overland Park, KS 66210
Phone: [phone]
Fax: [phone]
[e-mail]

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or

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FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

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DATED: November 24, 2015

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____________________________________
Jay C. Gandhi, United States Magistrate Judge

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ATTACHMENT A

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ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

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The undersigned hereby acknowledges that he/she has read the Protective
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Order dated November___, 2015 in the case captioned, Platinum Properties

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Investment Network, Inc. v. AMCO Insurance, Co., Case No. 2:15-mc-00213-

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JAR, and attached hereto, understands the terms thereof, and agrees to be bound
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by its terms. The undersigned submits to the jurisdiction of the United States
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STIPULATED PROTECTIVE ORDER

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District Court for the District of California in matters relating to this Protective
Order and understands that the terms of the Protective Order obligate him/her to

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use materials designated as Confidential Information in accordance with the order
solely for the purposes of the above-captioned action, and not to disclose any such
Confidential Information to any other person, firm, or concern, except in

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accordance with the provisions of the Protective Order. The undersigned

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acknowledges that violation of the Protective Order may result in penalties for

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contempt of court.

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Name:

______________________________________

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Job Title:

______________________________________

Employer:

______________________________________

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Business Address: ___________________________ ___________

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Date:

______________________________________

Signature:

______________________________________

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STIPULATED PROTECTIVE ORDER

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ATTESTATION OF CONCURRENCE IN FILING
I hereby attest and certify that on November 13, 2015, I received

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concurrence from Plaintiff’s counsel, Doug Iler, Esq., to file this document with

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his electronic signature attached.

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I certify under penalty of perjury under the laws of the United States of

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America that the foregoing is true and correct.

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Executed on November 17, 2015.

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/s/ Christine M. Emanuelson

Christine M. Emanuelson

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STIPULATED PROTECTIVE ORDER