Justin A Gopen v. The Regents of The University of California et al

Filing 72

STIPULATED PROTECTIVE ORDER by Magistrate Judge Karen E. Scott: See document for further information. (lwag)

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AARON D. GOPEN, Esq. (SBN 268451)
[e-mail]
THE LAW OFFICES OF AARON D. GOPEN
1601 N. Sepulveda Blvd., #584
Manhattan Beach, CA 90266
Tel: [phone]
Fax: [phone]
Attorney for Plaintiff,
JUSTIN A. GOPEN

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MARGARET M. HOLM, Esq. (SBN 71252)
[e-mail]
M. CHRISTOPHER HALL, Esq. (SBN 182439)
[e-mail]
BONNE, BRIDGES, MUELLER, O’KEEFE & NICHOLS
1851 E. First Street, Suite 810
Santa Ana, CA 92705
Tel: [phone]
Fax: [phone]

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Attorneys for all Named Defendants

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UNITED STATES DISTRICT COURT
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CENTRAL DISTRICT OF CALIFORNIA

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JUSTIN A. GOPEN,

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Plaintiff,
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vs.
THE REGENTS OF THE
UNIVERSITY OF CALIFORNIA,
et al.
Defendants

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Case No.: SACV15-02062 JVS (KESx)
ORDER RE:
STIPULATED PROTECTIVE
ORDER
Complaint filed: December 11, 2015
First Amended Complaint filed:
March 13, 2016
Judge: The Honorable James V. Selna
Magistrate Judge: Karen E. Scott

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Case No.: SACV15-02062 JVS (KESx)
Stipulated Protective Order

[1]

STIPULATED PROTECTIVE ORDER

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1.

INTRODUCTION

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A.

PURPOSES AND LIMITATIONS

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The parties in this matter possess confidential and sensitive information and

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medical records that are protected under various doctrines. This confidential and

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private information was obtained from confidential communications between

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plaintiff, in his capacity as a medical patient, and various health care professionals.

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Because Discovery in this action is likely to involve documents containing

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confidential or private information for which special protection from public

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disclosure is warranted, the parties hereby stipulate to and petition the Court to

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enter the following Stipulated Protective Order which provides for protecting

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certain confidential information from public disclosure.

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The parties acknowledge that this Order does not confer blanket protections

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on all disclosures or responses to discovery and that the protection it affords is

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relates to limiting public disclosure of confidential information or items that are

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entitled to this treatment under the applicable legal principles. The parties further

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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 with the

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Court, unless the filing Party has first obtained the appropriate permission from the

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Court. Civil Local Rule 79-5 sets forth the procedures that must be followed and

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

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file material under seal.

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B.

GOOD CAUSE STATEMENT

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Documents produced in this action are likely to involve confidential and

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sensitive information that is protected under various doctrines and privileges

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including, but not limited to, doctor/patient confidentiality, patient/therapist

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confidentiality, and the Health Insurance Portability and Accountability Act

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(“HIPPA”) for which special protection from public disclosure and from use for
Case No.: SACV15-02062 JVS (KESx)
Stipulated Protective Order

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any unauthorized purpose is warranted. Such confidential information exists in

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confidential medical records and was communicated under confidential

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circumstances between a patient and various health care professionals. This

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information is 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. Any information that is produced in

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discovery in this matter shall be designated and prominently marked as

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“CONFIDENTIAL”, when the public disclosure of such information would

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violate doctor/patient confidentiality, patient/therapist confidentiality, the Health

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Insurance Portability and Accountability Act (“HIPPA”) or that would in the

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reasonable opinion of a neutral party have a prejudicial effect on a Party that clearly

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outweighs the probative value of the information as it relates to this litigation.

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Accordingly, to expedite the flow of information, to facilitate the prompt

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resolution of disputes over confidentiality of discovery materials, to adequately

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protect information the parties are entitled to keep confidential, to ensure that the

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parties are permitted reasonable necessary uses of such material in preparation for

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and in the conduct of trial, to address their handling at the end of the litigation, and

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serve the ends of justice, a protective order for such information is justified in this

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matter. It is the intent of the parties that information will not be designated as

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“CONFIDENTIAL” for tactical reasons and that nothing be so designated without

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a good faith belief that it has been maintained in a confidential, non-public manner,

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and there is good cause why it should not be part of the public record of this case.

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2.

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DEFINITIONS
2.1

Action: This pending federal law suit captioned Justin A.

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Gopen v. The Regents of the University of California, et al., Case Number

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SACV15-02062 JVS (KESx).

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2.2

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

designation of information or items under this Order.
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Stipulated Protective Order

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2.3

“CONFIDENTIAL” Information or Items: information

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(regardless of how it is generated, stored or maintained) or tangible things that

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qualify for protection under Federal Rule of Civil Procedure 26(c), and as specified

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above in 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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Designating Party: a Party or Non-Party that designates

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

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“CONFIDENTIAL”.

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2.6

Disclosure or Discovery Material: all items or information,

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

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(including, among other things, testimony, transcripts, and tangible things), that

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

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2.7

Expert: 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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2.8

House Counsel: attorneys who are employees of a Party. House

Counsel does not include Outside Counsel of Record or any other 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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2.10 Outside Counsel of Record: attorneys who are not employees

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of a Party, but are retained to represent or advise a Party and have appeared in this

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Action on behalf of that Party or are affiliated with a law firm which has appeared

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on behalf of that Party, and includes support staff.

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2.11 Party: any party to this Action, including all of its officers,

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directors, employees, consultants, retained experts, and Outside Counsel of Record

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(and their support staffs).

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2.12 Producing Party: a Party or Non-Party that produces Disclosure
Case No.: SACV15-02062 JVS (KESx)
Stipulated Protective Order

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or Discovery Material in this Action.

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2.13 Professional Vendors: persons or entities that provide litigation

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

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

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medium) and their employees and subcontractors.

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2.14 Protected Material: any Disclosure or Discovery Material that
is or should be designated as “CONFIDENTIAL”.

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2.15 Receiving Party: a Party that receives Disclosure or Discovery
Material from a Producing Party.
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 of the

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trial 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

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otherwise in writing or a court order otherwise directs. Final Disposition is defined

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

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

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

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limits for filing any motions or applications for extension of time pursuant to

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applicable law.

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5.

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DESIGNATING PROTECTED MATERIAL
5.1

Exercise of Restraint and Care in Designating Material for

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Protection. Each Party or Non-Party that designates information or items for

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protection under this Order must take care to limit any such designation to specific

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material that qualifies under the appropriate standards. The Designating Party must

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designate for protection only those parts of material, documents, items, or oral or

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

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

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swept unjustifiably within the ambit of this Order.

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Mass,

indiscriminate,

or

routinized

designations

are

prohibited.

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

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

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or to 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 Party’s attention that information or items that

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it designated for protection do not qualify for protection, that Designating Party

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must promptly notify all other Parties that it is withdrawing the inapplicable

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designation.

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5.2

Manner and Timing of Designations. Except as otherwise

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

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

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

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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

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

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

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“CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that

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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
Case No.: SACV15-02062 JVS (KESx)
Stipulated Protective Order

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portion(s) (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

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the “CONFIDENTIAL legend” to each page that contains Protected Material. If

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

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Producing Party also must clearly identify the protected portion(s) (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 the

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

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all protected testimony.

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(c) for information produced in some form other than documentary and for

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

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exterior of the container or containers in which the information is stored the legend

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“CONFIDENTIAL”. If only a portion or portions of the information warrants

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

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protected portion(s).

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5.3

Inadvertent Failures to Designate. If timely corrected, an

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inadvertent failure to designate qualified information or items does not, standing

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alone, waive the Designating Party’s right to secure protection under this Order for

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

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make reasonable efforts to assure that the material is treated in accordance with the

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provisions of this Order.
Case No.: SACV15-02062 JVS (KESx)
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6.

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CHALLENGING CONFIDENTIALITY DESIGNATIONS
6.1

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

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a 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 Local Rule 37-1 et seq.

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6.3

Burden of Persuasion. The burden of persuasion in any such

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challenge proceeding shall be on the Designating Party. Frivolous challenges, and

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those made for an improper purpose (e.g., to harass or impose unnecessary

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expenses and burdens on other parties) may expose the Challenging Party to

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sanctions. Unless the Designating Party has waived or withdrawn the

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confidentiality designation, all parties shall continue to afford the material in

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question the level of protection to which it is entitled under the Producing Party’s

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designation until the Court rules on the challenge.

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7.

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ACCESS TO AND USE OF PROTECTED MATERIAL
7.1

Basic Principles. A Receiving Party may use Protected

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Material that is disclosed or produced by another Party or by a Non-Party in

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connection with this Action only for prosecuting, defending, or attempting to settle

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this Action. Such Protected Material may be disclosed only to the categories of

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persons and under the conditions described in this Order. When the Action has

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been terminated, a Receiving Party must comply with the provisions of section 13

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below (FINAL DISPOSITION).

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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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7.2

Disclosure of “CONFIDENTIAL” Information or Items.

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Unless otherwise ordered by the court or permitted in writing by the Designating

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Party, a Receiving Party may disclose any information or item designated
Case No.: SACV15-02062 JVS (KESx)
Stipulated Protective Order

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“CONFIDENTIAL” only to:
(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 (but not through ECF or in any way that

would place the information into the public record);

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(e)

court reporters and their staff;

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(f)

professional jury or trial consultants, mock jurors, and Professional

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

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

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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 (2)

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they will not be permitted to keep any confidential information unless they sign the

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“Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise

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

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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,

mutually agreed upon by any of the parties engaged in settlement discussions.
Case No.: SACV15-02062 JVS (KESx)
Stipulated Protective Order

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8.

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PRODUCED IN OTHER LITIGATION.

PROTECTED

MATERIAL

SUBPOENAED

OR

ORDERED

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In the unlikely event that a Party is served with a subpoena or a court order

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issued in other litigation that compels disclosure of any information or items

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designated in this Action as “CONFIDENTIAL”, that Party must:

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(a)

promptly notify in writing all counsel for parties to this Action. Such

notification shall 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

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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 include

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a copy of this Stipulated Protective Order; and

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(c)

cooperate with respect to all reasonable procedures sought to be

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pursued by the Party or parties whose Protected Material may be affected

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including, but not limited to, providing a fair and reasonable opportunity to contest

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the disclosure of the CONFIDENTIAL information before it is disclosed in

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response to a subpoena or a court order issued in other litigation.

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

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or court order shall not produce any information designated in this action as

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“CONFIDENTIAL” before a determination by the court from which the subpoena

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or order issued, unless the Party has obtained the permission of the Party or parties

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whose Protected Material may be affected. The Party or parties moving for a

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protective order shall either bear (if only one Party is moving for a protective order)

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or equally share (if two or more parties are moving for a protective order) the

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burden and expense of seeking protection of the confidential material and nothing

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in these provisions should be construed as authorizing or encouraging a Party to

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disobey a lawful directive from another court.

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9.

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PRODUCED IN THIS LITIGATION

A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

Case No.: SACV15-02062 JVS (KESx)
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(a)

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

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Non-Party and designated as “CONFIDENTIAL”. Such information produced

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

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

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prohibiting a Non-Party from seeking additional protections.

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(b)

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

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produce a Non-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

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confidential information, then the Party shall:

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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 a Non-Party;

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(2)

promptly provide the Non-Party with a copy of the Stipulated

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

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specific description of the information requested; and

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(3)

make the information requested available for inspection by the

Non-Party within 7 days, 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, the Receiving Party may produce the Non-Party’s

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

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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

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

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order to the contrary, the Non-Party shall bear the burden and expense of seeking

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protection in this court of its Protected Material.

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10.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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If a Party learns that, by inadvertence or otherwise, it has disclosed or has

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become aware that another Party has disclosed Protected Material to any person or
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Stipulated Protective Order

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in any circumstance not authorized under this Stipulated Protective Order, the

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Party must immediately (a) notify in writing the Party or parties whose Protected

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Material may be affected by the disclosure(s), (b) use its best efforts to retrieve all

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

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

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request such person or persons to execute the “Acknowledgment and Agreement

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to Be Bound” that is attached hereto as Exhibit A.

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OTHERWISE PROTECTED MATERIAL

INADVERTENT

PRODUCTION

OF

PRIVILEGED

OR

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When a Producing Party gives notice to Receiving Parties that certain

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

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

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Rule of Civil Procedure 26(b)(5)(B).

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12.

MISCELLANEOUS

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12.1 Right to Further Relief. Nothing in this Order limits the right
of any person or Party to seek the future modification of this Order by the Court.

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12.2 Right to Assert Other Objections. By stipulating to the entry of

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

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

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

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

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Order.

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

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

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

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sealing of the specific Protected Material at issue. If a Party’s request to file

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Protected Material under seal is denied by the court, then that Party must first

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contact the Party or Parties whose Protected Material is implicated for a meet and
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confer conference to discuss if redaction may resolve any issues regarding the

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CONFIDENTIAL information without unduly impairing a Party’s ability to

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present evidence that has probative value in excess of its likely prejudicial effect.

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If agreement is reached regarding the redaction, then the redacted documents may

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be filed in the public record unless otherwise instructed by the Court. If agreement

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cannot be reached on redaction, the Party or parties seeking to prevent the

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disclosure of the CONFIDENTIAL information shall have one week to file a

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request for a protective order and the CONFIDENTIAL information shall be kept

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confidential until that motion is completely resolved.

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13.

FINAL DISPOSITION

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After the Final Disposition of this Action, as defined in paragraph 4, within

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

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

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used in this subdivision, “all Protected Material” includes all copies, abstracts,

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

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

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

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

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

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

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

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

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

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

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

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

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copies that contain or constitute Protected Material remain subject to this

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

VIOLATIONS

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

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

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sanctions.

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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

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Dated: March 18, 2016

By: /s/ Aaron D. Gopen
Printed Name: Aaron D. Gopen
Attorney For Plaintiff Justin A. Gopen

Dated: March 18, 2016

By: /s/ M. Christopher Hall
Printed Name: M. Christopher Hall
Attorney For Defendants

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FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

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DATED: March 22, 2016

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_____________________________________

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The Honorable Karen E. Scott

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United States District/Magistrate Judge

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Case No.: SACV15-02062 JVS (KESx)
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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],

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declare under penalty of perjury that I have read in its entirety and understand the

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attached Stipulated Protective Order that was issued by the United States District

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Court for the Central District of California on ____________________ in the case

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of Justin A. Gopen v. The Regents of the University of California, et al., Case

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Number SACV15-02062 JVS (KESx). I agree to comply with and to be bound by

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

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that failure to so comply could expose me to both monetary and non-monetary

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sanctions and punishment in the nature of contempt. I solemnly promise that I will

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not disclose in any manner any information or item that is subject to this Stipulated

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

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provisions of this Order. I further agree to submit to the jurisdiction of the United

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States District Court for the Central District of California for the purpose of

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enforcing the terms of this Stipulated Protective Order, even if such enforcement

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proceedings occur after termination of this action.

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__________________________

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_______________________________________ [print or type full address and

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

22

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

23

Order.

24

Date: ______________________________________

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City and State where sworn and signed: _________________________________

26

Printed name: _______________________________

[print

or

type

I hereby appoint
full

name]

of

27
28

Signature: __________________________________
Case No.: SACV15-02062 JVS (KESx)
Stipulated Protective Order

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