The Regents of the University of California v. Triple S Steel Holdings Inc et al

Filing 39

PROTECTIVE ORDER by Magistrate Judge Frederick F. Mumm re Stipulation for Protective Order #37 (see attached) (jm)

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LAW OFFICES OF STEPHENSON,
ACQUISTO & COLMAN, INC.
MELANIE JOY STEPHENSON-LAWS, ESQ.(SBN 113755)
BARRY SULLIVAN, ESQ.
(SBN 136571)
RICHARD A. LOVICH, ESQ.
(SBN 113472)
KARLENE J. ROGERS-ABERMAN, ESQ. (SBN 237883)
303 N. Glenoaks Blvd., Suite 700
Burbank, CA 91502
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff
THE REGENTS OF THE UNIVERSITY OF CALIFORNIA,
a public trust corporation, on behalf of the University of
California, Irvine Medical Center

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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THE REGENTS OF THE
Case No.: SA CV 16-1408-DOC (FFM)
UNIVERSITY OF CALIFORNIA, a
public trust corporation, on behalf of the STIPULATED PROTECTIVE
University of California, Irvine Medical ORDER
Center,
Plaintiff,

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vs.

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TRIPLE S STEEL HOLDINGS, INC., a
Texas For Profit Corporation; and DOES
1 THROUGH 25, INCLUSIVE,

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Defendants.

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//

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//

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//

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[PROPOSED] STIPULATED PROTECTIVE ORDER
DM1\7350883.1
1904665V.1

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I.

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To expedite the flow of discovery materials, to facilitate the prompt resolution
of disputes over confidentiality of discovery materials, to adequately protect the
information the parties are entitled or obligated to keep confidential, to ensure that
only materials the parties are entitled or obligated to keep confidential are subject to
such treatment, and to ensure that the parties are permitted reasonably necessary uses
of such materials in preparation for and in the conduct of trial pursuant to Fed. R. Civ.
P. 26(c), the parties hereby stipulate to and petition the court to enter the following
Protective Order.
II. DEFINITIONS

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2.1

third parties unless pursuant to obligations to maintain confidentiality and which
contain trade secrets or other confidential research, development, technical, financial,
or commercial information, or protected health information (as that term is defined by
45 C.F.R. 160.103), whether embodied in physical objects, documents, or the factual
knowledge of persons; and that has been so designated by the producing party, unless
a Court declares such information to not properly meet said descriptions.
2.2

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“Disclosure or Discovery Material”: All items or information, regardless

of the medium or manner in which it is generated, stored, or maintained (including,
among other things, testimony, transcripts, and tangible things), that are produced or
generated in disclosures or responses to discovery in this matter.

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“Counsel”: Outside Counsel of Record.

2.3

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“CONFIDENTIAL” Information or Items: information (regardless of

how it is generated, stored or maintained) or tangible things that are not disclosed to

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PURPOSE

2.4

“Expert”: A person with specialized knowledge or experience in a matter

pertinent to the litigation who (1) has been retained by a Party or its counsel to serve
as an expert witness or as a consultant in this action, (2) is not a past or current
employee or a Party or of a Party’s competitor, and (3) at the time of retention, is not

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anticipated to become an employee of a Party or a Party’s competitor.

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2.5

Information or Items:

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2.6

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2.7

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Extremely sensitive “Confidential Information or Items,”

“Non-Party”: Any natural person, partnership, corporation, associations,

“Outside Counsel of Record”: Attorneys who are not employees of a

which has appeared on behalf of that party.
2.8

“Party”:

Any party to this action, including all of its officers,

directors, employees, consultants, retained experts, and Outside Counsel of Record
(and their support staffs).
2.9

“Professional Vendors”: Persons or entities that provide litigation

support services (e.g., photocopying, videotaping, translating, preparing exhibits or
demonstrations, and organizing, storing, or retrieving data in any form or medium)
and their employees and subcontractors.
2.10 “Protected Material”:
designated

as

Any Disclosure or Discovery Material that is

“CONFIDENTIAL,”

or

as

“HIGHLY

CONFIDENTIAL

–

ATTORNEYS’ EYES ONLY.”
III.

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ONLY”

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

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EYES

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

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ATTORNEYS’

or other legal entity not named as a party in this action.

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–

serious harm that could not be avoided by less restrictive means.

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CONFIDENTIAL

disclosure of which to another Party or Non-Party would create a substantial risk of

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“HIGHLY

DESIGNATION OF PROTECTED INFORMATION
3.1

Exercise of Restraint and Care in Designating Material for Protection.

Each Party or Non-Party that designates information or items for protection under this
Order must take care to limit any such designation to specific material that qualifies
under the appropriate standards. To the extent it is practical to do so, a producing
Party must designate for protection only those parts of material, documents, items or

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communications that qualify – so that other portions of the material, documents,
items, or communications for which protection is not warranted are not swept
unjustifiably within the ambit of this Order. Nothing in this order shall prevent a
receiving Party from contending that any or all documents or information designated
as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
ONLY” should not be so designated.

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If it comes to a producing Party’s attention that information or items that it
designated for protection do not qualify for protection at all or do not qualify for the
level of protection initially asserted, that Party must promptly notify all other parties
that it is withdrawing the mistaken designation.

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3.2

this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
under this Order must be clearly so designated before the material is disclosed or
produced.

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Designation in conformity with this Order requires:

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(a)

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for information in documentary form (e.g., paper or electronic

documents, but excluding transcripts of depositions or other pretrial or trial
proceedings), that the producing Party affix the legend “CONFIDENTIAL” or
“HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” to each page that
contains protected material. If only a portion or portions of the material on a page
qualifies for protection, the producing Party also must clearly identify the protected
portion(s) (e.g., by making appropriate markings in the margins) and must specify, for
each portion, the level of protection being asserted.

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Manner and Timing of Designations. Except as otherwise provided in

(b)

for testimony given in deposition that the designating Party identify on

the record, before the close of the deposition all protected testimony and specify the
level of protection being asserted. When it is impractical to identify separately each

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portion of testimony that is entitled to protection and it appears that substantial
portions of the testimony may qualify for protection, the designating Party may invoke
on the record (before the deposition, hearing, or other proceeding is concluded) a right
to have up to 30 days to identify the specific portions of the testimony as to which
protection is sought and to specify the level of protection being asserted. Only those
portions of the testimony that are appropriately designated for protection within the 30
days shall be covered by the provisions of this Protective Order. Alternatively, a
designating Party may specify, at the deposition or up to 30 days afterwards if that
period is properly invoked, that the entire transcript shall be treated as
“CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
ONLY.”

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Parties shall give the other parties notice if they reasonably expect a deposition
to include Protected Material so that the other parties can ensure that only authorized
individuals who have signed the “Acknowledgment and Agreement to Be Bound”
(Exhibit A) are present at those proceedings. The use of a document as an exhibit at a
deposition shall not in any way affect its designation as “CONFIDENTIAL” or
“HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY.”

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Transcripts containing Protected Material shall have an obvious legend on the
title page that the transcript contains Protected Material, and the title page shall be
followed by a list of all pages (including line numbers as appropriate) that have been
designated as Protected Material and the level of protection being asserted by the
designating Party. The designating Party shall inform the court reporter of these
requirements. Any transcript that is prepared before the expiration of a 21-day period
for designation shall be treated during that period as if it had been designated
“HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” in its entirety unless
otherwise agreed. After the expiration of that period, the transcript shall be treated
only as actually designated.

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(c)

any other tangible items, that the producing Party affix in a prominent place on the
exterior of the container or containers in which the information or item is stored the
legend “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
ONLY”. If only a portion or portions of the information or item warrant protection,
the producing Party, to the extent practicable, shall identify the protected portion(s)
and specify the level of protection being asserted.

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3.3

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designating Party’s right to secure protection under this Order for such material.
Upon timely correction of a designation, the receiving Party must make reasonable
efforts to assure that the material is treated in accordance with the provisions of this
Order.
IV.

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Basic Principles: A Party may use Protected Materials that is disclosed

or produced by another Party or Non-Party in connection with this case only for
prosecuting, defending or attempting to settle this litigation. Such Protected Material
may be disclosed only to the categories of persons and under the conditions described
in this Order. When the litigation has been terminated, the Parties must comply with
the provisions of section 8 below (Final Disposition).
4.2

Disclosure of “CONFIDENTIAL” Information or Items. Unless

otherwise ordered by court or permitted in writing by the designating Party, a
receiving Party may disclose any information or item designated “CONFIDENTIAL”
only to:

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ACCESS TO AND USE OF PROTECTED MATERIAL
4.1

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Inadvertent Failures to Designate. If timely corrected, an inadvertent

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

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for information produced in some form other than documentary and for

(a)

the receiving Party’s Outside Counsel of Record in this action, as well as

employees of said Outside Counsel of Record to whom it is reasonably necessary to
disclose the information for this litigation and who have signed the “Acknowledgment

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and Agreement to Be Bound” that is attached hereto as Exhibit A;

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(b)

disclosure is reasonably necessary for this litigation and who have signed the
“Acknowledgment and Agreement to Be Bound” (Exhibit A);

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(c)

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

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

during their depositions, witnesses in the action to whom disclosure is

reasonably necessary and who have signed the “Acknowledgment and Agreement to
Be Bound” (Exhibit A), unless otherwise agreed by the designating Party or ordered
by the court. Pages of transcribed deposition testimony or exhibits to depositions that
reveal Protected Material may not be disclosed to anyone except as permitted under
this Stipulated Protective Order;

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court reporters and their staff, professional jury or trial consultants, and

Professional Vendors to whom disclosure is reasonably necessary for this litigation

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the Court and its personnel;

(e)

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Experts (as defined in this Order) of the receiving Party to whom

disclosure is reasonably necessary for this litigation and who have signed the

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the officers, directors, and employees of the receiving Party to whom

(g)

the author or recipient of a document containing the information or a

custodian or other person who otherwise possessed or knew the information;

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4.3 Disclosure of “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
ONLY” Information or Items. Unless otherwise ordered by the court or permitted in
writing by the designating Party, a receiving Party may disclose any information
or item designated “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY”
only to:

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(a)

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the receiving Party’s Outside Counsel of Record in this action, as well as
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employees of said Outside Counsel of Record to whom it is reasonably necessary to
disclose the information for this litigation and who have signed the “Acknowledgment
and Agreement to Be Bound” (Exhibit A);

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(b)

necessary for this litigation, and (2) who have signed the “Acknowledgment and
Agreement to Be Bound” (Exhibit A);

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(c)

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

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Information or Items under the provisions of this section, (ii) to whom disclosure is
reasonably necessary and (iii) who have signed the “Acknowledgment and Agreement
to Be Bound” (Exhibit A), unless otherwise agreed by the designating Party or ordered
by the court. Pages of transcribed deposition testimony or exhibits to depositions that
reveal Protected Material may not be disclosed to anyone except as permitted under
this Stipulated Protective Order; and
(f)

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The author or recipient of a document containing the information or a

custodian or other person who otherwise possessed or knew the information.
V. CHALLENGES TO PROTECTED INFORMATION DESIGNATIONS

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during their depositions, witnesses in the action who (i) are otherwise

permitted to see HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY

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court reporters and their staff and Professional Vendors to whom

disclosure is reasonably necessary for this litigation and who have signed the

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the court and its personnel;

(d)

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Experts of the receiving Party (1) to whom disclosure is reasonably

5.1

Timing of Challenges.

Any Party or Non-Party may challenge a

designation of confidentiality at any time. Unless a prompt challenge to a designating
Party’s confidentiality designation is necessary to avoid foreseeable, substantial
unfairness, unnecessary economic burdens, or a significant disruption or delay of the
litigation, a Party does not waive its right to challenge a confidentiality designation by
electing not to mount a challenge promptly after the original designation is disclosed.

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5.2

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The challenging Party shall initiate the dispute

resolution process by providing written notice of each designation it is challenging
and describing the basis for each challenge. To avoid ambiguity as to whether a
challenge has been made, the written notice must recite that the challenge to
confidentiality is being made in accordance with this specific paragraph of the
Protective Order. The Parties shall attempt to resolve each challenge in good faith and
must begin the process by conferring directly (Pursuant to Local Rule 37) within 14
days of the date of service of notice. In conferring, the challenging Party must explain
the basis for its belief that the confidentiality designation was not proper and must
give the designating Party an opportunity to review the designated material, to
reconsider the circumstances, and, if no change in designation is offered, to explain
the basis for the chosen designation. A challenging Party may proceed to the next
stage of the challenge process only if it has engaged in this meet and confer process
first or establishes that the designating Party is unwilling to participate in the meet and
confer process in a timely manner.

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Meet and Confer.

5.3

Judicial Intervention. If the Parties cannot resolve a challenge without

court intervention, the designating Party shall file and serve a motion to retain
confidentiality in compliance with Local Civil Local Rule 37 within 21 days of the
initial notice of challenge or within 14 days of the parties agreeing that the meet and
confer process will not resolve their dispute, whichever is earlier. Each such motion
must be accompanied by a competent declaration affirming that the movant has
complied with the meet and confer requirements imposed in the preceding paragraph.
Failure by the designating Party to make such a motion including the required
declaration within 21 days (or 14 days, if applicable) shall automatically waive the
confidentiality designation for each challenged designation. In addition, the
challenging Party may file a motion challenging a confidentiality designation at any
time if there is good cause for doing so, including a challenge to the designation of a

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deposition transcript or any portions thereof. Any motion brought pursuant to this
provision must be accompanied by a competent declaration affirming that the movant
has complied with the meet and confer requirements imposed by the preceding
paragraph.

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

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Unless the designating Party has waived the confidentiality designation by
failing to file a motion to retain confidentiality as described above, all parties shall
continue to afford the material in question the level of protection to which it is entitled
under the producing Party’s designation until the court rules on the challenge.
VI.

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The protections conferred by this Protective Order cover not only Protected
Material, but also (1) any information copied or extracted from Protected Material; (2)
all copies, excerpts, summaries, or compilations of Protected Material; and (3) any
testimony, conversations, or presentations by Parties or their Counsel that might
reveal Protected Material. However, the protections conferred by this Protective
Order do not cover the following information: (a) any information that is in the public
domain at the time of disclosure or becomes part of the public domain after its
disclosure to a receiving Party as a result of publication not involving a violation of
this Order, including becoming part of the public record through trial or otherwise;
and (b) any information known to the receiving Party prior to the disclosure or
obtained by the receiving Party after the disclosure from a source who obtained the
information lawfully and under no obligation of confidentiality to the designating
Party.

Any use of Protected Material at trial shall be governed by a separate

agreement or order.

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SCOPE

8.

PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN

OTHER LITIGATION

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A.

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If a Party is served with a subpoena or a court order issued in other
litigation that compels disclosure of any information or items designated

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

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1.

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(a)

promptly notify in writing the Designating Party. Such

notification shall include a copy of the subpoena or court order;

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2.

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(b) promptly notify in writing the party who caused the subpoena
or order to issue in the other litigation that some or all of the

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material covered by the subpoena or order is subject to this

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Protective Order. Such notification shall include a copy of this

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Stipulated Protective Order; and

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3.

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(c) cooperate with respect to all reasonable procedures sought to

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be pursued by the Designating Party whose Protected Material may

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be affected.

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B.

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If the Designating Party timely seeks a protective order, the Party served
with the subpoena or court order shall not produce any information

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designated in this action as “CONFIDENTIAL” before a determination

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by the court from which the subpoena or order issued, unless the Party

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

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shall bear the burden and expense of seeking protection in that court of

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its confidential material and nothing in these provisions should be

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construed as authorizing or encouraging a Receiving Party in this Action

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to disobey a lawful directive from another court.

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9.

A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS

LITIGATION

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1.

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

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a

Non-Party

in

this

Action

and

designated

as

“CONFIDENTIAL.” Such information produced by Non-Parties in

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connection with this litigation is protected by the remedies and

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relief provided by this Order. Nothing in these provisions should

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be construed as prohibiting a Non-Party from seeking additional

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protections.

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2.

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(b) In the event that a Party is required, by a valid discovery

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request, to produce a Non-Party’s confidential information in its

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possession, and the Party is subject to an agreement with the Non-

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

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the Party shall:

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a.

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(1) promptly notify in writing the Requesting Party and the
Non-Party that some or all of the information requested is

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subject to a confidentiality agreement with a Non-Party;

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b.

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(2) promptly provide the Non-Party with a copy of the

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Stipulated Protective Order in this Action, the relevant

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discovery request(s), and a reasonably specific description

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of the information requested; and

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c.

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

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3.

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

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within 14 days of receiving the notice and accompanying

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information, the Receiving Party may produce the Non-Party’s

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confidential information responsive to the discovery request. If the

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Non-Party timely seeks a protective order, the Receiving Party

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shall not produce any information in its possession or control that

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is subject to the confidentiality agreement with the Non-Party

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before a determination by the court. Absent a court order to the

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

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seeking protection in this court of its Protected Material.
VII. MISCELLANEOUS PROVISIONS

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7.1

person to seek its modification by the court in the future.

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7.2

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disclosing or producing any information or item on any ground not addressed in this
Stipulated Protective Order. Similarly, no Party waives any right to object on any
ground to use in evidence of any of the material covered by this Protective Order.
7.3

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Filing Protected Material.

Without written permission from the

designating Party or a court order secured after appropriate notice to all interested
persons, a Party may not file in the public record in this action any Protected Material.
A Party that seeks to file under seal any Protected Material must comply with the
procedures for seeking a court order authorizing sealing as permitted by the United
States District Court for the Central District of California. If an application to file
Protected Material under seal is denied by the court, then the Receiving Party may file
the Protected Material in the public record pursuant to Civil Local Rule 79-5(e) unless
otherwise instructed by the court.

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

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

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

7.4

Duration.

Even after final disposition of this litigation, the

confidentiality obligations imposed by this Order shall remain in effect until a
designating Party agrees otherwise in writing or a court order otherwise directs. Final

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disposition shall be deemed to be the later of (1) dismissal of all claims and defenses
in this action, with or without prejudice; and (2) final judgment herein after the
completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of
this action, including the time limits for filing any motions or applications for
extension of time pursuant to applicable law.
VIII. FINAL DISPOSITION

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Within 60 days after the entry of a final non-appealable judgment or order, or
the complete settlement of all claims asserted between the parties in this action, each
party shall, at its option, either return to the producing party or destroy all physical
objects and documents which embody PROTECTED INFORMATION, and shall
destroy in whatever form stored or reproduced, all other physical objects and
documents and copies thereof, including but not limited to, correspondence,
memoranda, notes and other work product materials, which contain or refer to
PROTECTED INFORMATION; provided that all PROTECTED INFORMATION,
not embodied in physical objects and documents, shall remain subject to this Order.
Notwithstanding the foregoing, Counsel shall be entitled to maintain an archival copy
of all pleadings, motions, and trial briefs (including all supporting and opposing
papers thereto), written discovery requests and responses (and exhibits thereto),
deposition transcripts (and exhibits thereto), trial transcripts, and exhibits offered or
introduced into evidence at trial.

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FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

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Dated: December 06, 2017
/s/Frederick F. Mumm
FREDERICK F. MUMM
United States Magistrate Judge

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ATTACHMENT A

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Confidentiality Agreement

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I, ___________________________________, state:

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1. I reside at _____________________________________________.

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2. My present employer is __________________________________.

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3. My present occupation or job description is __________________.

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4. I have read the Stipulated Protective Order dated _____________, and have
been engaged as a _______________________________________ on behalf of
______________________________ in the preparation and conduct of litigation
between Plaintiff The Regents of the University of California and Defendant Triple S
Steel Holdings, Inc.

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5. I am fully familiar with and agree to comply with and be bound by the
provisions of said Order. I understand that I am to retain all material designated as
“CONFIDENTIAL” of “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
ONLY” in a secure manner, and that all copies are to remain in my personal custody
until I have completed my assigned duties, whereupon the copies and any writings
prepared by me containing PROTECTED INFORMATION are to be returned to
counsel who provided me with such material.

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6. I will not divulge to persons other than those specifically authorized by said
Order, and will not copy or use, any information obtained pursuant to said Order
except solely for purposes of this action, except as provided in said Order. I also agree
to notify any stenographic or clerical personnel who are required to assist me of the
terms of said Order.
///
///
///

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7. I hereby consent to personal jurisdiction and venue in the United States District
Court for the Central District of California for the purposes of enforcing said Order.
8. I state under penalty of perjury under the laws of the United States of America
that the foregoing is true and correct.

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Executed on _______________, 201_.

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___________________________________

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STIPULATED PROTECTIVE ORDER
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