Cathy J. Van Huisen v. J.P. Morgan Chase National Corporate Services, Inc.

Filing 20

PROTECTIVE ORDER by Magistrate Judge Karen E. Scott re Stipulation for Protective Order 19 . IT IS SO ORDERED. (see document for details). (dro)

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MORGAN, LEWIS & BOCKIUS LLP
Daryl S. Landy, Bar No. 136288
[e-mail]
Nancy Nguyen, Bar No. 301677
[e-mail]
600 Anton Boulevard, Suite 1800
Costa Mesa, CA 92626-7653
Tel: [phone]
Fax: [phone]

Note changes made by the Court.

Attorneys for Defendant
JPMORGAN CHASE BANK, N.A.
(incorrectly named as J.P. MORGAN CHASE
NATIONAL CORPORATE SERVICES, INC.
dba J.P. MORGAN CHASE BANK)

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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CATHY J. VAN HUISEN,
Plaintiff,

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Case No. 8:17-cv-02031-DOC-KES

vs.
J.P. MORGAN CHASE NATIONAL
CORPORATE SERVICES, INC. dba
J.P. MORGAN CHASE BANK;
ALBERT BROOKS; EDWARD ELY,
and DOES 1-50 Inclusive,

STIPULATION AND [PROPOSED]
PROTECTIVE ORDER
Complaint Filed: October 3, 2017

Defendant.

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MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
COSTA MESA

STIPULATION AND [PROPOSED]
PROTECTIVE ORDER

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Plaintiff Cathy J. Van Huisen (“Plaintiff”) and Defendant JPMorgan Chase

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Bank, N.A. (“Defendant,” incorrectly named as “J.P. MORGAN CHASE

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NATIONAL CORPORATE SERVICES, INC. dba J.P. MORGAN CHASE

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BANK”) (together, the “Parties”), by and through their counsel of record agree and

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stipulate as follows:

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Good Cause Statement

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WHEREAS, Plaintiff has requested documents evidencing transactions

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performed for customers and clients by Plaintiff, documents that potentially could

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include private financial information of Defendant’s customers or other private

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information concerning non-parties, and internal operational documents that are

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confidential and proprietary;

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THEREFORE, IT IS STIPULATED AND AGREED, by and between
Plaintiff and Defendant and their respective undersigned counsel of record that:

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[PROPOSED] PROTECTIVE ORDER

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DEFINITIONS

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1.

For the purpose of this Order:
(a)

“Information” is defined broadly to include information in

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any form, whether provided in response to a request for information, in

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documents, or in testimony;

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(b)

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“Document” is defined broadly to include tangible paper

as well as information stored electronically on disc, tape or otherwise;
(c)

“Confidential Material” is defined to include information

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designated as “Confidential” or “Highly Confidential – Attorneys’ Eyes

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Only” or provisionally treated as “Confidential” or “Highly Confidential –

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Attorneys’ Eyes Only” under the terms of this Order.

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MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
COSTA MESA

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STIPULATION AND [PROPOSED]
PROTECTIVE ORDER

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SCOPE, DESIGNATION AND USE OF CONFIDENTIAL MATERIAL
2.

The Parties acknowledge that they will be requesting and exchanging

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documents and information solely because they are parties to the Litigation and

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therefore agree that all material exchanged between them will be used only for

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purposes of and in connection with prosecuting or defending this Litigation, actions

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that have been related to this Litigation, and/or alternative dispute resolution efforts

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between the parties hereto and for no other purpose. In addition, the parties

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acknowledge that certain of the documents and materials exchanged in discovery in

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this Litigation will be sensitive and confidential and deserve additional protections

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from disclosure, as set forth in this Order. Counsel for each party, and each person

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receiving Confidential Material must take reasonable precautions to prevent the

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unauthorized or inadvertent disclosure of such information.

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3.

A party or non-party subject to discovery in the Litigation may

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designate as “Confidential” or “Highly Confidential – Attorneys’ Eyes Only”

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documents or information produced in discovery that the party or non-party

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considers in good faith to contain confidential information, including but not

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limited to information falling within the following categories:

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(a)

INFORMATION” is defined herein as:
(i)

a trade secret or other confidential research, development
or commercial information; and/or

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Confidential Information. “CONFIDENTIAL

(ii)

any sensitive personal information of nonparties, the

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parties, or their managers, representatives or employees,

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current or former, including the following: Social

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Security number, date of birth, medical records, medical

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information, personnel records, address(es), telephone

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records/numbers, e-mail address(es), wage and benefit

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data, account numbers, tax records, and other financial

MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
COSTA MESA

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STIPULATION AND [PROPOSED]
PROTECTIVE ORDER

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information such as credits, loans, or other business

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transactions, assets, and/or income data;
(b)

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Attorneys’ Eyes Only Information. “ATTORNEYS’

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EYES ONLY INFORMATION” is defined herein as CONFIDENTIAL

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INFORMATION which constitutes, discloses, reveals, describes or

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discusses, in whole or in part, a trade secret within the meaning of the

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California Uniform Trade Secrets Act, financial statements or budgets of

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Defendant, provided however, to the extent that any party intends to rely on

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that party’s budgets, financial statements or net worth information in support

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of, or in defense against, a claim for damages or for recovery of equitable

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relief of a monetary nature, such information shall be designated as

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Confidential, and not Attorneys’ Eyes Only.

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4.

A party or non-party seeking to designate as “Confidential” or “Highly

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Confidential – Attorneys’ Eyes Only” any document that that party or non-party

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produces in response to a document request or subpoena in the Litigation shall

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designate the document as confidential by labeling the document “Confidential” or

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“Highly Confidential – Attorneys’ Eyes Only” on the face of each page of the

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document, along with an indication identifying the producing party. In the event a

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producing party elects to produce materials for inspection, no marking need be

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made by the producing party in advance of the initial inspection. For purposes of

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the initial inspection, all materials produced will be considered as “Highly

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Confidential – Attorneys’ Eyes Only” and must be treated as such pursuant to the

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terms of this Order. Thereafter, upon selection of specified materials for copying

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by the inspecting party, the producing party must, within a reasonable time prior to

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producing those materials to the inspecting party, mark the copies of those materials

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that contain Confidential Information with the appropriate confidentiality marking.

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MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
COSTA MESA

5.

If a party believes that a document produced by someone other than

that party contains confidential information, the party wishing to designate such
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STIPULATION AND [PROPOSED]
PROTECTIVE ORDER

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confidential information under the terms of this Order shall notify the other party in

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the Litigation in writing that it considers the information confidential, label the

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affected document with the legend “Confidential” or “Highly Confidential –

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Attorneys’ Eyes Only” on the face of each page of the document along with an

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indication identifying the party designating the document as confidential, and send

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a copy of the document with the appropriate “Confidential” or “Highly Confidential

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– Attorneys’ Eyes Only” legend to the non-designating party.
6.

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A party or non-party seeking to designate as “Confidential” or “Highly

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Confidential – Attorneys’ Eyes Only” any written response to an interrogatory or

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other request provided by that party or non-party shall designate the response as

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confidential by clearly indicating the page(s) or section(s) of the response that is

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designated as confidential, including by placing the legend “Confidential” or

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“Highly Confidential – Attorneys’ Eyes Only” on the face of each page of the

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response that contains confidential information. If a party believes that a written

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discovery response served by someone other than the party seeking to designate the

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response or any portion thereto as confidential, the designating party shall designate

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the response as confidential by clearly indicating the page(s) or section(s) of the

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response that is designated as confidential, including by placing the legend

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“Confidential” or “Highly Confidential – Attorneys’ Eyes Only” on the face of each

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page of the response that contains confidential information, and shall send a copy of

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the document with the appropriate confidentiality legend to the non-designating

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party.

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7.

A party also may designate as “Confidential” or “Highly Confidential

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– Attorneys’ Eyes Only” any deposition testimony by (a) stating orally on the

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record of a deposition that the entire transcript or portion thereof is “Confidential”

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or “Highly Confidential – Attorneys’ Eyes Only”; or (b) by written notice to

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counsel for the other party in the Litigation of such designation within seven (7)

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days after receipt of the deposition transcript.

MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
COSTA MESA

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STIPULATION AND [PROPOSED]
PROTECTIVE ORDER

(a)

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Disclosure of Confidential Transcripts to the Deponent.

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Deposition transcripts containing Protected Material may be shown to the

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deponent for the purpose of correction, but the deponent may not retain a

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copy of the transcript unless (s)he agrees to be bound by this Protective

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Order by signing a copy of the Acknowledgement Form.
(b)

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Transcript pages containing or constituting

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CONFIDENTIAL INFORMATION shall be separately bound by the court

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reporter and marked “CONFIDENTIAL” on each page. If a Receiving Party

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wishes to show non-CONFIDENTIAL portions of a document or transcript

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containing CONFIDENTIAL INFORMATION to a person or party not

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described below in Paragraph 12, it shall first redact all pages designated

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CONFIDENTIAL.

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8.

The parties shall provisionally treat all documents and written

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discovery responses as Confidential until five (5) calendar days after receipt of such

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documents or discovery responses, unless otherwise agreed by the parties in

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writing. The parties shall provisionally treat all deposition testimony as

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Confidential until seven (7) calendar days after the receipt of each volume of

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deposition transcript, unless otherwise agreed by the parties in writing. If no party

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or non-party has designated documents, written discovery responses, deposition

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testimony or other information as confidential within these time periods, the

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documents and information shall thereafter be treated as if they are not Confidential

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Material, unless and until a party later designates such documents, written

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discovery responses or deposition as Confidential Material.

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9.

Failure to designate material as Confidential using the procedures

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described above shall not operate to waive a party’s or non-party’s ability to later so

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designate such material. Information inadvertently disclosed without being

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designated as confidential may thereafter be designated confidential by promptly

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notifying the party/ies receiving the information in writing that such information is

MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
COSTA MESA

5

STIPULATION AND [PROPOSED]
PROTECTIVE ORDER

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confidential, and, where appropriate, sending copies of the designated pages

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containing confidential information with the appropriate “Confidential” or “Highly

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Confidential – Attorneys’ Eyes Only” legend placed on the face of each page that

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contains confidential information.

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10.

Neither the original nor any copy of any document, response,

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testimony or information which contains or constitutes Confidential Material nor

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any excerpt, quotation, paraphrase or other description thereof which conveys the

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confidential contents thereof shall be disclosed to any person, or used for any

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purpose, except in accordance with the terms of this Order.

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11.

Access to and disclosure of sensitive personal information and

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documents that have been designated as “Confidential,” including but not limited to

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employee personnel files and employee payroll information, shall be limited to the

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to those persons identified in Paragraphs 12(a), (b), (d), and (f) and the employee to

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whom the personal documents and information relates.

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12.

Subject to Paragraph 11, access to and disclosure of other documents

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or information designated by any party or non-party as “Confidential” shall be

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limited, except as otherwise provided herein, or agreed by the parties in writing, or

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as otherwise ordered by the Court, to:

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(a)

The attorneys of record in this Litigation or any action

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that has been related to this Litigation and in-house counsel, if any, for said

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parties, their clerical, paralegal and other employees, and Defendants’

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managers, officers, executives, and directors, who reasonably need access to

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the Confidential Material in connection with and to assist with the

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prosecution or defense of this action, and personnel from any third-party

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vendors retained to assist the attorneys with document collection, translation,

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photocopying, scanning, or other services related to the prosecution or

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defense of this Litigation;

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MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
COSTA MESA

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STIPULATION AND [PROPOSED]
PROTECTIVE ORDER

(b)

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This Court, any court to which a party petitions for

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discovery of a non-party, and court personnel, including but not limited to

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court reporters, translators and persons operating video recording equipment;
(c)

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The parties to this action and those employees of the

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parties who reasonably need access to the Confidential Material in

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connection with and to assist with the prosecution or defense of this action;
(d)

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Any person who authored or received the Confidential

Material prior to the commencement of the Litigation;
(e)

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Any witness not encompassed by the terms of paragraphs

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12(c) or 12(d), above, whose deposition is taken in this action or who is

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being prepared by counsel to give testimony at deposition, provided that any

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such witness abide by the terms of paragraph 14 below; and
(f)

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Outside experts and consultants for any party, whose

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advice or consultation is being or will be used by such party in connection

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with this Litigation, and their employees who reasonably need access to the

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Confidential Material in connection with and to assist with the prosecution or

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defense of this Litigation, provided that any such outside expert, consultant,

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or their employees witness abide by the terms of paragraph 14 below.

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13.

Access to and disclosure of documents or information designated by

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any party or non-party as “Highly Confidential – Attorneys’ Eyes Only” shall be

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limited, except as otherwise provided herein, or agreed by the parties in writing, or

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as otherwise ordered by the Court, to those persons identified in Paragraphs 12(a),

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(b), (d), (e), and/or (f).

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14.

The attorneys for a party may disclose Confidential Material to any

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person described in Paragraph 12(e), above, provided, however, that the witness

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first must be shown this Order and agree to abide by its terms by signing the Non-

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Disclosure Agreement attached hereto as Exhibit 1. Any such deponent or witness

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MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
COSTA MESA

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STIPULATION AND [PROPOSED]
PROTECTIVE ORDER

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may be shown Confidential Material but shall not retain the original, any copy or

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any notes of any such Confidential Material.

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The attorneys for a party may disclose Confidential Material to any

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person described in Paragraph 12(f), above, provided, however, that the expert,

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consultant or employee of an expert or consultant first must be shown this Order

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and agree to abide by its terms by signing the Non-Disclosure Agreement attached

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hereto as Exhibit 1. Any such expert, consultant or employee of an expert or

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consultant shall not retain the original, any copy or any notes of any such

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Confidential Material for longer than three (3) months after the final termination of

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the Litigation.
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If a party or any of its representatives, including counsel, inadvertently

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discloses any Confidential Material to a person not authorized by this Order to use

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or possess such Confidential Material, the disclosing party shall provide immediate

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written notice of the disclosure to the party or non-party whose Confidential

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Material was inadvertently disclosed. The disclosing party shall also promptly take

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reasonable measures to obtain the return of such inadvertently disclosed

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information. If a party has actual knowledge that Confidential Material is being

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used or possessed by a person not authorized to use or possess that material,

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regardless of how the material was disclosed or obtained by such person, the party

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shall provide immediate written notice of the unauthorized use or possession to the

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party or non-party whose Confidential Material is being used or possessed.

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17.

Any party, through counsel, may make a good faith written objection

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to the designation of any document, response, testimony or information as

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“Confidential” or “Highly Confidential – Attorneys’ Eyes Only.” The good faith

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written objection must notify counsel for the designating party of the objected-to

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materials and the grounds for the objection. The parties shall meet and confer in

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good faith to attempt to resolve the dispute without the intervention of the Court. If

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it is not possible to resolve the dispute, the party making the confidentiality

MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
COSTA MESA

8

STIPULATION AND [PROPOSED]
PROTECTIVE ORDER

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designation shall make a motion before the Court pursuant to Local Rule 37

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seeking to preserve the confidentiality designation or use the telephonic process

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described on the Court’s website. Applicable California law shall govern the

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burden and standard of proof on any such motion. The failure to object to the

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confidential designation shall not be construed as a concession that the information

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is confidential.

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18.

Any party or non-party may remove or downgrade its own

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confidentiality designation of documents or information by providing written notice

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to the other party or to the parties of the de-designation or downgrade, or by

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providing new copies of the documents or materials with any confidentiality legend

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removed or replaced with the appropriate legend.

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19.

In the event that any brief, memorandum or other paper to be

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submitted to the Court by or on behalf of a party or non-party contains Confidential

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Material of any other party or non-party that designated that material as

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confidential, the party or non-party submitting the Confidential Material to the

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Court shall file the Confidential Material provisionally under seal accompanied by

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an application to file under seal pursuant to Local Rule 79-5. Good cause must be

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shown in the application to file under seal for non-dispositive matters. If a party

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needing to submit Confidential Material designated by the other party or a non-

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party in connection with a brief, memorandum or other paper to be submitted to the

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Court believes that the confidentiality designation is incorrect, such that the

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Confidential Material need not be filed provisionally under seal, that party shall

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meet and confer with the designating party or non-party pursuant to paragraph 17 of

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this Order reasonably in advance of the date the Confidential Material is to be

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submitted to the Court. If a non-party designated the material to be submitted to

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the Court as confidential, the party submitting the Confidential Material to the

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Court shall meet and confer with that designating non-party reasonably in advance

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of the date the Confidential Material is to be submitted to the Court and/or provide

MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
COSTA MESA

9

STIPULATION AND [PROPOSED]
PROTECTIVE ORDER

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contemporaneous notice to the non-party that its Confidential Information has been

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submitted to the Court with and application to file under seal per Local Rule 79-

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5.2.2(b).

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20.

This Order shall not and does not constitute an admission or

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concession or permit an inference that any document, response, testimony or

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information constituting Confidential Material is, in fact, confidential for purposes

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other than the proper safeguarding of materials produced in discovery in this

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Litigation. Conversely, any disclosure of Confidential Material under this Order

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shall not be construed as a waiver of the confidentiality of the information.
TERMINATION OF LITIGATION

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21.

After termination of this Litigation, each party shall continue to

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maintain and limit access and disclosure to all material in the manner provided in

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this Order. No later than three (3) months after the final termination of the

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Litigation, including the exhaustion of any appeals and cross-appeals and requests

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for discretionary review, each person or party subject to the terms of this Protective

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Order upon request (1) shall either (a) return all materials produced to it in

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discovery to the party or non-party that produced the document, written response or

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information; or (b) destroy all materials produced to it in discovery to the party or

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non-party that produced the document, written response or information, and (2)

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shall promptly certify in writing to the other party and any non-parties that such

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documents have been destroyed or returned. Nothing herein shall obligate any

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person or party to destroy (i) attorney work product, including, without limitation,

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attorney notes or memos, collections of documents used for litigation purposes, and

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deposition summaries; (ii) any transcript of any deposition, hearing, or trial

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proceeding and exhibits attached to such a transcript; and/or (iii) any pleading or

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paper served on another party or filed with the Court in the Litigation, and any

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exhibits attached to such a pleading or paper.

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MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
COSTA MESA

10

STIPULATION AND [PROPOSED]
PROTECTIVE ORDER

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22.

This Court shall retain jurisdiction over the Litigation following its

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termination (whether by judgment, settlement, or otherwise) for the purpose of

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enforcing this Order.
MISCELLANEOUS

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23.

If any party receives from a third party a subpoena, discovery request

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or other demand for information disclosed in this case by the other party or a non-

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party, the party receiving the subpoena, discovery request or other demand shall

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immediately notify the producing party or non-party that it has received a demand

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for the information, and shall not provide any response or information until at least

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fifteen (15) days have passed from said notice, unless the subpoena provides a

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shorter time period. The party receiving the subpoena, discovery request or other

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demand shall reasonably cooperate with the designating party if the producing party

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or non-party seeks a protective order or other limitation on disclosure of the

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Confidential Material. The producing party shall pay the reasonable expense of

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such cooperative efforts.

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24.

Nothing in this Order and no action taken pursuant to it shall be

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construed or asserted to be (a) an agreement by the parties to produce any

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documents or supply any information or testimony in discovery not otherwise

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agreed upon or required by applicable California law; (b) a waiver by any person or

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party of any right to object to or seek a further protective order with respect to any

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discovery request in this or any other action.; or (c) a waiver of any claim of

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immunity or privilege with regard to any testimony, documents or information.

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25.

Nothing in this Order and no action taken pursuant to it shall be

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construed or asserted to waive any objection to the alleged relevancy or

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admissibility of any document, testimony or other evidence at any proceeding in the

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Litigation.

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MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
COSTA MESA

11

STIPULATION AND [PROPOSED]
PROTECTIVE ORDER

26.

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This Order does not govern the treatment of Confidential Material at

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trial, which the parties and the Court will address by a Stipulation and Order issued

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at an appropriate time in the future.
27.

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This Order may be modified in part or entirely by written agreement of

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the parties hereto or upon application to and entry of an Order by the Court upon

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the parties’ agreement or for good cause shown.

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Dated:

June 14, 2018

MORGAN, LEWIS & BOCKIUS LLP

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By /s/ Daryl S. Landy
Daryl S. Landy
Nancy Nguyen
Attorneys for Defendant JPMORGAN
CHASE BANK, N.A. (incorrectly named
as J.P. MORGAN CHASE NATIONAL
CORPORATE SERVICES, INC. dba J.P.
MORGAN CHASE BANK)

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Dated:

June 14, 2018

BERNARD & BERNARD

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By /s/ Stephen Bernard
Stephen Bernard
Attorneys for Plaintiff
CATHY J. VAN HUISEN

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MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
COSTA MESA

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STIPULATION AND [PROPOSED]
PROTECTIVE ORDER

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FILER’S ATTESTATION

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I, Daryl Landy, am the ECF user whose identification and password are

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being used to file this Stipulation and [Proposed] Protective Order. In compliance

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with Local Rule 5-4.3.4(2), I hereby attest that Stephen Bernard of Bernard &

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Bernard has concurred in this filing.

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Dated: June 12, 2018

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MORGAN, LEWIS & BOCKIUS LLP
By

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IT IS SO ORDERED.

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/s/ Daryl S. Landy
Daryl S. Landy

Dated: June 14, 2018

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Honorable Karen E. Scott
United States Magistrate Judge

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MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
COSTA MESA

13

STIPULATION AND [PROPOSED]
PROTECTIVE ORDER

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EXHIBIT “1” TO PROTECTIVE ORDER

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NON-DISCLOSURE AGREEMENT

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I certify that I have carefully read the Protective Order in the case of Van

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Huisen v. J.P. Morgan Chase National Corporate Services, Inc. dba J.P. Morgan

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Chase Bank, et al., Central District of California Case No. 17-cv-02031, and that I

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fully understand the terms of the Order. I understand that Confidential Material is

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being provided to me pursuant to the terms and restrictions of the Protective Order.

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I recognize that I am bound by the terms of this Protective Order and I agree to

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comply with those terms. I certify that I will not reveal Confidential Material to

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anyone except as allowed by the Protective Order and will maintain all such

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Confidential Material, including copies, notes or other transcripts made therefrom,

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in a secure manner to prevent unauthorized access to it.

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I hereby consent to the personal jurisdiction of the United States District

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Court, Central District of California for any proceedings involving the enforcement

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of that Order.

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Executed this day ____ of ____________, 20___, at ___________________,
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Signature
Name

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Affiliation or Company

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Business Address
Home Address

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MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
COSTA MESA

14

STIPULATION AND [PROPOSED]
PROTECTIVE ORDER