Tin Dinh v. Tornos LTD et al

Filing 17

PROTECTIVE ORDER by Magistrate Judge Autumn D. Spaeth re Stipulation for Protective Order 16 . (see document for details) (hr)

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KARA PAPE, STATE BAR #131565
ARIADNE GIANNIS, STATE BAR # 292208
[e-mail]; [e-mail]
TYSON & MENDES, LLP
445 South Figueroa Street, Suite 3100
Los Angeles, CA 90071
Telephone: [phone]/Facsimile: 213.745.8604
Attorneys for Defendant,
TORNOS TECHNOLOGIES U.S. CORPORATION

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA – SOUTHERN DIVISION

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TYSON & MENDES, LLP
445 SOUTH FIGUEROA STREET, SUITE 3100
LOS ANGELES, CA 90071
[phone]/ FAX: [phone]

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TIN DINH,

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PLAINTIFF,

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Case No. 8:20-cv-01481-MCS-ADSx
Assigned to: Judge Mark C. Scarsi and
Magistrate Judge Autumn D. Spaeth
DISCOVERY MATTER

vs.

STIPULATED PROTECTIVE
TORNOS LTD., TORNOS
ORDER CONCERNING
TECHNOLOGIES U.S.
CONFIDENTIAL INFORMATION
CORPORATION, AND DOES 1 TO
25, INCLUSIVE,
Action Date: May 29, 2020
Trial Date: November 16, 2021
DEFENDANTS.

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I.

PURPOSES AND LIMITATIONS

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A.

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proprietary, or private information for which special protection from public disclosure

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and from use for any purpose other than prosecuting this litigation may be warranted.

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Discovery in this action is likely to involve production of confidential,

Accordingly, the parties hereby stipulate to and petition the Court to enter the following
Stipulated Protective Order. The parties acknowledge that this Order does not confer
-1STIPULATED PROTECTIVE ORDER CONCERNING CONFIDENTIAL INFORMATION
Case No. 8:20-cv-01481-MCS-ADSx

blanket protections on all disclosures or responses to discovery and that the protection

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it affords from public disclosure and use extends only to the limited information or

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items that are entitled to confidential treatment under the applicable legal principles.

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The parties further acknowledge, as set forth in Section XIII(C), below, that this

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Stipulated Protective Order does not entitle them to file confidential information under

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seal; Civil Local Rule 79-5 sets forth the procedures that must be followed and the

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

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material under seal.

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II.

GOOD CAUSE STATEMENT

TYSON & MENDES, LLP
445 SOUTH FIGUEROA STREET, SUITE 3100
LOS ANGELES, CA 90071
[phone]/ FAX: [phone]

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A.

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valuable research, development, commercial, financial, technical and/or proprietary

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

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This action is likely to involve trade secrets, customer and pricing lists and other

purpose other than prosecution of this action is warranted. Such confidential and
proprietary materials and information consist of, among other things, confidential
business or financial information, information regarding confidential business
practices, or other confidential research, development, or commercial information

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(including information implicating privacy rights of third parties), information

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otherwise generally unavailable to the public, or which may be privileged or otherwise

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protected from disclosure under state or federal statutes, court rules, case decisions, or

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common law. 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 protect
information the parties are entitled to keep confidential, to ensure that the parties are
permitted reasonable necessary uses of such material in preparation for and in the

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

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of justice, a protective order for such information is justified in this matter. It is the
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Case No. 8:20-cv-01481-MCS-ADSx

intent of the parties that information will not be designated as confidential for tactical

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reasons and that nothing be so designated without a good faith belief that it has been

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maintained in a confidential, non-public manner, and there is good cause why it should

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not be part of the public record of this case.

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III.

DEFINITIONS
A.

Action: This pending federal law suit; Tin Dinh v. Tornos US Technology

Corporation; Case No. 8:20-cv-01481-MCS-ADSx.
B.

Challenging Party: A Party or Non-Party that challenges the designation of

information or items under this Order.

TYSON & MENDES, LLP
445 SOUTH FIGUEROA STREET, SUITE 3100
LOS ANGELES, CA 90071
[phone]/ FAX: [phone]

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C.

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generated, stored or maintained) or tangible things that qualify for protection under

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Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause

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“CONFIDENTIAL” Information or Items: Information (regardless of how it is

Statement.
D.

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

support staff).
E.

Designating Party: A Party or Non-Party that designates information or items

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that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.”

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F.

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

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

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Disclosure or Discovery Material: All items or information, regardless of the

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

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

to the litigation who has been retained by a Party or its counsel to serve as an expert
witness or as a consultant in this Action.
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Case No. 8:20-cv-01481-MCS-ADSx

H.

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

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Counsel does not include Outside Counsel of Record or any other outside counsel.

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I.

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legal entity not named as a Party to this action.

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

Outside Counsel of Record: Attorneys who are not employees of a party to this

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

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in this 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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K.

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Party: Any party to this Action, including all of its officers, directors, employees,

TYSON & MENDES, LLP
445 SOUTH FIGUEROA STREET, SUITE 3100
LOS ANGELES, CA 90071
[phone]/ FAX: [phone]

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

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L.

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Material in this Action.

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M.

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Producing Party: A Party or Non-Party that produces Disclosure or Discovery

Professional Vendors:

Persons or entities that provide litigation support

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

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

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and their employees and subcontractors.

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N.

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“CONFIDENTIAL.”

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O.

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Producing Party.

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IV.

Protected Material: Any Disclosure or Discovery Material that is designated as

Receiving Party: A Party that receives Disclosure or Discovery Material from a

SCOPE
A.

The protections conferred by this Stipulation and Order cover not only Protected

Material (as defined above), but also (1) any information copied or extracted from
Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected
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Case No. 8:20-cv-01481-MCS-ADSx

Material; and (3) any testimony, conversations, or presentations by Parties or their

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Counsel that might reveal Protected Material.

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B.

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

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V.

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DURATION
A.

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

Even after final disposition of this litigation, the confidentiality obligations

imposed by this Order shall remain in effect until a Designating Party agrees otherwise

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

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

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TYSON & MENDES, LLP
445 SOUTH FIGUEROA STREET, SUITE 3100
LOS ANGELES, CA 90071
[phone]/ FAX: [phone]

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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 limits

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for filing any motions or applications for extension of time pursuant to applicable law.

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VI.

DESIGNATING PROTECTED MATERIAL
A.

Exercise of Restraint and Care in Designating Material for Protection
1.

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

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

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specific material that qualifies under the appropriate standards.

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Designating Party must designate for protection only those parts of material,

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documents, items, or oral or written communications that qualify so that other

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portions of the material, documents, items, or communications for which

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The

protection is not warranted are not swept unjustifiably within the ambit of this
Order.
2.

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

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an improper purpose (e.g., to unnecessarily encumber the case development
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Case No. 8:20-cv-01481-MCS-ADSx

process or to impose unnecessary expenses and burdens on other parties) may

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expose the Designating Party to sanctions.

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3.

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

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

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If it comes to a Designating Party’s attention that information or items

inapplicable designation.
B.

Manner and Timing of Designations
1.

Except as otherwise provided in this Order (see, e.g., Section B(2)(b)

below), or as otherwise stipulated or ordered, Disclosure or Discovery Material

TYSON & MENDES, LLP
445 SOUTH FIGUEROA STREET, SUITE 3100
LOS ANGELES, CA 90071
[phone]/ FAX: [phone]

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that qualifies for protection under this Order must be clearly so designated

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before the material is disclosed or produced.

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2.

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Designation in conformity with this Order requires the following:
a.

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 at a minimum, the
legend “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to

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each page that contains protected material. If only a portion or portions

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of the material on a page qualifies for protection, the Producing Party also

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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.

A Party or Non-Party that makes original documents available for

inspection need not designate them for protection until after the
inspecting Party has indicated which documents it would like copied and

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produced. During the inspection and before the designation, all of the

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material

made

available
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for

inspection

shall

be

deemed

STIPULATED PROTECTIVE ORDER CONCERNING CONFIDENTIAL INFORMATION
Case No. 8:20-cv-01481-MCS-ADSx

“CONFIDENTIAL.”

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After the inspecting Party has identified the

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documents it wants copied and produced, the Producing Party must

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determine which documents, or portions thereof, qualify for protection

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under this Order. Then, before producing the specified documents, the

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Producing Party must affix the “CONFIDENTIAL legend” to each page

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that contains Protected Material. If only a portion or portions of the

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material on a page qualifies for protection, the Producing Party also must

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clearly identify the protected portion(s) (e.g., by making appropriate

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markings in the margins).

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TYSON & MENDES, LLP
445 SOUTH FIGUEROA STREET, SUITE 3100
LOS ANGELES, CA 90071
[phone]/ FAX: [phone]

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c.

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identify the Disclosure or Discovery Material on the record, before the

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close of the deposition all protected testimony.

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d.

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For testimony given in depositions, that the Designating Party

For information produced in form other than document and for

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

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place on the exterior of the container or containers in which the

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information is stored the legend “CONFIDENTIAL.” If only a portion or

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portions of the information warrants protection, the Producing Party, to

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the extent practicable, shall identify the protected portion(s).

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C.

Inadvertent Failure to Designate
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If timely corrected, an inadvertent failure to designate qualified

information or items does not, standing alone, waive the 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

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assure that the material is treated in accordance with the provisions of this

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Order.
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VII.

CHALLENGING CONFIDENTIALITY DESIGNATIONS
A.

Timing of Challenges

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1.

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any time that is consistent with the Court’s Scheduling Order.

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B.

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The Challenging Party shall initiate the dispute resolution process under

Local Rule 37.1 et seq.

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Meet and Confer
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Any party or Non-Party may challenge a designation of confidentiality at

C.

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

Designating Party. Frivolous challenges, and those made for an improper purpose

TYSON & MENDES, LLP
445 SOUTH FIGUEROA STREET, SUITE 3100
LOS ANGELES, CA 90071
[phone]/ FAX: [phone]

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(e.g., to harass or impose unnecessary expenses and burdens on other parties) may

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expose the Challenging Party to sanctions. Unless the Designating Party has waived or

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withdrawn the confidentiality designation, all parties shall continue to afford the

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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.
VIII. ACCESS TO AND USE OF PROTECTED MATERIAL
A.

Basic Principles

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1.

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produced by another Party or by a Non-Party in connection with this Action only

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for prosecuting, defending, or attempting to settle this Action. Such Protected

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Material may be disclosed only to the categories of persons and under the

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A Receiving Party may use Protected Material that is disclosed or

conditions described in this Order. When the Action has been terminated, a
Receiving Party must comply with the provisions of Section XIV below.
2.

Protected Material must be stored and maintained by a Receiving Party

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at a location and in a secure manner that ensures that access is limited to the

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persons authorized under this Order.
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Case No. 8:20-cv-01481-MCS-ADSx

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B.

Disclosure of “CONFIDENTIAL” Information or Items

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Designating Party, a Receiving Party may disclose any information or item

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designated “CONFIDENTIAL” only to:

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Unless otherwise ordered by the Court or permitted in writing by the

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 Action;
b.

The officers, directors, and employees (including House Counsel)

of the Receiving Party to whom disclosure is reasonably necessary for this

TYSON & MENDES, LLP
445 SOUTH FIGUEROA STREET, SUITE 3100
LOS ANGELES, CA 90071
[phone]/ FAX: [phone]

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Action;

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c.

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disclosure is reasonably necessary for this Action and who have signed

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

the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
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The Court and its personnel;

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Court reporters and their staff;

f.

Professional jury or trial consultants, mock jurors, and

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Professional Vendors to whom disclosure is reasonably necessary or this

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Action and who have signed the “Acknowledgment and Agreement to be

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Bound” attached as Exhibit A hereto;

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g.

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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;
h.

During their depositions, witnesses, and attorneys for witnesses,

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in the Action to whom disclosure is reasonably necessary provided: (i)

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the deposing party requests that the witness sign the “Acknowledgment
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Case No. 8:20-cv-01481-MCS-ADSx

and Agreement to Be Bound;” and (ii) they will not be permitted to keep

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any confidential information unless they sign the “Acknowledgment and

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Agreement to Be Bound,” unless otherwise agreed by the Designating

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Party or ordered by the Court. Pages of transcribed deposition testimony

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or exhibits to depositions that reveal Protected Material may be

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

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anyone except as permitted under this Stipulated Protective Order; and

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i.

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personnel, mutually agreed upon by any of the parties engaged in

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settlement discussions.

TYSON & MENDES, LLP
445 SOUTH FIGUEROA STREET, SUITE 3100
LOS ANGELES, CA 90071
[phone]/ FAX: [phone]

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Any mediator or settlement officer, and their supporting

IX.

PROTECTED MATERIAL SUPOENAED OR ORDERED PRODUCED IN
OTHER LITIGATION
A.

If a Party is served with a subpoena or a court order issued in other litigation

that compels disclosure of any information or items designated in this Action as
“CONFIDENTIAL,” that Party must:
1.

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Promptly notify in writing the Designating Party. Such notification shall

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include a copy of the subpoena or court order;

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2.

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

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

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Promptly notify in writing the party who caused the subpoena or order to

include a copy of this Stipulated Protective Order; and

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3.

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Cooperate with respect to all reasonable procedures sought to be pursued

by the Designating Party whose Protected Material may be affected.

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B.

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

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the subpoena or court order shall not produce any information designated in this action
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Case No. 8:20-cv-01481-MCS-ADSx

as “CONFIDENTIAL” before a determination by the Court from which the subpoena or

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order issued, unless the Party has obtained the Designating Party’s permission. The

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

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of its confidential material and nothing in these provisions should be construed as

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authorizing or encouraging a Receiving Party in this Action to disobey a lawful directive

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from another court.
X.

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

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

TYSON & MENDES, LLP
445 SOUTH FIGUEROA STREET, SUITE 3100
LOS ANGELES, CA 90071
[phone]/ FAX: [phone]

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in this Action and designated as “CONFIDENTIAL.” Such information produced by

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

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

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a Non-Party from seeking additional protections.
B.

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

Non-Party’s confidential information in its possession, and the Party is subject to an
agreement with the Non-Party not to produce the Non-Party’s confidential
information, then the Party shall:

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1.

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

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with a Non-Party;

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2.

Promptly notify in writing the Requesting Party and the Non-Party that

Promptly provide the Non-Party with a copy of the Stipulated Protective

Order in this Action, the relevant discovery request(s), and a reasonably specific
description of the information requested; and

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3.

Make the information requested available for inspection by the Non-

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Party, if requested.
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Case No. 8:20-cv-01481-MCS-ADSx

C.

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If the Non-Party fails to seek a protective order from this court within 14 days

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of receiving the notice and accompanying information, the Receiving Party may

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produce the Non-Party’s confidential information responsive to the discovery request.

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If the Non-Party timely seeks a protective order, the Receiving Party shall not produce

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any 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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XI.

UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

TYSON & MENDES, LLP
445 SOUTH FIGUEROA STREET, SUITE 3100
LOS ANGELES, CA 90071
[phone]/ FAX: [phone]

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A.

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

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Stipulated Protective Order, the Receiving Party must immediately (1) notify in writing

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

the Designating Party of the unauthorized disclosures, (2) use its best efforts to retrieve
all unauthorized copies of the Protected Material, (3) inform the person or persons to
whom unauthorized disclosures were made of all the terms of this Order, and (4)
request such person or persons to execute the “Acknowledgment and Agreement to be
Bound” that is attached hereto as Exhibit A.
XII. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

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PROTECTED MATERIAL

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A.

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When a Producing Party gives notice to Receiving Parties that certain

inadvertently produced material is subject to a claim of privilege or other protection,
the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure

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may be established in an e-discovery order that provides for production without prior

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privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
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Case No. 8:20-cv-01481-MCS-ADSx

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parties reach an agreement on the effect of disclosure of a communication or

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information covered by the attorney-client privilege or work product protection, the

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parties may incorporate their agreement in the Stipulated Protective Order submitted

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to the Court.

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XIII. MISCELLANEOUS
A.

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1.

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Nothing in this Order abridges the right of any person to seek its

modification by the Court in the future.

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Right to Further Relief

B.

Right to Assert Other Objections

TYSON & MENDES, LLP
445 SOUTH FIGUEROA STREET, SUITE 3100
LOS ANGELES, CA 90071
[phone]/ FAX: [phone]

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1.

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right it otherwise would have to object to disclosing or producing any information

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or item on any ground not addressed in this Stipulated Protective Order.

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Similarly, no Party waives any right to object on any ground to use in evidence of

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By stipulating to the entry of this Protective Order, no Party waives any

any of the material covered by this Protective Order.
C.

Filing Protected Material
1.

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A Party that seeks to file under seal any Protected Material must comply

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with Civil Local Rule 79-5. Protected Material may only be filed under seal

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pursuant to a court order authorizing the sealing of the specific Protected

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Material at issue. If a Party's request to file Protected Material under seal is

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denied by the Court, then the Receiving Party may file the information in the

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public record unless otherwise instructed by the Court.
XIV. FINAL DISPOSITION
A.

After the final disposition of this Action, as defined in Section V, within sixty (60)

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

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Protected Material to the Producing Party or destroy such material. As used in this
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Case No. 8:20-cv-01481-MCS-ADSx

April 27, 2021

/s/ Autumn D. Spaeth

EXHIBIT A
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

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I,

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[print or type full name], of

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[print or type full address], declare under penalty of perjury that I have read in

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its entirety and understand the Stipulated Protective Order that was issue by the United States

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District Court for the Central District of California on ________________[DATE] in the
case of Tin Dinh v. Tornos US Technology Corporation; Case No. 8:20-cv-01481-MCS-ADSx. I
agree to comply with and to be bound by all the terms of this Stipulated Protective Order and
I understand and acknowledge that failure to so comply could expose me to sanctions and

TYSON & MENDES, LLP
445 SOUTH FIGUEROA STREET, SUITE 3100
LOS ANGELES, CA 90071
[phone]/ FAX: [phone]

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punishment in the nature of contempt. I solemnly promise that I will not disclose in any

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

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

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I further agree to submit to the jurisdiction of the United States District Court for the
Central District of California for the purpose of enforcing the terms of this Stipulated Protective
Order, even if such enforcement proceedings occur after termination of this action. I hereby
appoint

[print or type full name] of

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[print or type full address and telephone number] as my California agent for

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service of process in connection with this action or any proceedings related to enforcement of

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this Stipulated Protective Order.

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Date:

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City and State where sworn and signed:
Printed Name:
Signature:

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Case No. 8:20-cv-01481-MCS-ADSx