Cartagz, Inc. v. Sanders, et al.

Filing 28

STIPULATED PROTECTIVE ORDER signed by Magistrate Judge Allison Claire on 11/20/2015. (Michel, G.)

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LECLAIRRYAN
Robert S. McWhorter (CA 226186)
Kevin T. Collins (CA 185427)
980 9th Street, 16th Floor
Sacramento, CA 95814
Telephone: [phone]
Facsimile: 916.449.9694
[e-mail]
[e-mail]
Brian C. Vanderhoof
725 S. Figueroa St., Suite 350
Los Angeles, CA 90017
Telephone: [phone]
Facsimile: 213.624.3755
[e-mail]
Attorneys for Defendants
GREGORY SANDERS, CATHY SANDERS,
erroneously sued as KATHY SANDERS,
and CAR REGISTRATION, INC. erroneously
sued as EZTAGS, INC.

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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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CARTAGZ, INC., a California corporation,
Plaintiff,

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v.
GREGORY SANDERS; KATHY SANDERS;
EZTAGS, INC., a California corporation; and  
DOES 1 through 95, inclusive

Case No.: 2:15-cv-01918-MCE-AC
STIPULATED PROTECTIVE ORDER
GOVERNING THE USE AND
DISSEMINATION OF CONFIDENTIAL
INFORMATION

Defendants.

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PROTECTIVE ORDER GOVERNING USE AND DISSEMINATION OF CONFIDENTIAL INFORMATION

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I.

PURPOSES, LIMITATIONS AND SCOPE
1.

Disclosure and discovery activity in this action are likely to involve

production of confidential, proprietary, or private information for which special
protection from public disclosure and from use for any purpose other than
prosecuting this litigation may be warranted. 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 blanket protections on all
disclosures or responses to discovery and that the protection it affords from public
disclosure and use extends only to the limited information or items that are entitled
to confidential treatment under the applicable legal principles. The parties further
acknowledge, as set forth below, that this Stipulated Protective Order does not
entitle them to file confidential information under seal; Civil Local Rules set forth
the procedures that must be followed and the standards that will be applied when a
party seeks permission from the court to file material under seal.
2.

This Protective Order shall govern any document, thing, or

information that is designated as containing “CONFIDENTIAL” or “HIGHLY
CONFIDENTIAL” information, as defined herein1 and that is produced or
disclosed by any party or non-party in connection with the above-captioned action
(“Action”). Documents and other information produced in this Action and
designated “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL” shall be used
only for purposes of this Action. The forms of information which may be subject
to this Protective Order include, but are not limited to, documents and things,
responses to requests to produce documents, responses to interrogatories, responses
to requests for admissions, subpoenaed documents, deposition testimony and
exhibits, deposition transcripts, and all copies, extracts, summaries, compilations,

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1 For the purpose of this order, “HIGHLY CONFIDENTIAL” and “CONFIDENTIAL – ATTORNEYS’
EYES ONLY” have the same meaning and effect and can be used interchangeably.
PROTECTIVE ORDER GOVERNING USE AND DISSEMINATION OF CONFIDENTIAL INFORMATION

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designations and portions thereof (collectively “Discovery Materials”).

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3.

All Discovery Materials produced in discovery in this Action and

designated “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL” shall be used
solely for the purpose of pre-trial proceedings (including, but not limited to,
motions and briefing), settlement, trial preparation, trial, and appeals in connection
with this Action. Discovery Materials shall not be used for any business or nonlitigation related purpose whatsoever.
II.

DEFINITIONS
4.

The following definitions apply in this Protective Order:
(a)

The designation “CONFIDENTIAL” may be applied by

any Party or non-party to any Discovery Materials that contain
information that is not publically available.
(b)

The designation “HIGHLY CONFIDENTIAL” or

“CONFIDENTIAL – ATTORNEYS’ EYES ONLY” may be applied
by any party to highly sensitive forms of information, including, but
not limited to: (i) trade secrets as defined in Cal. Civ. Code
§ 3426.1(d); and/or (ii) extremely sensitive “CONFIDENTIAL”
information or items whose disclosure to another Party or non-party
would create a substantial risk of injury that could not be avoided by
less restrictive means.
(c)

“CONFIDENTIAL INFORMATION” refers to all

information that is subject to the designations “CONFIDENTIAL” or
“HIGHLY CONFIDENTIAL” as described above.
(d)

“Party” means every party to this Action and every

director, officer, employee, and managing agent of every party to this
Action.
(e)

“Order” means this Protective Order.

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PROTECTIVE ORDER GOVERNING USE AND DISSEMINATION OF CONFIDENTIAL INFORMATION

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(f)

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and interpreted to encompass not only those items or things which

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consist of or include CONFIDENTIAL INFORMATION, but also any

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information derived therefrom, and all copies, excerpts, and

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summaries thereof, as well as testimony and oral statements derived

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therefrom or related thereto.

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(g)

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(h)

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(i)

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“Designating Party” means a Party or non-party that

designates Discovery Materials or other information as

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“Receiving Party” means a Party that receives disclosure

or DISCOVERY MATERIAL from a Producing Party.

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“Producing Party” means a Party or non-party that

produces disclosure or DISCOVERY MATERIAL in this Action.

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The scope of this Protective Order shall be understood

“CONFIDENTIAL” or “HIGHLY CONFIDENTIAL.”
III.

TERMS OF THE PROTECTIVE ORDER
A.

Designation

5.

The designation of CONFIDENTIAL INFORMATION shall be made

in the following manner:
(a)

For documents, by placing the appropriate designation on

each page of the document;
(b)

For tangible objects, by placing a label or tag with the

appropriate designation on the object or the container therefor, or, if
not practicable, as otherwise agreed;
(c)

For written responses to discovery by placing the

appropriate designation on the page(s) containing the relevant
responses and on the face of the document containing such
designations; and
(d)

For depositions, during the deposition or in writing

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PROTECTIVE ORDER GOVERNING USE AND DISSEMINATION OF CONFIDENTIAL INFORMATION

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within twenty (20) days after receipt by the Designating Party of the
transcript of the deposition.

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B.

Manner of Designating Documents

6.

A Party shall designate documents containing CONFIDENTIAL

INFORMATION by placing a legend in plain view on each page of any document
that the Party wishes to protect against disclosure or use pursuant to this Order.
This legend shall state “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL” as
appropriate.
C.

Manner of Designating Depositions

7.

A deposition transcript comprising or containing CONFIDENTIAL

INFORMATION shall be designated “CONFIDENTIAL” or “HIGHLY
CONFIDENTIAL” by requesting such treatment thereof either on the record at the
time of the deposition or by written notice after service of the deposition transcript.
If confidential treatment of a deposition transcript is requested on the record at the
time of the deposition, the requesting party shall instruct the court reporter to stamp
or mark each page of the transcript containing the CONFIDENTIAL
INFORMATION with the terms “CONFIDENTIAL” or “HIGHLY
CONFIDENTIAL.” The requesting party may also instruct the court reporter to
separately bind the pages of the transcript that have been designated as
“CONFIDENTIAL” or “HIGHLY CONFIDENTIAL.” If confidential treatment of
a transcript is requested by a party by written notice after completion of a
deposition transcript, such written notice shall be mailed to all other parties within
thirty (30) days after completion and service of the transcript by the court reporter.
Such written notice shall specifically identify by page and line number all portions
of the transcript that should be treated as “CONFIDENTIAL” or “HIGHLY
CONFIDENTIAL” in accordance with this Order. Documents or things used as

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exhibits at a deposition that a Party desires to be subject to this Order shall be
separately stamped or marked “CONFIDENTIAL” or “HIGHLY
CONFIDENTIAL” in the manner described above.
8.

The Parties shall not disseminate a deposition transcript or the

contents thereof beyond the persons designated in paragraph 14 for a period of
thirty (30) days after completion and service of the transcript by the court reporter
in order to give adequate time for a Party or non-party to provide written notice to
designate deposition testimony or exhibits used at depositions as
“CONFIDENTIAL” or “HIGHLY CONFIDENTIAL,” except that deposition
transcripts and exhibits used at depositions may be filed under seal with the Court
in accordance with paragraph 16 for use in connection with the proceedings in this
Action at any time.
D.

Designation of Information Produced by Non-Parties

9.

Any Party may designate documents or things produced by a non-

party pursuant to a subpoena or otherwise as “CONFIDENTIAL” or “HIGHLY
CONFIDENTIAL” by providing written notice to each other Party within fifteen
(15) days of receipt of the documents or things produced by the non-party. Such
written notice shall specifically identify each page of each document or each thing
produced by the non-party that should be treated as “CONFIDENTIAL” or
“HIGHLY CONFIDENTIAL” in accordance with this Order.
10.

The Parties shall not disseminate documents or things produced by a

non-party beyond the persons designated in paragraph 14 for a period of thirty (30)
days after service of the documents or things in order to give adequate time for a
Party or non-party to provide written notice to designate the documents or things
produced as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL,” except that the
documents or things produced by a non-party may be filed under seal with the
Court in accordance with paragraph 16 for use in connection with the proceedings

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PROTECTIVE ORDER GOVERNING USE AND DISSEMINATION OF CONFIDENTIAL INFORMATION

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in this Action at any time.
E.

Inadvertent Production

11.

Each Party retains the right to subsequently re-designate documents

and to require such documents to be treated in accordance with such designations
from that time forward. An inadvertent or unintentional failure to designate
qualified information or things as “CONFIDENTIAL” or “HIGHLY
CONFIDENTIAL” shall not be construed as a waiver, in whole or in part, of (i)
any Party’s claims of confidentiality either as to the specific information
inadvertently or unintentionally disclosed or as to any other confidential material
disclosed prior or subsequent to that date, or (ii) any Party’s right to designate said
material as CONFIDENTIAL or HIGHLY CONFIDENTIAL pursuant to this
Order. In the event of an inadvertent or unintentional failure to designate qualified
information or things, the Producing Party shall promptly notify the Receiving
Party that the information is CONFIDENTIAL or HIGHLY CONFIDENTIAL.
The Producing Party shall further provide the Receiving Party with substitute
copies of the affected documents, marked with the appropriate confidentiality
designation in accordance with this Order.
12.

Upon receiving notice of the confidentiality designation of previously-

produced materials, the Receiving Party shall take reasonable steps to retrieve and
destroy all undesignated copies of the materials, and shall treat the newly
designated materials according to their confidentiality designation under this Order.
Prior to a change in designation by the Producing Party, however, the Receiving
Party shall not be precluded from using the information according to its thenexisting designation or as undesignated if it had no previous designation. No Party
shall be deemed to be in violation of this Order with respect to the disclosure of
any Discovery Material to any other persons prior to the designation of the
Discovery Material as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL”

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PROTECTIVE ORDER GOVERNING USE AND DISSEMINATION OF CONFIDENTIAL INFORMATION

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pursuant to this Order.
13.

Inadvertent or unintentional production of privileged or work product

information will not be construed as an intentional waiver, in whole or in part, of
the privileged or the work product status of the information inadvertently or
unintentionally disclosed. In the event of an inadvertent or unintentional
production of privileged or work product information, the Producing Party shall
promptly notify the Receiving Party that the information is privileged or is work
product. The Producing Party shall further provide the Receiving Party with
substitute copies of the affected documents in which the privileged or work product
information has been redacted.
14.

Upon receiving notice of the Producing Party’s claim of the privileged

or work product status of previously-produced information, the Receiving Party
shall take reasonable steps to retrieve and destroy all un-redacted copies of the
materials containing the privileged or work product information.
F.

Access to Confidential Information

15.

Discovery Material designated as “CONFIDENTIAL” may be

disclosed by the Receiving Party to only the following persons:
(a)

outside attorneys of record for any Party in connection

with this Action (“Outside Counsel”), and to the support personnel
employed by Outside Counsel including law clerks, paralegals,
assistants, secretaries, and clerical staff;
(b)

organizations retained by Outside Counsel to provide

litigation support services in this Action, including, but not limited to,
document imaging services and services producing graphic or visual
aids, provided, however, that before any such person is permitted
access to any CONFIDENTIAL INFORMATION;
(c)

independent outside experts and consultants retained by

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PROTECTIVE ORDER GOVERNING USE AND DISSEMINATION OF CONFIDENTIAL INFORMATION

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Outside Counsel or a Party in connection with this Action, provided,
however, that any such expert or consultant meets the conditions set
forth in paragraph 17, and further provided that before any such
person is permitted access to any CONFIDENTIAL INFORMATION,
such person or a supervising individual in his or her organization shall
have signed the “Non-Disclosure Agreement” (Exhibit A);

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(d)

counsel) of the Receiving Party to whom disclosure is reasonably
necessary for the handling of this litigation and who have signed the
“Non-Disclosure Agreement” (Exhibit A);

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(e)

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transcribing, or translating testimony in this Action;
(f)

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this Action on a confidential basis;
(g)

document or copies thereof were addressed or delivered;
(h)

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the Court and its personnel and all appropriate courts of

appellate jurisdiction; and

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the author of the document containing the

CONFIDENTIAL INFORMATION, or persons to whom such

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any mediator, arbitrator or referee retained by the Parties

to assist them in alternative dispute resolution proceedings relating to

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any court or other shorthand reporters, videographers,

translators, or interpreters involved in the taking, recording,

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the officers, directors, and employees (including in-house

(i)

such other persons as hereafter may be designated by

written agreement of the Parties or by order of the Court.
G.

Access to Highly Confidential Information

16.

Discovery Material designated as “HIGHLY CONFIDENTIAL” may

be disclosed by the Receiving Party to only the following persons:
(a)

outside attorneys of record for any Party in connection

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PROTECTIVE ORDER GOVERNING USE AND DISSEMINATION OF CONFIDENTIAL INFORMATION

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with this Action (“Outside Counsel”), and to the support personnel
employed by Outside Counsel including law clerks, paralegals,
assistants, secretaries, and clerical staff;
(b)

organizations retained by Outside Counsel to provide

litigation support services in this Action, including, but not limited to,
document imaging services and services producing graphic or visual
aids, provided, however, that before any such person is permitted
access to any CONFIDENTIAL INFORMATION, such person or a
supervising individual in his or her organization shall have signed the
“Non-Disclosure Agreement” (Exhibit A);
(c)

independent outside experts and consultants retained by

Outside Counsel or a Party in connection with this Action, provided,
however, that any such expert or consultant meets the conditions set
forth in paragraph 17, and further provided that before any such
person is permitted access to any CONFIDENTIAL INFORMATION,
such person or a supervising individual in his or her organization shall
have signed the “Non-Disclosure Agreement” (Exhibit A);
(d)

any court or other shorthand reporters, videographers,

translators, or interpreters involved in the taking, recording,
transcribing, or translating testimony in this Action;
(e)

any mediator, arbitrator or referee retained by the Parties

to assist them in alternative dispute resolution proceedings relating to
this Action on a confidential basis;
(f)

the author of the document containing the

CONFIDENTIAL INFORMATION, or persons to whom such
document or copies thereof were addressed or delivered;
(g)

the Court and its personnel and all appropriate courts of

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appellate jurisdiction; and

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(h)

written agreement of the Parties or by order of the Court.
H.

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such other persons as hereafter may be designated by

Disclosure of Confidential Information to Outside Experts
and Consultants

17.

The outside experts and consultants referenced in paragraphs 15(c)

and 16(c) shall not include any of the following: (a) the Parties to the Action; (b)
present or former officers, directors, members, employees, servants, investors,
suppliers, vendors, subcontractors, agents, or other representatives acting on a
Party’s behalf; or (c) known business competitors to any of the Parties to this
Action.
I.

Filing Confidential Documents with the Court

18.

All information designated as CONFIDENTIAL INFORMATION

which is to be filed or lodged with the Court, or any pleading, memorandum,
declaration, exhibit or other document purporting to reproduce or paraphrase such
information, shall be filed under seal in accordance with Local Rule 141.
J.

Effect of Confidential Designations

19.

The designation of Discovery Material as CONFIDENTIAL

INFORMATION shall be deemed effective unless and until the Court orders
otherwise or the Designating Party withdraws the designation.
20.

The designation by a Party of any document, material or information

as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL” is intended solely to
facilitate discovery in this Action. This Order shall not prejudice the right of any
Party to bring before the Court a motion in compliance with Local Rule 251 or
other applicable rules seeking a determination that information produced by
another Party has been improperly designated as CONFIDENTIAL
INFORMATION and that such information should not be subject to the terms of

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this Order. In any challenge to a designation, the Designating Party bears the
burden of proof to establish the necessity of the designation, except that the Party
bringing such motion shall have the burden of proving that the information
designated as CONFIDENTIAL INFORMATION has been publically disclosed or
was in possession of the Receiving Party prior to its disclosure through discovery
in this Action.
21.

No Party shall be obligated to challenge the propriety of a

confidentiality designation and the failure to do so shall not constitute acquiescence
as to the appropriateness of the designation or otherwise preclude a subsequent
challenge to the designation.
K.

Exceptions to this Order

22.

Nothing contained in this Order shall affect the right of a Party to

disclose or to use any of its own CONFIDENTIAL INFORMATION as it desires.
23.

Nothing contained in this Order shall affect the right of a Party to

disclose any CONFIDENTIAL INFORMATION to the author or addressees of any
document containing such information.
24.

The provisions of this Order shall not apply to, and any Party may

seek to remove the designation as “CONFIDENTIAL” or “HIGHLY
CONFIDENTIAL” of any information (a) available to the public at the time of its
production hereunder, (b) available to the public after the time of its production
through no act, or failure to act, by the Receiving Party, its counsel,
representatives, experts, or consultants, or (c) obtained from a non-party having the
right to disclose the information. The Receiving Party shall have the burden of
proving that the information should not be designated as “CONFIDENTIAL” or
“HIGHLY CONFIDENTIAL” on the grounds set forth in this paragraph.
L.

Unauthorized Disclosure of Confidential Information

25.

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

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disclosed CONFIDENTIAL INFORMATION to any person or in any circumstance
not authorized under this Order, the Receiving Party must immediately (a) use its
best efforts to retrieve all copies of the CONFIDENTIAL INFORMATION, (b)
inform the person or persons to whom unauthorized disclosures were made of all
the terms of this Order, and (c) request that such person or persons execute the
“Non-Disclosure Agreement” (Exhibit A).
M.

Final Disposition of Action

26.

After the final disposition of this Action, including appeals, any Party

may serve written notice on the other Parties demanding that counsel of record for
each Party promptly destroy, or see to the destruction of, all CONFIDENTIAL
INFORMATION and all writings related thereto that are not in the custody of the
Court, and certify to the Designating Party that such destruction has been done. As
an exception to the above, counsel of record may retain a file copy of any pleadings
or other documents filed with the Court, written discovery responses, and
transcripts of depositions and trial testimony, together with all exhibits thereto.
Counsel for the Parties may also retain copies of their work product that
incorporates, describes, or refers to CONFIDENTIAL INFORMATION. The
copies of these retained documents shall be treated as “HIGHLY
CONFIDENTIAL.”
N.

Survival of Terms

27.

Absent written modification hereof by the Parties hereto or further

order of the Court, the provisions of this Order that restrict the disclosure and use
of CONFIDENTIAL INFORMATION shall survive the final disposition of this
Action and shall continue to be binding on all persons subject to the terms of this
Order.
O.

Violation of Order

28.

In the event anyone shall violate or threaten to violate any term of this

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Order, the Parties agree that the aggrieved Party may immediately apply to obtain
injunctive relief against any such person violating or threatening to violate any of
the terms of this Order and, in the event the aggrieved party shall do so, the
respondent person subject to the provisions of this Order shall not employ as a
defense thereto the claim that the aggrieved Party possesses an adequate remedy of
law. The Parties and any other person subject to the terms of this Order agree that
this Court has jurisdiction over such person or party for the purpose of enforcing
this Order. In the event that any CONFIDENTIAL INFORMATION is disclosed
by a Receiving Party in violation of this Order, the CONFIDENTIAL
INFORMATION shall not lose its status as CONFIDENTIAL INFORMATION
through such disclosure, and the Parties shall take all steps reasonably required to
assure its continued confidentiality.
P.

Subpoena in Another Action

29.

A Receiving Party that is served with a subpoena or other compulsory

process seeking the production of CONFIDENTIAL INFORMATION shall
promptly, and before producing such materials, notify the requesting party of this
Order, and notify counsel for the Designating Party of the receipt of such
compulsory process and provide counsel for the Designating Party with copies of
that process. Nothing in this Order, however, shall be construed as authorizing a
Party to disobey a lawful subpoena issued in connection with another action or
proceeding.
Q.

Right to Assert Other Objections

30.

By stipulating to the entry of this Order no Party waives any right it

otherwise would have to object to disclosing or producing any information or item
on any ground not addressed in this Order. Similarly, no Party waives any right to
object on any ground to use in evidence of any of the material covered by this
Order. Nothing herein affects, in any way, the admissibility of any document,

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testimony, or other evidence at trial or restricts the use of information obtained
from investigations, interviews or sources other than via the discovery process or
voluntary disclosure of information by any Party conducted under the terms of this
Order.
R.

Use of Confidential Information at Trial

31.

The Court will determine, in its sole discretion, how documents

designated as CONFIDENTIAL or HIGHLY CONFIDENTIAL will be treated
during the trial of this Action. The Parties agree to request, prior to trial, that the
Court make an appropriate order to maintain the confidentiality of
CONFIDENTIAL INFORMATION during the course of the trial to the extent
practicable.
S.

Modification of Order

32.

Nothing herein shall preclude any Party upon proper notice to all other

Parties from applying to the Court for any modification of this Order, for relief
from the restrictions contained in this Order, or for further or additional protective
orders.
THE FOREGOING IS STIPULATED AND AGREED TO BY:

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Dated: November 11, 2015

LECLAIRRYAN LLP

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By: /s/Kevin T. Collins
Kevin T. Collins
Brian C. Vanderhoof

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Attorneys for Defendants and CrossComplainants GREGORY SANDERS,
CATHY SANDERS, erroneously sued
as KATHY SANDERS, and CAR
REGISTRATION, INC. erroneously
sued as EZTAGS, INC.

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Dated: November 11, 2015

Law Offices of Matthew V. Brady

PROTECTIVE ORDER GOVERNING USE AND DISSEMINATION OF CONFIDENTIAL INFORMATION

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By: /s/ Matthew V. Brady(as authorized on 11/11/15)
Matthew V. Brady

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Attorneys for Plaintiff Cartagz, Inc. a
California Corporation

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ORDER

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Pursuant to stipulation and good cause having been found, IT IS SO
ORDERED.

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Dated: November 20, 2015

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EXHIBIT A

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NON-DISCLOSURE AGREEMENT
I, _________________________________________________, state that:
1.

My address is

________________________________________________________________.
2.

My current employer is

________________________________________________________________.
3.

My present occupation or job title is

________________________________________________________________.
4.

I have received a copy of the Protective Order Re Confidentiality

entered in the case of Cartagz, Inc., v. Gregory Sanders, et al., United States
District Court for the Eastern District of California Case No. CV 2:15-cv-01918MCE-AC.
5.

I have read and understand the Protective Order Re Confidentiality. I

hereby agree to comply with all of the terms of the Protective Order, including
holding in confidence and not disclosing to any unqualified person all documents,
things, or information designated “CONFIDENTIAL,” or “HIGHLY
CONFIDENTIAL,” or “CONFIDENTIAL – ATTORNEYS’ EYES ONLY.”
6.

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

for the Eastern District of California for the purposes of enforcing the Protective
Order Re Confidentiality and this agreement to be bound thereby.

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Dated: __________________

__________________________________
SIGNATURE

__________________________________
PRINT NAME

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PROTECTIVE ORDER GOVERNING USE AND DISSEMINATION OF CONFIDENTIAL INFORMATION