Blackman v. AutoZone, Inc.
Filing
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STIPULATED PROTECTIVE ORDER signed by District Judge John A. Mendez on 11/14/17. (Mena-Sanchez, L)
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MICHAEL HOFFMAN, Bar No. 162496
AMY C. HIRSH, Bar No. 246533
ARENA HOFFMAN LLP
44 Montgomery Street, Suite 3520
San Francisco, CA 94104-4828
Telephone:
415.433.1414
Facsimile:
415.520.0446
Email:
mhoffman@arenahoffman.com
ahirsh@arenahoffman.com
Attorneys for Defendant
AUTOZONE, INC.
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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GLENN BLACKMAN,
Plaintiff,
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STIPULATED PROTECTIVE ORDER
v.
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Case No. 2:17-CV-00659-JAM-DB
AUTOZONE, INC., and DOES 1 through
20, inclusive,
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Defendants.
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1.
PURPOSES , LIMITATIONS, AND GOOD CAUSE STATEMENT
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Disclosure and discovery activity in this action are likely to involve production of private
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information for which special protection from public disclosure and from use for any purpose other
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than prosecuting this litigation may be warranted. Accordingly, the parties hereby stipulate to and
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petition the court to enter the following Stipulated Protective Order.
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The parties acknowledge that this Stipulated Protective Order does not confer blanket
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protections on all disclosures or responses to discovery and that the protection it affords from public
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disclosure and use extends only to the limited information or items that are entitled to confidential
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treatment under the applicable legal principles. The parties further acknowledge, as set forth in
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Section 11.3, below, that this Stipulated Protective Order does not entitle them to file confidential
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information under seal; Civil Local Rule 141 sets forth the procedures that must be followed and the
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ARENA HOFFMAN LLP
44 Montgomery Street
Suite 3520
San Francisco, CA 94104.4622
415.433.1414
[PROPOSED] STIPULATED
PROTECTIVE ORDER
1.
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standards that will be applied when a party seeks permission from the court to file material under
seal.
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This action may involve private personnel information regarding non-parties, as well as trade
secrets or competitively sensitive confidential and/or proprietary information regarding Defendant’s
business and operations, including but not limited to, confidential business or financial information;
information regarding confidential business practices, or other confidential research, development,
or commercial information (including information implicating privacy rights of third parties); and
proprietary information that would otherwise not generally be available to the public, or which may
be privileged or otherwise protected from disclosure under applicable laws.
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Accordingly, to expedite the flow of information, facilitate the prompt resolution of disputes
over confidentiality of discovery materials, to adequately protect information the parties are entitled
to keep confidential, to address their handling at the end of litigation, and serve the ends of justice, a
protective order for such information is justified. It is the intent of the parties that information will
not be designated confidential for tactical reasons and that nothing be so designated without a good
faith belief that it has been maintained in a confidential, non-public manner and there is good cause
why it should not be part of the public record in this case.
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2.
DEFINITIONS
2.1
Challenging Party: a Party or Non-Party that challenges the designation of
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information or items under this Order.
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2.2
“CONFIDENTIAL” Information or Items: information (regardless of how it is
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generated, stored or maintained) or tangible things that qualify for protection under Federal Rule of
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Civil Procedure 26(c).
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2.3
Counsel (without qualifier): Outside Counsel of Record and House Counsel (as well
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as their support staff).
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2.4
Designating Party: a Party or Non-Party that designates information or items that it
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produces in disclosures or in responses to discovery as “CONFIDENTIAL.”
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ARENA HOFFMAN LLP
44 Montgomery Street
Suite 3520
San Francisco, CA 94104.4622
415.433.1414
[PROPOSED] STIPULATED
PROTECTIVE ORDER
2.
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2.5
Disclosure or Discovery Material: all items or information, regardless of the medium
or manner in which it is generated, stored, or maintained (including, among other things, testimony,
transcripts, and tangible things), that are produced or generated in disclosures or responses to
discovery in this matter.
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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.
2.7
House Counsel: attorneys (and their support staffs) who are employees of a party to
this action. House Counsel does not include Outside Counsel of Record or any other outside
counsel.
2.8
Non-Party: any natural person, partnership, corporation, association, or other legal
entity not named as a Party to this action.
2.9
Outside Counsel of Record: attorneys (and their support staffs) 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 in this action on behalf of that party or are affiliated with a law firm which has
appeared on behalf of that party.
2.10
Party: any party to this action, including all of its officers, directors, employees,
consultants, retained experts, and Outside Counsel of Record (and their support staffs).
2.11
Producing Party: a Party or Non-Party that produces Disclosure or Discovery
Material in this action.
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Professional Vendors: persons or entities that provide litigation support services
(e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and organizing,
storing, or retrieving data in any form or medium) and their employees and subcontractors.
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Protected Material: any Disclosure or Discovery Material that is designated as
“CONFIDENTIAL.”
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Receiving Party: a Party that receives Disclosure or Discovery Material from a
Producing Party.
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ARENA HOFFMAN LLP
44 Montgomery Street
Suite 3520
San Francisco, CA 94104.4622
415.433.1414
[PROPOSED] STIPULATED
PROTECTIVE ORDER
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SCOPE
The protections conferred by this Stipulated Protective 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 Material; and (3) any
testimony, conversations, or presentations by Parties or their Counsel that might reveal Protected
Material. However, the protections conferred by this Stipulated Protective Order do not cover the
following information: (a) any information that is in the public domain at the time of disclosure to a
Receiving Party or becomes part of the public domain after its disclosure to a Receiving Party as a
result of publication not involving a violation of this Order, including becoming part of the public
record through trial or otherwise; and (b) any information known to the Receiving Party prior to the
disclosure or obtained by the Receiving Party after the disclosure from a source who obtained the
information lawfully and under no obligation of confidentiality to the Designating Party.
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Any use of Protected Material at trial shall be governed by a separate agreement or order.
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4.
DURATION
Even after final disposition of this litigation, the confidentiality obligations imposed by this
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Stipulated Protective Order shall remain in effect until a Designating Party agrees otherwise in
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writing or a court order otherwise directs. Final disposition shall be deemed to be the later of (1)
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dismissal of all claims and defenses in this action, with or without prejudice; and (2) final judgment
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herein after the completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of
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this action, including the time limits for filing any motions or applications for extension of time
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pursuant to applicable law.
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5.
DESIGNATING PROTECTED MATERIAL
5.1
Exercise of Restraint and Care in Designating Material for Protection. Each Party or
Non-Party that designates information or items for protection under this Stipulated Protective Order
must take care to limit any such designation to specific material that qualifies under the appropriate
standards. The Designating Party must designate for protection only those parts of material,
ARENA HOFFMAN LLP
44 Montgomery Street
Suite 3520
San Francisco, CA 94104.4622
415.433.1414
[PROPOSED] STIPULATED
PROTECTIVE ORDER
4.
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documents, items, or oral or written communications that qualify – so that other portions of the
material, documents, items, or communications for which protection is not warranted are not swept
unjustifiably within the ambit of this Order.
Mass, indiscriminate, or routinized designations are prohibited. Designations that are shown
to be clearly unjustified or that have been made for an improper purpose (e.g., to unnecessarily
encumber or retard the case development process or to impose unnecessary expenses and burdens on
other parties) expose the Designating Party to sanctions.
If it comes to a Designating Party’s attention that information or items that it designated for
protection do not qualify for protection, that Designating Party must promptly notify all other Parties
that it is withdrawing the mistaken designation.
5.2
Manner and Timing of Designations. Except as otherwise provided in this Order
(see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered,
Disclosure or Discovery Material that qualifies for protection under this Order must be clearly so
designated before the material is disclosed or produced.
Designation in conformity with this Order requires:
(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 the legend “CONFIDENTIAL” to each page that contains protected material. If only a portion
or portions of the material on a page qualifies for protection, the Producing Party also must clearly
identify the protected portion(s) (e.g., by making appropriate markings in the margins).
A Party or Non-Party that makes original documents or materials available for inspection
need not designate them for protection until after the inspecting Party has indicated which material it
would like copied and produced. During the inspection and before the designation, all of the material
made available for inspection shall be deemed “CONFIDENTIAL.” After the inspecting Party has
identified the documents it wants copied and produced, the Producing Party must determine which
documents, or portions thereof, qualify for protection under this Order. Then, before producing the
specified documents, the Producing Party must affix the “CONFIDENTIAL” legend to each page
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ARENA HOFFMAN LLP
44 Montgomery Street
Suite 3520
San Francisco, CA 94104.4622
415.433.1414
[PROPOSED] STIPULATED
PROTECTIVE ORDER
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that contains Protected Material. If only a portion or portions of the material on a page qualifies for
protection, the Producing Party also must clearly identify the protected portion(s) (e.g., by making
appropriate markings in the margins).
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(b) for testimony given in deposition or in other pretrial or trial proceedings, that the
Designating Party identify on the record, before the close of the deposition, hearing, or other
proceeding, all protected testimony.
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(c) for information produced in some form other than documentary and for any other
tangible items, that the Producing Party affix in a prominent place on the exterior of the container or
containers in which the information or item is stored the legend “CONFIDENTIAL.” If only a
portion or portions of the information or item warrant protection, the Producing Party, to the extent
practicable, shall identify the protected portion(s).
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5.3
Inadvertent Failures to Designate. 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 assure that the material is treated in
accordance with the provisions of this Order.
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6.
CHALLENGING CONFIDENTIALITY DESIGNATIONS
6.1
Timing of Challenges. Any Party or Non-Party may challenge a designation of
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confidentiality at any time. Unless a prompt challenge to a Designating Party’s confidentiality
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designation is necessary to avoid foreseeable, substantial unfairness, unnecessary economic burdens,
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or a significant disruption or delay of the litigation, a Party does not waive its right to challenge a
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confidentiality designation by electing not to mount a challenge promptly after the original
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designation is disclosed.
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6.2
Meet and Confer. The Challenging Party shall initiate the dispute resolution process
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by providing written notice of each designation it is challenging and describing the basis for each
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challenge. To avoid ambiguity as to whether a challenge has been made, the written notice must
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recite that the challenge to confidentiality is being made in accordance with this specific paragraph
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ARENA HOFFMAN LLP
44 Montgomery Street
Suite 3520
San Francisco, CA 94104.4622
415.433.1414
[PROPOSED] STIPULATED
PROTECTIVE ORDER
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of the Stipulated Protective Order. The parties shall attempt to resolve each challenge in good faith
and must begin the process by conferring directly (in voice to voice dialogue; other forms of
communication are not sufficient) within 14 days of the date of service of notice. In conferring, the
Challenging Party must explain the basis for its belief that the confidentiality designation was not
proper and must give the Designating Party an opportunity to review the designated material, to
reconsider the circumstances, and, if no change in designation is offered, to explain the basis for the
chosen designation. A Challenging Party may proceed to the next stage of the challenge process only
if it has engaged in this meet and confer process first or establishes that the Designating Party is
unwilling to participate in the meet and confer process in a timely manner.
6.3
Judicial Intervention. If the Parties cannot resolve a challenge without court
intervention, the Designating Party shall file and serve a motion to retain confidentiality under Civil
Local Rule 141.1 (and in compliance with Civil Local Rule 251, if applicable) within 21 days of the
initial notice of challenge or within 14 days of the parties agreeing that the meet and confer process
will not resolve their dispute, whichever is earlier. Each such motion must be accompanied by a
competent declaration affirming that the movant has complied with the meet and confer
requirements imposed in the preceding paragraph. Failure by the Designating Party to make such a
motion including the required declaration within 21 days (or 14 days, if applicable) shall
automatically waive the confidentiality designation for each challenged designation. In addition, the
Challenging Party may file a motion challenging a confidentiality designation at any time if there is
good cause for doing so, including a challenge to the designation of a deposition transcript or any
portions thereof. Any motion brought pursuant to this provision must be accompanied by a
competent declaration affirming that the movant has complied with the meet and confer
requirements imposed by the preceding paragraph.
The burden of persuasion in any such challenge proceeding shall be on the Designating
Party. Frivolous challenges, and those made for an improper purpose (e.g., to harass or impose
unnecessary expenses and burdens on other parties) may expose the Challenging Party to sanctions.
Unless the Designating Party has waived the confidentiality designation by failing to file a motion to
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ARENA HOFFMAN LLP
44 Montgomery Street
Suite 3520
San Francisco, CA 94104.4622
415.433.1414
[PROPOSED] STIPULATED
PROTECTIVE ORDER
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retain confidentiality as described above, all parties shall continue to afford the material in question
the level of protection to which it is entitled under the Producing Party’s designation until the court
rules on the challenge.
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7.
ACCESS TO AND USE OF PROTECTED MATERIAL
7.1
Basic Principles. A Receiving Party may use Protected Material that is disclosed or
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produced by another Party or by a Non-Party in connection with this case only for prosecuting,
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defending, or attempting to settle this litigation. Such Protected Material may be disclosed only to
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the categories of persons and under the conditions described in this Order. When the litigation has
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been terminated, a Receiving Party must comply with the provisions of section 12 below (FINAL
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DISPOSITION).
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Protected Material must be stored and maintained by a Receiving Party at a location and in a
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secure manner that ensures that access is limited to the persons authorized under this Order.
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7.2
Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise ordered by
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the court or permitted in writing by the Designating Party, a Receiving Party may disclose any
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information or items designated “CONFIDENTIAL” only to:
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(a) the Receiving Party’s Counsel in this action (and to the Receiving Party, where
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the CONFIDENTIAL information is received by the Receiving Party’s Counsel);
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(b) the officers, directors, and employees of the Receiving Party to whom disclosure
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is reasonably necessary for this litigation and who have signed the “Acknowledgment and
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Agreement to Be Bound” (Exhibit A);
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(c) Experts (as defined in this Order) of the Receiving Party to whom disclosure is
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reasonably necessary for this litigation and who have signed the “Acknowledgment and Agreement
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to Be Bound” (Exhibit A);
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(d) the court and its personnel;
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(e) court reporters and their staff, professional jury or trial consultants, mock jurors,
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and Professional Vendors to whom disclosure is reasonably necessary for this litigation and who
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have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
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ARENA HOFFMAN LLP
44 Montgomery Street
Suite 3520
San Francisco, CA 94104.4622
415.433.1414
[PROPOSED] STIPULATED
PROTECTIVE ORDER
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(f) during their depositions, witnesses in the action to whom disclosure is reasonably
necessary and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A),
unless otherwise agreed by the Designating Party or ordered by the court. Pages of transcribed
deposition testimony or exhibits to depositions that reveal Protected Material must be separately
bound by the court reporter and may not be disclosed to anyone except as permitted under this
Stipulated Protective Order.
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(g) the author or recipient of a document containing the information or a custodian or
other person who otherwise possessed or knew the information.
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PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER
LITIGATION
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:
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(a) promptly notify in writing the Designating Party. Such notification shall include a
copy of the subpoena or court order;
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(b) promptly notify in writing the party who caused the subpoena or order to issue in
the other litigation that some or all of the material covered by the subpoena or order is subject to this
Stipulated Protective Order. Such notification shall include a copy of this Stipulated Protective
Order; and
(c) cooperate with respect to all reasonable procedures sought to be pursued by the
Designating Party whose Protected Material may be affected.
If the Designating Party timely seeks a protective order, the Party served with the subpoena
or court order shall not produce any information designated in this action as “CONFIDENTIAL”
before a determination by the court from which the subpoena or order issued, unless the Party has
obtained the Designating Party’s permission. The Designating Party shall bear the burden and
expense of seeking protection in that court of its confidential material – and nothing in these
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ARENA HOFFMAN LLP
44 Montgomery Street
Suite 3520
San Francisco, CA 94104.4622
415.433.1414
[PROPOSED] STIPULATED
PROTECTIVE ORDER
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provisions should be construed as authorizing or encouraging a Receiving Party in this action to
disobey a lawful directive from another court.
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UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected
Material to any person or in any circumstance not authorized under this Stipulated Protective Order,
the Receiving Party must immediately (a) notify in writing the Designating Party of the unauthorized
disclosures, (b) use its best efforts to retrieve all unauthorized copies of the Protected Material, (c)
inform the person or persons to whom unauthorized disclosures were made of all the terms of this
Order, and (d) request such person or persons to execute the “Acknowledgment and Agreement to
Be Bound” that is attached hereto as Exhibit A.
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10.
INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED
MATERIAL
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When a Producing Party gives notice to Receiving Parties that certain inadvertently produced
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material is subject to a claim of privilege or other protection, the obligations of the Receiving Parties
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are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to
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modify whatever procedure may be established in an e-discovery order that provides for production
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without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
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parties reach an agreement on the effect of disclosure of a communication or information covered by
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the attorney-client privilege or work product protection, the parties may incorporate their agreement
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in the stipulated protective order submitted to the court.
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MISCELLANOUS
11.1
Right to Further Relief. Nothing in this Order abridges the right of any person to seek
its modification by the court in the future.
11.2
Right to Assert Other Objections. By stipulating to the entry of this Stipulated
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Protective Order no Party waives any right it otherwise would have to object to disclosing or
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producing any information or item on any ground not addressed in this Stipulated Protective Order.
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ARENA HOFFMAN LLP
44 Montgomery Street
Suite 3520
San Francisco, CA 94104.4622
415.433.1414
[PROPOSED] STIPULATED
PROTECTIVE ORDER
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Similarly, no Party waives any right to object on any ground to use in evidence of any of the material
covered by this Stipulated Protective Order.
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11.3
Filing Protected Material. Without written permission from the Designating Party or a
court order secured after appropriate notice to all interested persons, a Party may not file in the
public record in this action any Protected Material. A Party that seeks to file under seal any Protected
Material must comply with Civil Local Rules 141 and 14.1 and General Order 164. Protected
Material may only be filed under seal pursuant to a court order authorizing the sealing of the specific
Protected Material at issue.
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12.
FINAL DISPOSITION
Within 60 days after the final disposition of this action, as defined in paragraph 4, each
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Receiving Party must return all Protected Material to the Producing Party or destroy such material.
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As used in this subdivision, “all Protected Material” includes all copies, abstracts, compilations,
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summaries, and any other format reproducing or capturing any of the Protected Material. Whether
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the Protected Material is returned or destroyed, the Receiving Party must submit a written
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certification to the Producing Party (and, if not the same person or entity, to the Designating Party)
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by the 60 day deadline that (1) identifies (by category, where appropriate) all the Protected Material
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that was returned or destroyed and (2) affirms that the Receiving Party has not retained any copies,
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abstracts, compilations, summaries or any other format reproducing or capturing any of the Protected
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Material. Notwithstanding this provision, Counsel are entitled to retain an archival copy of all
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pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda,
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correspondence, deposition and trial exhibits, expert reports, attorney work product, and consultant
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and expert work product, even if such materials contain Protected Material. Any such archival copies
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that contain or constitute Protected Material remain subject to this Stipulated Protective Order as set
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forth in Section 4 (DURATION).
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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
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44 Montgomery Street
Suite 3520
San Francisco, CA 94104.4622
415.433.1414
[PROPOSED] STIPULATED
PROTECTIVE ORDER
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Case No. 2:17-CV-00659-JAM-DB
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DATED: 11/9/2017
/s/ JILL TELFER
Attorneys for Plaintiff Glenn Blackman
DATED: 11/13/207
/s/ AMY HIRSH
Attorneys for Defendant AutoZone, Inc.
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PURSUANT TO STIPULATION, IT IS SO ORDERED.
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DATED: November 14, 2017
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/s/ JOHN A. MENDEZ
UNITED STATES DISTRICT COURT JUDGE
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ARENA HOFFMAN LLP
44 Montgomery Street
Suite 3520
San Francisco, CA 94104.4622
415.433.1414
[PROPOSED] STIPULATED
PROTECTIVE ORDER
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EXHIBIT A
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
I,
_____________________________
[print
or
type
full
name],
of
_________________ [print or type full address], declare under penalty of perjury that I have read in
its entirety and understand the Stipulated Protective Order that was issued by the United States
District Court for the Eastern District of California on [date] in the case of Glenn Blackman v.
AutoZone, Inc., Case No. 2:17-CV-00659-JAM-DB. 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 punishment in the nature of contempt. I solemnly promise
that I will not disclose in any manner any information or item that is subject to this Stipulated
Protective Order to any person or entity except in strict compliance with the provisions of this Order.
I further agree to submit to the jurisdiction of the United States District Court for the
Eastern 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
_______________________________________ [print or type full address and telephone number] as
my California agent for service of process in connection with this action or any proceedings related
to enforcement of this Stipulated Protective Order.
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Date: _________________________________
City and State where sworn and signed: _________________________________
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Printed name: ______________________________
[printed name]
Signature: __________________________________
[signature]
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ARENA HOFFMAN LLP
44 Montgomery Street
Suite 3520
San Francisco, CA 94104.4622
415.433.1414
[PROPOSED] STIPULATED
PROTECTIVE ORDER
13.
Case No. 2:17-CV-00659-JAM-DB
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